IIAR

By Andrea Fischer

Efficient, tested eyewash and shower stations that are properly built, installed, and maintained are a central part of any machine room, and eyewash and shower procedures are a basic part of emergency response planning, at least where EPA and OSHA regulations are concerned. But although the ammonia refrigeration industry considers eyewash and shower equipment and procedures integral to operations wherever safety is an issue, little formal guidance is actually available when it comes to where and how stations should be installed, outside of the obvious areas where high volumes of ammonia are consistently present.

“Far too many companies have no formal overall plan or guidance for where they should locate eyewash and shower stations and what type of stations they should install throughout their facilities,” said Peter Jordan, Senior Principal Engineer of MBD Risk Management Services. Jordan presented a technical workshop focused on the positioning of eyewash and shower stations at the IIAR 2012 Industrial Refrigeration Conference & Exhibition.

“There’s a big gray area between the explicit need for an eyewash and shower station in a machine room for example, and the potential need everywhere else in a facility. For most of the industry, there aren’t many clear guidelines, or in some cases no advice at all on how to handle eyewash and shower stations anywhere but the machine room,” said Jordan.

Addressing that gray area can be a challenge for facilities without a formal strategy for positioning eyewash and shower equipment. Installing permanent eyewash and shower stations in every part of a facility that has even a small chance that an exposure to ammonia might occur can be prohibitively expensive. But focusing only on the machine room to the exclusion of all other, even unlikely, hazardous areas can be a potentially dangerous response.

The answer, said Jordan, is to establish a clear method to determine where to install different kinds of emergency eyewash and shower equipment according to the risk and likelihood of exposure to ammonia. Then, he said, that method should be applied to every area of a facility where ammonia is present.

Jordan worked on a project to develop just such a strategy for a large IIAR member and end-user company. “We worked closely to develop a philosophy and method to answer the questions surrounding where to put eyewash and shower stations, and how to determine what kinds of eyewash and shower stations are most effective in what kinds of areas and use cases,” said Jordan.

That philosophy and method can be used to develop a plan for installing a comprehensive eyewash and safety shower system at almost any facility because it employs an easy to apply evaluation using a risk ranking method, said Jordan. The objective is to evaluate risk and likelihood of exposure to ammonia and respond in an appropriate measure.

For example, a large volume of ammonia in one area where maintenance is routinely performed would rank high on a “likelihood and severity of exposure” risk matrix and would require a permanent eyewash and shower station. A smaller volume of ammonia where maintenance is only rarely performed, for example on the roof of a facility, might carry a low exposure risk and would only require a temporary eyewash and shower station to constitute an adequate safety response. “The questions to answer are, where can you go permanent and where can you go temporary, and what are your options when it comes to temporary stations?” said Jordan.

The first step in developing the risk matrix Jordan uses to determine appropriate eyewash and shower equipment resources at a facility was to take a look at all available regulatory guidance.

According to ANSI, IIAR-2-2008 requirements, an emergency unit must be installed “external to each machinery room readily accessible via an exit.” Additionally, units inside each machinery room must be positioned “such that no unit is further than 10 seconds or 55 feet [16.8 m] from a hazard.”

The IIAR-2 guidance is clear, but does not address any safety scenarios beyond the machine room, such as how to provide eyewash and safety shower capabilities when necessary in other cases, said Jordan, who added that he next examined OSHA requirements.

According to OSHA requirement 29 CFR 1910.151(c): “Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.”

The OSHA language brings up several considerations, said Jordan, including the idea that even if a facility has emergency eyewash and shower equipment available at fixed locations, and safety plans that make use of personal protective equipment, an eyewash and shower safety plan should still make provisions for a “last resort,” or a ready method of eyewash and safety shower capabilities. “What this says to me is that we can’t just rely on other safety methods,” said Jordan. “We still have to have a backup when it comes to eyewash and shower capability.”

Perhaps some of the most specific guidance concerning eyewash and shower program strategies comes from concerns raised during facility inspections conducted by EPA region 7 officials, said Jordan.

Companies developing an eyewash and safety shower philosophy can look to four specific citations issued as a result of these inspections to learn how to watch out for weaknesses that regulators are looking for in eyewash and safety shower programs.

According to Jordan, EPA’s four citations addressed: the absence of units in all areas where potential eye injuries could occur; cases where inspection records were not available, and, or inspections were not performed; units that discharged rusty water; and units that didn’t comply with ANSI design and operation standards.

The last citation in that list is an especially important item to pay attention to because any eyewash and safety shower plan should meet all the provisions set out by ANSI/ISEA Z358 1-2009, the ANSI standard that provides minimum requirements for emergency eyewash and shower equipment.

This standard addresses the performance, use, installation, test procedures, maintenance and training related to permanent eyewash and shower stations and identifies a number of choices for temporary eyewash and shower stations. “This ANSI standard is really the bible for eyewash and safety shower,” said Jordan. “Any safety plan should begin and end with this standard.”

The first three descriptions of safety options for eyewash and shower units laid out by the ANSI standard address permanent units and include definitions of emergency showers, eyewash stations and permanent eye/face wash equipment.

According to ANSI, emergency showers should be designed to deliver flushing fluid in sufficient volume (20 gpm, 15 minutes) to cascade over the entire body. Emergency showers should be placed in accessible locations, defined as taking less than ten seconds to reach from the potential incident area. Appendix B in the standard indicates that the average person travels a distance of approximately 55 feet in 10 seconds when walking at a normal pace. The showers should be located on the same level as the hazard, and in a place where the path of travel is free of obstructions that may inhibit their immediate use. Finally, the showers should deliver tepid flushing fluid at temperatures between 60°F to 100°F.

