From REM Assistant Director on 2/4/2004
From the administrative position: Physical Facilities has a book listing building items versus departmental items. The book lists eyewashes as a departmental funded item. Work Control will need an account number to begin the work.
From the safety perspective:
A functioning eyewash is required for safety and OSHA compliance. Both Don or I agree funding eyewash repairs from the OSHA compliance account is an appropriate use of those funds. HOWEVER, I do not want to give the impression that REM is responsible for maintaining the 1400+ eyewashes on campus. We lack the resources. The individuals in the lab should be checking and flushing the eyewashes weekly. REM re-certifies eyewashes annually for compliance purposes. At that time, we initiate and pay for necessary repairs. Additionally, REM does not have the ability to respond to malfunctioning eyewashes in an urgent manner as is needed. Work Control is better suited for this.
Recommendations:
I would like the departments to directly call Work Control to initiate the repairs and designate the task as urgent. Corrosive materials should not be used in the lab until the eyewash is repaired or other provisions, such as a portable eyewash, are in place. OSHA funds may reimburse the repairs using the REM 113 form. Due to the paperwork involved, we would be chasing pennies with dollars to reimburse an hour or two of a plumbers time. More appropriate reimbursements will be for higher dollar repairs and replacement parts.
Also note:
OSHA relies upon ANSI Z358.1-2004, entitled American National Standard for Emergency Eyewash and Shower Equipment, to regulate the placement, performance and identification of EW/SS equipment. On page 9 of the standard under section 4.5 Installation:
It is the installer's
responsibility to ensure that emergency showers shall:
4.5.1 Be assembled and installed in accordance with the
manufacturer's instructions.
4.5.2 Be in accessible locations that require no more than 10
seconds to reach. The shower shall be
located on the same level as the hazard and
the path of travel shall be free of obstructions that may
inhibit the immediate use of the
equipment.
4.5.3 Be located in an area identified with a highly visible
sign positioned so the sign shall be
visible within the area served by the
shower.