Michigan OSHA Clarifies Requirements For Eyewashes And Safety Showers

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Earlier this month MIOSHA released a new Fact Sheet entitled Eyewashes and Safety Showers. Briefly, this Fact Sheet states the general requirement that:

Suitable facilities for quick drenching or flushing of the eyes and body must be provided within the work area for immediate emergency use when the eyes or body of any person may be exposed to injurious or corrosive substances.

The fact sheet summarizes an Agency Instruction (MIOSHA-STD-07-1R4) dated April 12, 2018 and clarifies what constitutes an “injurious or corrosive substance,” “suitable facilities” and location of suitable eyewashes and showers.

Injurious or Corrosive Substance

  • The chemical manufacturer’s or importer’s hazard classification will be the primary criteria relied upon. The use of pH will not be the primary measure of defining “injurious or corrosive.”
  • “[I]njurious or corrosive materials” will be defined as chemicals that have the GHS classification of serious skin/eye damage and serious skin/eye irritation.” Employers should review Section 2 of an SDS  to help determine if an eyewash/shower is required.  Look for statements such as “severe skin burns and eye damage”; “serious eye damage”; or “serious eye irritation.”
  • “A GHS classification reading “causes eye irritation” (Category 2B) would not require an eyewash/shower.

Suitable Facilities

  • The activation time of the eyewash control valve must be within 1 second and simple to operate
  • More than one motion to activate an eyewash is allowed so long as that activation occurs in one second or less.
  • Second/separate motion to remove nozzle covers is not permitted

Location of Eyewash/Shower

  • Location of the emergency shower and/or eyewash facility should be within a 10 second travel distance which equates to 55 feet
  • Location of the shower or eyewash facility must be on the same level as the hazard and easily accessible, clearly marked and well lighted.

Personal Use Eyewashes

  • Personal wash units (e.g. 12-16 oz bottles) may be supplemental but do not constitute eyewash equipment.
  • Self-contained or portable units must be capable of delivering to the eyes not less than 1.5 liters per minute (0.4 gallons per minutes) for 15 minutes.

To learn more, see the MIOSHA Fact Sheet (Eyewashes and Safety Showers) and Agency Instruction MIOSHA-STD-07-1R4.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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