Subject: RE: [DCHAS-L] Thoughts on some arguments against drains under safetyshowers
Date: October 3, 2018 at 1:06:13 PM EDTFrom my experience, your architects have two very valid points. The drains we have below our showers are connected to sanitary drains and are often giving off sewer gas when the trap dries out. So yes, I concur with the source of microbiological growth. Who would maintain these drains if you have them? Can custodial services fill them with water monthly and keep them clean?
Whenever we have had a shower deploy, for either an emergency or vandalism, the majority of the water ends up all over the corridors and surrounding rooms, we don‰??t have sloped floors or any type of berm, so again, they have a valid point for a value engineering standpoint.
Stephanie‰??s point that a contaminated individual might allow RCRA material to go into the drain is a valid point in an exposure event. When barium is used for medical imaging procedure, that release is exempt for medical purposes, the same is true for radioisotopes used in medical testing ‰?? so the question is ‰?? is a chemical exposure (a medical emergency) medically exempt?
Chemical exposure are infrequent (at least they should be) and the amount of material is usually negligible in the decon water, so there should be some guidance or exception as to emergency decon of personnel as opposed to decon from a planned response.
Has anyone ever collected the rinse water from and emergency shower decon and them have it tested? Or collected and sent out as Hazardous waste?
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From: ILPI Support
Subject: Re: [DCHAS-L] Thoughts on some arguments against drains under safetyshowers
Date: October 3, 2018 at 1:10:02 PM EDTYes, you did. Such washings are ‰??de minimums‰?? and specifically exempt under federal (and presumably most if not all state) law. Archived answer to that very question:
http://www.ilpi.com/dchas/2018/20180313d.html
Rob Toreki
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From: Michael
Subject: Re: [DCHAS-L] Thoughts on some arguments against drains under safety showers
Date: October 3, 2018 at 1:14:20 PM EDT
The purpose of a safety shower is in an emergency get the chemical agents off of the person as soon as possible to prevent further injury. The person that has had an acid spill on them is not going to think or care about the contaminants going down the drain.
Mike Buczynski
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From: "Chainani, Edward Torres"
Subject: Re: [DCHAS-L] Thoughts on some arguments against drains under safetyshowers
Date: October 3, 2018 at 1:15:30 PM EDT
To: ACS Division of Chemical Health and Safety
The effluent resulting from use of a safety shower are considered ‰??de minimis losses‰?? and are exempted from the definition of hazardous waste, except where prohibited by the receiving POTW.
In 40 C.F.R. 261.3(a)(2)(iv)(D): "For purposes of this paragraph (a)(2)(iv)(D), de minimis losses are inadvertent releases to a wastewater treatment system, including those from ‰?| discharges from safety showers and rinsing and cleaning of personal safety equipment; ‰??
This matter was discussed In the DCHAS report on the Safety Shower and Eyewash Survey and Recommendations for the 2019 Revision of ANSl/ISEA 2358.1, on page 13, and also on page 25 (appendix B):
https://dchas.org/wp-content/uploads/2016/12/DCHAS-Report-to-ISEA.pdf
Regards,
Edward Chainani, Ph.D.
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From: Steve McLean
Subject: RE: [DCHAS-L] Thoughts on some arguments against drains under safetyshowers
Date: October 3, 2018 at 1:18:39 PM EDT
Take a look at 40 CFR 261.3(a) (2) (iv) (D).
SJM
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From: "GOODE, SCOTT"
Subject: RE: [DCHAS-L] Thoughts on some arguments against drains under safety showers
Date: October 3, 2018 at 1:24:38 PM EDTI work with architects and engineers on designing labs and I generally oppose floor drains under safety showers. You need floor drains in all research labs, in which overnight experiments are done, and possibly near sinks where spills might occur (like the one you use to fill demineralized water carboys) and locations where you handle liquids.
One reason is that in over 4.5 decades, I‰??ve only seen one safety showers used, and that was in a research lab. The proximate cause was a solvent fire. The safety shower is needed for safety and is required by OSHA if you are handling corrosive chemicals. But floor drains are not necessary. The traps dry out (even when trap primers are installed) and allow odors into the lab and they are generally not successful in handing more than a fraction of the 22 gpm flow from a shower head.
Our renovation-in-progress adds 17 new labs, 88 hoods, and 22 safety showers. We have some areas like prep rooms with two floor drains but did not specifically install drains under safety showers. Our eyewash stations all have drains because it‰??s easier to handle a 2-gpm flow.
Also, I‰??ve received support from our local EHS to add a bypass valve that will allow us to connect a garden hose to the safety shower supply to flush the system. We will install a lockout/tagout valve that will be locked into the shower position except during the flushing operation. EHS is quite happy because they realize that flushing will become safer, easier, and thus more likely to occur.
