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The OSHA eyewash/shower requirement at 1910.151(c) states, “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.” [emphasis added]
OSHA further addresses this issue in Letter of Interpretation (LOI) dated April 14, 2008 which says, “the employer must determine if employees can or will be exposed during the course of their duties to hazardous materials in such a way that the protections of an eyewash or emergency shower would be necessary. If hazardous materials are present at a worksite in such a way that exposure could not occur (for example, in sealed containers that will not be opened, or caustic materials in building piping), then an eyewash or emergency shower would not be necessary. However, if the building piping containing caustic materials has, at certain locations, a spigot or tap from which the contents are to be sampled or withdrawn and employees are expected to perform such tasks, then, certainly, an eyewash and/or emergency shower would be needed where this task is to occur.”
Ask:
If the answer to both of these questions is ‘yes,’ then an emergency eyewash and/or shower is required. If the answer is ‘no’ to either of those questions, then a unit would not need to be provided.
Ultimately, OSHA expects the employer to determine the level of potential risk to employees and provide protection accordingly.