1. “To Plumb or Not to Plumb, that is the Question”
The debate continues with eye wash stations
The questions and concerns continue! Healthcare organizations struggle with the questions of
“where to place” and “if we really need” plumbed eye wash stations. The basic premise of safety
for the staff utilizing hazardous chemicals or materials should drive organizations to decide on
the need and placement of eye wash stations. To understand the regulatory requirements, it is
necessary to consider OSHA, American National Standards Institute (ANSI) and where
surveyors are citing RFIs.
OSHA's general regulation is applicable to all facilities. Regarding the installation of an
emergency shower or eye wash station equipment as a form of first aid as directed under 29 CFR
1910.151(c). It states that:
"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 standard states an eyewash and/or safety shower would be required where an employee's
eyes or body could be exposed to injurious corrosive materials. If none of the materials used in
this work area is an injurious corrosive [chemical] (as indicated by the Material Safety Data
Sheet (MSDS) for each product), then an emergency eyewash or shower would not be required
pursuant to 1910.151(c).
Since the OSHA regulations do not specify minimum operating requirements or installation set-
up requirements, the ANSI developed the ANSI standard Z358.1-1990. While it doesn't have the
full force of an OSHA regulation, the standard covers situations when employees are exposed to
hazardous materials. ANSI's definition of "hazardous material" would include caustics, as well as
additional substances and compounds that have the capability of producing adverse effects on the
health and safety of humans.
The most recent ANSI standard (2009 version of ANSI-Z358) helps the user select and install
emergency equipment to meet OSHA requirements. An excerpt indicates:
 Eye wash station shall be located in an area that requires no more than 10 seconds to
reach. *Consult a medical professional to determine the appropriate distance for harsh
acids and caustics (high hazard=closer distance)
 The location of the eye wash station shall be in a well-lit area and identified with a sign
 Eye wash stations shall be on the same level as the hazard
Considering the direction of the OSHA and ANSI, organizations should conduct a detailed risk
assessment to determine location of hazardous materials, the requirements outlined in the MSDS

2. of products and the current placement of plumbed eye wash stations and portable flush bottles. It
is important to document the risk assessment as well as follow-up actions taken.
TJC Surveyors have been scoring eye wash stations under the Environment of Care standards
related to safety, risk assessment and hazardous materials management. Surveyors could score
under EC.02.02.01, related to hazardous materials; EC.03.01.01 related to staff and LIPs being
familiar with their roles and responsibilities relative to the environment of care; or EC.04.01.01,
EP1 related to monitoring conditions in the environment. These findings also tie back to CMS’
Physical Environment Condition of Participation 482.41(c)(2) in terms of maintaining a safe
environment.
Healthcare organizations are also encouraged to consider any regulatory expectations that their
individual State may require while completing a risk assessment of current eye wash locations
and corrosive materials that may impact the decision-making of whether “to plumb or not to
plumb.”
Sources: OSHA 1910.151(c). osha.gov
ANSI/ISEA Z358.1-2009
CMS Conditions of Participation SOM-A: 482.41 (c) (2)-Physical Environment. March 23,
2012.
The Joint Commission Hospital Manual 2013
The Bradley Corporation: A Guide to the ANSI Z358.1-2009 Standard for Emergency
Eyewashes and Shower Equipment, 2010