=================
Scott Goode, Distinguished Professor Emeritus
Fellow of the American Chemical Society, ACSF
Department of Chemistry and Biochemistry
University of South Carolina
631 Sumter Street
Columbia SC 29208
Email: Goode**At_Symbol_Here**sc.edu
Mobile: 803-622-1060
===
From: Jennifer Mattler
Subject: Re: [DCHAS-L] Thoughts on some arguments against drains under safety showers
Date: October 3, 2018 at 1:28:53 PM EDT
To: "DCHAS-L**At_Symbol_Here**PRINCETON.EDU"
At Stanford we recommend the installation of floor drains, but they are rarely installed. In our lab design guide we require a plug to cover, when not in use, in order to prevent hazmat spills from being released to the sewer. However, during eyewash/safety shower emergency use, it is fine to release hazmat to the sewer if it is to protect life or health.
https://ehs.stanford.edu/manual/laboratory-standard-design-guidelines/design-maintenance-and-use
Jennifer Mattler
Industrial Hygienist/Asst. CHO
Stanford University, EH&S
650-723-0183
===
From: "Zack Mansdorf"
Subject: RE: [DCHAS-L] Thoughts on some arguments against drains under safety showers
Date: October 3, 2018 at 1:30:01 PM EDT
To: "'ACS Division of Chemical Health and Safety'" Well said Robert. Old fish tales (non-sexist) and hysteria.
Quick story of a shower that had a valve break during testing outside of a Level 3 Biolab and resulted in water seeping past the chamber doors and the decontamination of two labs at a cost of several hundreds of thousands of dollars to include the loss of several minus 80 freezers and months of delay in the research. Don‰??t need a drain?-do a risk assessment or a what-if analysis and then decide.
One other quick point. The solution to pollution is dilution (you have all heard this many times before). I can‰??t image a situation where the shower wash from a splash would be so toxic that it would need to be held as a hazardous waste. Better to worry about that later than to contaminate the entire floor!
Zack
S.Z. Mansdorf, PhD, CIH, CSP, QEP
Consultant in EHS and Sustainability
===
From: Alan Hall
Subject: Re: [DCHAS-L] Thoughts on some arguments against drains under safety showers
Date: October 3, 2018 at 1:40:00 PM EDT
Et al,
Why you should have drains under safety shower/eyewashes:
- The diluted rinsings following the Z358.1 Standard wouldn'tlikey be cncentrated enough to cause any harm. Say a student a student spills 50 ml of 20% NaOH on his arm and gets in the shower for 15 minutes. Someone work out the math. What's going to end up in the drain?
- In an EPA assessment of mass casualty decontamination, they stated that the run-off fluid wasn't much of an environmental concern.
- The damage to labs, equipment, walls, etc, perhaps from student "pranks" by activating the equipment or legitmate decontaminause.(think mold development in drywall and other construction materials? Duh? Health hazard? Downstream mucho costs?
Being a member of the ANSI/ISEA Z358.1 Standard revision committee, there's lots of reasons from plumbing codes and so forth why we don't include drains in the standard. Your can can only fix so much and then common sense (the rarest common thing in the world) must take over. You want all that water all over everywhere just because it might cost a few dollars to put in an acceptable drain concistent will all other applicable things?
Alan
Alan H. Hall, M.D.
Medical Toxicologist
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From: "Meschewski, Brian D"
Subject: RE: [DCHAS-L] Thoughts on some arguments against drains under safety showers
Date: October 3, 2018 at 2:39:52 PM EDTYep. We would always take the excess water from testing our showers/eyewashes and just pour it down the floor drain.
Floor drains are required wherever a safety shower is installed per our state plumbing code (according to our plumbers). Discharges from safety showers fall under the RCRA de minimis loss exemption anyway, provided they meet a few CWA requirements.
I have tested safety showers and have been present in a lab where a safety shower needed to be used. I have seen the aftermath of safety showers in crowded labs as well. Even in labs with a floor drain, it is going to be a mess. If your plan is to collect this water and treat it as a hazardous waste, consider the flow rate of the shower, the required time someone should be under the shower, and where the water is going to go in the meantime. Suddenly having 300 gallons of potentially hazardous water on the floor spreading to neighboring labs and offices is not something I would ever want to encounter. Now imagine that lab or its neighbors contains electrical hazards, or any other number of scenarios.
Add in the safety of the person who is likely naked and panicking under the shower, and I really do not want to worry about potential issues elsewhere. On a side note, I encourage everyone to consider installing curtains that can be closed around a safety shower to at least give that person a bit of privacy.
Let‰??s hope you are on good terms with your neighbors, and that they brought an umbrella.
Brian Meschewski
Research Safety Professional
Division of Research Safety
University of Illinois at Urbana-Champaign
(217)333-2423
bmesche2**At_Symbol_Here**illinois.edu
===
From: Ken Kretchman
Subject: Re: [DCHAS-L] Thoughts on some arguments against drains under safety showers
Date: October 3, 2018 at 2:47:44 PM EDT
To: ACS Division of Chemical Health and Safety
I think there is a much greater chance of a significant chemical release down a fume hood sink drain than the residue from the emergency use of a safety shower
which should be insignificant. The water is the significant release.
Shower without drains are ones that are less likely to be used when needed for fear of the flooding that Rob refers to. We push for putting them in where we can these days for a variety of reasons.
Ken
Ken Kretchman, CIH, CSP Director, Environmental Health and Safety
NC State University / Box 8007 / 2620 Wolf Village Way / Raleigh North Carolina 27695-8007
Email: Ken_Kretchman**At_Symbol_Here**ncsu.edu / Phone: (919).515.6860 / Fax: (919).515.6307
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