The revision of IIAR-2 involved discussions of many philosophical and practical matters. Among the topics discussed was that of the need for eyewash/safety showers in areas other than machinery rooms, and specifically in cold environments such as a freezer or on the roof. Hoping to gain insight on OSHA’s intent, IIAR submitted some formal questions regarding risks and the need for eyewash/safety showers. The paraphrased letter and OSHA’s response follows.

After many months of circulation and review by OSHA’s technical and legal departments, the following response was returned including the paraphrased questions:

Question #1: Would OSHA accept the use of personal protective equipment in lieu of permanent or portable eyewash/safety showers in cold environments?

Reply #1: No. OSHA would not accept the use of personal protective equipment in lieu of eyewash/safety showers regardless of the environment. Further, there are emergency eye wash and safety shower products that have built-in heating elements for maintenance operations in cold environments.

Question #2: If the ammonia refrigeration is in a sealed container (sic) where there is no intention of opening or repairing the pressure-containing envelope of the piping system, does 29 CFR 1910.151 (c) require an eyewash or emergency shower?

Reply #2: No. However, as you recognized in your letter, for some maintenance operations, such as oil draining, equipment replacement, and valve and piping maintenance or repair, there is potential for exposure to ammonia. In those circumstances, the standard requires the employer to provide facilities for quick drenching or flushing of the eyes or body.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA’s requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA’s interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA’s website at http:// www.osha.gov. The response above is poignant for our industry. It is our estimation that the response is both positive and negative.

The response clearly indicates that just because ammonia equipment and piping is present doesn’t automatically mean that a risk exists. Taking this logic a bit further, a facility does not need to provide an eyewash/safety shower everywhere there are ammonia refrigeration components. But if there is a plan to open the system, the use of PPE is not a substitute for a “facility for quick drenching or flushing of the eyes or body”. A “facility” could be any method such as portable unit or hoses (and a suitable nozzle) with an appropriate supply of water at the appropriate temperature. ANSI/ ISEA Z358.1 provides the requirements for flow rate and temperature, as well as maintenance for permanently installed stations. While the response did not address the possibility of slip/trip hazards or hypothermia, we must presume that OSHA regards these possibilities as minimal compared to not having the ability to dilute an ammonia exposure.

Building designers and owners should account for the need for occasional maintenance that includes opening the system. Water supply or a means to provide portable eyewash/ safety showers on roofs, in process areas or other places should be considered. As always an evaluation of costs and benefits is appropriate.