I only copied the sections Jeffery had in his post. If you read the two documents, it adds up to follow the whole standard or be in possible violation. I like it. I'm going to write up something for our newsletter based on all the good comments and questions in this thread.

Monona Rossol, M.S., M.F.A., Industrial Hygienist

President: Arts, Crafts & Theater Safety, Inc.

Safety Officer: Local USA829, IATSE

181 Thompson St.., #23

New York, NY 10012 212-777-0062

actsnyc**At_Symbol_Here**cs.com www.artscraftstheatersafety.org

-----Original Message-----
From: James Kaufman <jim**At_Symbol_Here**LABSAFETY.ORG>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Sun, Jul 8, 2018 11:05 am
Subject: Re: [DCHAS-L] Emergency Shower and Eyewash Temperatures

I believe the Z-358.1 requires weekly activation (not testing) and annual testing.

James A. Kaufman, Ph.D.
Founder, LSI

On Sun, Jul 8, 2018, 7:48 AM Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote:

Jeffery: You'll be pleased to know MIOSHA has updated their fact sheet and their standards.

https://w2.lara.state.mi.us/ADMS/File/ViewDmsDocument/13189

MIOSHA-STD-07-1R4

April 12, 2018

Eyewash/Shower Equipment page 4

XIII. Application of Standards

B. The terms suitable facilities, quick drench showers, acceptable facilities,

appropriate eyewash facilities, emergency shower and eye-wash station, eye wash

station, and facilities, as utilized in any of the specified standards/rules, shall be

defined as a plumbed or self-contained emergency shower and/or eyewash

equipment, or eye/face wash equipment, meeting the engineering design

specifications of the American National Standard for Emergency Eyewash and

page 5

Shower Equipment (i.e., ANSI Z358.1 - 2014). This Instruction relies on ANSI

Z358.1 - 2014, to determine how quickly the control valve must be operated.

ANSI states that activation of the eyewash control valve shall occur in 1 second or

less and be simple to operate. MIOSHA has made a clarification that more than

one motion to activate the eyewash is permitted as long as the activation occurs in

one second or less. A second/separate motion to remove nozzle covers is not

allowed.

Note the "shall" for the actual equipment. And the new fact sheet covers the other issues and it now reads:

https://www.michigan.gov/documents/dleg/eyewash_292559_7.pdf Revised 06/21/18

What does "suitable facilities" mean?

The terms suitable facilities, appropriate eyewash facilities, and other such terms that appear in

various MIOSHA standards/rules, can be met by following the ANSI (American National Standard

Institute) standard for Emergency Eyewash and Shower Equipment (Z358.1 - 2014).

The emergency eyewash/shower must be activated within 1 second and must not require a separate

action to remove covers. Many eyewash covers are pushed off/open by water pressure. Ensure

employees are properly trained in the operation and activation of the eyewash/shower and that activation occurs in 1 second or less.

and

Does MIOSHA require the supply of tempered water at plumbed eyewash and safety showers?

MIOSHA standards do not require any specific temperatures. However, implied in the term "suitable facility" is providing a water temperature that is not too cold or hot. ANSI Z358.1 - 2014 recommends that tepid water (temperatures between 60 =B0-to-100 =B0 F) be supplied. Temperatures below 60 =B0 F may cause the employee not to use the facility long enough (15-minutes). Temperatures above 100 =B0 F may be too hot and enhance chemical interactions with the eyes and skin.

and

Does MIOSHA require testing of such facilities?

MIOSHA standards do not specifically require

testing of plumbed emergency eyewashes or safety

showers. Follow the manufacturer's

recommendation for testing. ANSI Z358.1 - 2014

specifies that testing of such equipment be

performed on a weekly basis. Remember that these

facilities are provided for "emergency use." Testing

is necessary to ensure that facilities perform per the

manufacturer's specifications.

Looks like a done deal in Michigan to me. Lord, Nice to know some safety agency is still working in the country.

Monona Rossol, M.S., M.F.A., Industrial Hygienist

President: Arts, Crafts & Theater Safety, Inc.

Safety Officer: Local USA829, IATSE

181 Thompson St., #23

New York, NY 10012 212-777-0062

actsnyc**At_Symbol_Here**cs.com www.artscraftstheatersafety.org

-----Original Message-----
From: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Fri, Jul 6, 2018 5:01 pm
Subject: Re: [DCHAS-L] Emergency Shower and Eyewash Temperatures

Note that the same ANSI standard that recommends tepid water also recommends weekly testing. Like OSHA, our state MIOSHA doesn't "require" following the ANSI standards, but makes it clear they expect it as seen in these excerpts from the "MIOSHA Fact Sheet, Eyewashes and Safety Showers":

NOTE when reading these that failure to provide a suitable facility can be deemed a violation.

What does "suitable facilities" mean?

The terms suitable facilities, appropriate eyewash facilities, and other such terms that appear in various MIOSHA standards/rules, can be met by following the ANSI (American National Standard Institute) standard for Emergency Eyewash and Shower Equipment (Z358.1 - 2004). [Note, I've deleted two sentences because they are changing the definition of when they are required and distance from hazard; the new requirements now mirror the ANSI standard] The ANSI standard also provides eyewash/shower specifications, inspection requirements, and other important elements.

and

Does MIOSHA require the supply of tempered water at plumbed eyewash and safety showers?

MIOSHA standards do not require any specific temperatures. However, implied in the term "suitable facility" is providing a water temperature that is not too cold or hot. ANSI Z358.1 - 2004 recommends that tepid water (temperatures between 60 =B0-to-100 =B0 F) be supplied. Temperatures below 60 =B0 F may cause the employee not to use the facility long enough (15-minutes). Temperatures above 100 =B0 F may be too hot and enhance chemical interactions with the eyes and skin.

and

Does MIOSHA require testing of such facilities?