The second permanent safety option, an eyewash station, is any device defined by ANSI as capable of irrigating and flushing both eyes simultaneously. Eyewash stations should be capable of delivering 0.4 gpm of fluid for 15 minutes and have the same requirements for location and temperature as emergency showers.

Finally, permanent eye/face wash equipment is defined by ANSI as including any device used to flush the eyes and face simultaneously. This equipment should be capable of delivering 3.0 gpm of fluid for 15 minutes and have the same requirements for location and temperature as emergency showers.

The ANSI standard allows facilities to use temporary units, such as drench hoses and personal wash units, to supplement or replace permanent units under certain conditions. According to ANSI, drench hoses are defined as flexible hoses connected to a water supply used to irrigate and flush the eyes, face and body area. The hoses should support shower and eyewash units, “but shall not replace them.” Drench hoses must also be capable of delivering tepid flushing fluid at temperatures between 60°F to 100°F. The hoses may also be considered an eyewash or eye, face wash device if their performance meets the performance requirements laid out for permanent devices.

Under the risk safety matrix laid out by Jordan, drench hoses are the kind of temporary device that could be used in places where ammonia exposure is rarely likely. In that scenario, a facility would install hard water lines in locations where a temporary hose could be set up prior to engaging in an operation that might introduce risk, for example during line breaking. “The idea is to have hard-piped water lines set up and ready to be turned on before they might be needed,” said Jordan. “Most of the time, that line is dry, but when you’re ready to do work where it might be required, that line is on and ready.”

The second type of temporary safety equipment is defined by ANSI as a personal wash unit. These are supplementary units that support plumbed and, or gravity-fed units. The personal wash unit must be capable of delivering immediate flushing fluid to the eyes or body to provide relief in the crucial seconds that pass before an approved station can be reached. There are no minimum flow requirements for this temporary option, and the only temperature requirement is that they be protected from freezing and ambient temperatures above 100°F.

Personal wash units represent the last line of defense in Jordan’s risk safety matrix, and might be used in cases where exposure risk exists in hard-to-reach or seldom occupied areas. “The use of this kind of equipment comes with a huge provisory,” said Jordan. “It’s something portable that would be carried to an area, but it’s only there to provide limited protection until a permanent station can be reached.”

Once a company has gained a clear understanding of the available equipment options for permanent and temporary eyewash and shower units, the next step is to determine what equipment to place in which locations. Jordan’s risk matrix does this by defining the number, type and location of emergency eyewash and shower equipment units needed. The higher a facility area ranks on the matrix according to the likelihood and severity of a potential exposure, the more likely it is to require a permanent station, while a lower rank may indicate that a drench hose or personal station will constitute adequate risk preparation.

The matrix can be applied to ammonia and other corrosive materials handled on-site at a facility. “The trick is to use the ranking system to decide where you want to implement each kind of equipment,” said Jordan. “All three options are suitable as long as they are done correctly.”

Matrix definitions for severity and likelihood of ammonia exposure are ranked one through five with a score of five representing the least severe or likely cases and a score of one representing the most severe or likely cases.

Suggested definitions for severity of exposure include: a large volume of ammonia (representing a score of one); a large volume of ammonia vapor (representing a score of two); a smaller volume of liquid ammonia (representing a score of three); the presence of an ammonia valve station (representing a score of four); and ammonia piping with no valve stations (representing a score of five).

Suggested definitions for likelihood of exposure include: line breaking once a week (representing a score of one); line breaking once a month (representing a score of two); line breaking once a quarter (representing a score of three); line breaking once a year (representing a score of four); and line breaking less than once a year (representing a score of five).

While smaller facilities may not adhere to Jordan’s risk matrix exactly, the scoring system is a good way to identify which risk options to use where a situation seems ambiguous. “Facilities may not use such a formal approach each time they build or evaluate an eyewash and safety shower plan,” said Jordan. “This is a way to decide how much ammonia is out there and what approach to use.”

As for how to actually implement and monitor any plan developed with an eyewash and safety shower risk matrix, Jordan recommends supporting the core plan with a variety of additional precautions and safeguards such as employing written procedures in each use case, implementing a “buddy system” to promote accountability and wearing appropriate personal protective equipment (PPE).

In larger facilities Jordan often participates in a team made up of two or three members to conduct an informal eyewash and safety shower evaluation. Members of the team should know the location and use of ammonia equipment as well as the location of emergency eyewash and shower equipment. The team typically tours the facility and then uses a site map to identify areas that should be ranked on the risk matrix. The evaluation typically results in recommendations where additional permanent or temporary units should be provided. Like any hazard evaluation, recommendations identified during this process should be addressed on a timely basis.

Overall, the risk matrix as applied to eyewash safety programs has provided “reasonable” results when it comes to ensuring that the possible ammonia exposure risks in a facility have been thoroughly considered and prepared for, said Jordan. He added that the plan can help companies avoid the significant expense of installing permanent eyewash and shower stations in all ammonia locations where measures like the extensive use of drench hoses may be adequate.

Nevertheless, companies should consider these decisions carefully and always emphasize the appropriate levels of preparedness, said Jordan.

“We’re dealing with a potentially corrosive material when we work with ammonia. If the extreme happens, that’s not the time to find out you don’t have the right eyewash and shower capabilities in the right places,” said Jordan. “It’s all about pre-planning. Make sure you know ahead of time how you’re going to deal with as many potential situations as possible.”