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.

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Photo of Tressi L. Cordaro Tressi L. Cordaro

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state…

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state OSHA enforcement agencies.

Ms. Cordaro has advised employers faced with willful and serious citations as the result of catastrophic events and fatalities, including citations involving multi-million dollar penalties. Ms. Cordaro’s approach to representing an employer cited by OSHA is to seek an efficient resolution of contested citations, reserving litigation as the option if the client’s business objectives cannot otherwise be achieved. As a result, she has secured OSHA withdrawals of citations without the need for litigation.

Ms. Cordaro’s unique experience with government agencies involved in OSHA enforcement enables her to provide employers with especially insightful guidance as to how regulators view OSHA compliance obligations, and evaluate contested cases.

Ms. Cordaro served as the Presidentially-appointed Legal Counsel and Special Advisor to the past Chairman and Commissioner Horace A. Thompson, III at the U.S. Occupational Safety & Health Review Commission (OSHRC) in Washington, DC, the agency that adjudicates contested federal OSHA citations. As the Commissioner’s chief counsel, Ms. Cordaro analyzed all cases presented to the OSHRC and advocated the Commissioner’s position during decisional meetings.

In addition, Ms. Cordaro worked at the U.S. Department of Labor’s Occupational Safety & Health Administration developing OSHA standards, regulations and enforcement and compliance policies, with emphasis on the construction industry. She has in-depth experience on technical issues including, in particular, issues related to cranes and derricks in construction.

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