MIOSHA standards do not specifically require testing of plumbed emergency eyewashes or safety showers. However, ANSI Z358.1 - 2004 does require the testing of such equipment on a weekly basis. The pertinent point to remember is that such facilities are provided for "emergency use." Facilities that are not routinely tested may not perform per the manufacturer's specifications and deliver uncontaminated water. This can result in the employer failing to provide a "suitable facility" and more importantly leave employees unprotected.

Jeff

On Fri, Jul 6, 2018 at 4:13 PM <mail**At_Symbol_Here**echelonenvironmental.net> wrote:

Mr. Towle,

Back to the original question: "Are there any regulations surrounding eyewash and emergency shower temperatures?"

The answer is No.

OSHA (the regulatory body in our case) has a regulation at 29 CFR 1910.151(c) which requires eyewash/showers to be available where employees can be exposed to chemicals hazardous to the skin or eyes. Nowhere in this rule is a temperature range specified for the water.

OSHA often refers to ANSI [Z]358.1-2004 which does specify a temp range of 85 to 100F, but this is guidance only - not enforceable.

Guidance is good though, because if your employee has to use an ice cold or scalding hot eyewash/shower, your insurance company will be much displeased and their lawyer will be dancing all the way to the bank.

I hope this helps. Good luck.

Ron Harvey

Echelon Environmental

843-599-0330

https://www.linkedin.com/in/ronharvey/

-------- Original Message --------
Subject: Re: [DCHAS-L] Emergency Shower and Eyewash Temperatures
From: Tyrell Towle <tyrelltowle**At_Symbol_Here**GMAIL.COM>
Date: Fri, July 06, 2018 11:23 am
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU

Thank you for your input, everyone! This is a lot of great information for me to use moving forward.

Upon further inspection of our setup, there is a single mixing valve beneath each handwashing sink that feeds both the sink and the emergency eyewash. Has anyone encountered this configuration before? To me, it seems that there should be a separate mixing valve for the handwashing sink and the eyewash since they have different temperature requirements.

Anyway, thank you, again!

-Tyrell

On Fri, Jul 6, 2018 at 11:56 AM, Chance, Brandon <bchance**At_Symbol_Here**mail.smu.edu> wrote:

Also, remember that mixing valves fail. I have had situations where mixing valves that served all of the units on a floor have failed on the hot side, resulting in a complete system having water above 120F. We have asked our Facilities group to ensure the valves are part of the building preventative maintenance plan after we had to rebuild or replace a number of them.

Regards,

Brandon S. Chance, MS, CCHO

Director of Environmental Health and Safety

Sustainability Committee Chair

Office of Risk Management

Southern Methodist University

PO Box 750231 | Dallas, TX 75275-0231

T) 214.768.2430 | M) 469-978-8664

bchance**At_Symbol_Here**smu.edu

"=E2=80=A6 our job in safety is to make the task happen, SAFELY; not to interfere with the work-" Neal Langerman

From: ACS Division of Chemical Health and Safety on behalf of Penny Manisco
Reply-To: ACS Division of Chemical Health and Safety

Date: Thursday, July 5, 2018 at 6:14 PM

To: "DCHAS-L**At_Symbol_Here**PRINCETON.EDU"
Subject: Re: [DCHAS-L] Emergency Shower and Eyewash Temperatures

Hi All,

This is so weird because this exact thing happened in one of our newly renovated labs. A few weeks ago I was instructing students on flushing eyewash and safety shower and noticed the shower was scalding hot. The eyewash/shower had been installed last summer and has been fine all year. I checked a second system in that lab only to find that the shower was not functioning at all. It turned out that someone (contractors remodeling a restroom perhaps?) had erroneously turned off the cold water valve that feeds the emergency equipment. That caused scalding water at one end of the room, and no pressure at the other. The eyewash and shower are fed with water from a mixing valve.

This is why we check!

Best,

Penny Manisco

Chemical Hygiene Officer

Harvey Mudd College

On Thu, Jul 5, 2018 at 2:14 PM, Tyrell Towle <Tyrell**At_Symbol_Here**medpharmholdings.com> wrote:

Hello everyone,

This may seem like a basic question, but I am getting some pushback from our plumbing contractors on this.

We have a brand new facility and I went through to test all of the eyewash and emergency shower stations. At first everything seemed to be working fine, but then I noticed that the emergency eyewash water was getting warmer. I was horrified when the eyewash water became hot. I have never encountered hot eyewash water before. I had the contractors re-plumb the eyewash stations into cold tap water only. Now they are pushing back, wanting to hook the eyewash stations back into the hot water.

I also noticed that our emergency shower is releasing hot water.

Are there any regulations surrounding eyewash and emergency shower temperatures? My understanding has always been to have cold, potable tap water running into emergency showers and eyewashes so that chemical reactions are not accelerated upon exposure to heat. Regardless, with the temperatures that our eyewash stations were reaching, there was no way that anyone could keep their eyeballs open for 10 minutes in this water. Any information is appreciated, especially information that will put this debate to rest.

Thank you!

Tyrell R. Towle, Ph.D.
Senior Chemist
MedPharm Holdings, LLC
www.medpharmholdings.com

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--

Penny Manisco,
Chemical Hygiene Officer
Harvey Mudd College

(909)6074217

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Jeff Lewin

Chemical Safety Officer

Compliance, Integrity, and Safety

Environmental Health and Safety

Michigan Technological University

Houghton, MI 49931

O 906-487.3153

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