MedicalEnvironment Update

September1, 2016

SECTION:Vol. 26 No. 9 ISSN: 1520-8222

Editor’snote: Inthis story, which originally appeared in Facility Care, consultant Brad Keyes,CHSP, explains the complex world of eyewash stations.

   Whenand where are eyewash stations required in a healthcare facility? This isone of the more frequent issues with which healthcare professionals struggle.There is a tendency to place these stations nearly everywhere, but in realitythere aren’t as many locations that require eyewashstations as one may think.

   Eyewash stations are required wherever thereis a possibility that caustic or corrosive chemicals could splash into anindividual’s eye. It is important to note that blood and body fluids are notconsidered to be caustic or corrosive. It is also important to note that theuse of PPE such as face shields, glasses, or goggles does not exempt a facilityfrom needing an eyewash station.

   Where to place a station

   Most accreditation organizations base theirpositions on whether an eyewash station (or an emergency shower) is required onthe healthcare organization’s decision to conduct a risk assessment, and on thefindings of that assessment. Areas where work is done with corrosive andcaustic chemicals do not necessarily require an eyewash station or emergencyshower unless chemicals could be splashed into the eyes or onto the skin. Anexception is if an eyewash station is part of regulation or accreditationrequirements.

   For example, if an environmental servicesworker opens a 1-gallon container of a liquid cleaner that is consideredcaustic or corrosive, and inserts a suction tube for a mixer, that may notpresent much of a splash hazard, and a risk assessment could state that aneyewash station is not warranted.

On the other hand, if therisk assessment determines the removal of the suction tube constitutes a splashhazard, then an eyewash station would be required. Similarly, if the employeepours this chemical from its original container into another container, now therisk of a splash is much greater, and a risk assessment would likely require aneyewash station. All risk assessments are conducted with the presumption thatstaff will not be wearing any PPE, although eye protection, face shields, andgloves and aprons must be worn during the use of caustic or corrosivematerials.

   If there are no corrosive or causticchemicals present, there is no need to conduct a risk assessment and thereforeno need for an eyewash station. Whether the term “corrosive” or the term“injurious corrosive” is used to describe a chemical, it’s all the same. Eitherwould cause an injury.

   If there is a possibility that a corrosiveor caustic material can be splashed onto the skin, then an emergency shower is required.But if a risk assessment determines there is no possibility of the chemicalssplashing onto the skin through normal use, there would not be a requirementfor an emergency shower. The risk assessment should also consider emergencyspills as well. Just like eyewash stations, if regulation or accreditationstandards require the presence of emergency showers, you would need to installone regardless of whether corrosive or caustic materials are present.

   Nofair substitute

   While portablesqueeze bottles are not prohibited, they are not a substitute for an approvedANSI Z358.1-2014 eyewash station because they don’t provide hands-free use anddo not flow water continuously for 15 minutes. In fact, portable squeezebottles are a potential problem for healthcare organizations since they areusually placed around an area where a potential hazard may occur. In otherwords, they are placed in locations where somebody decided that there is somesort of splash risk present and that a portable bottle would be of some use.This can lead to the incorrect assumption that portable bottles are an approvedeyewash station.

   In addition,portable squeeze bottles need to have their water changed every two years orso, and that can be overlooked at times, leading to a citation. Also, thesebottles are a huge red flag to a surveyor-once he or she sees the portablebottle, a tracer is likely to follow.

   Amandatory guidance?    

   The ANSI Z358.1-2014 standard for eyewashstations is based on recommendations from OSHA letters of interpretation. OSHArequires an employer to provide suitable facilities for quick drenching orflushing of the eyes and body when employees may be exposed to injuriouscorrosive materials. ANSI standards become mandatory OSHA standards only whenthey are adopted by OSHA. ANSI Z358.1 has not; however, it provides detailedinformation regarding the installation and operation of emergency eyewash andshower equipment. OSHA, therefore, has often referred employers to ANSI Z358.1as a source of guidance for protecting employees who may be exposed toinjurious corrosive materials. Accreditation organizations seem to have latchedon to ANSI Z358.1 as the standard with which to comply.

   A proper assessment

   The organization is expected to conduct arisk assessment (or survey) of its facility’s operation and process areas todetermine if and where eyewash stations are needed. If the facility hasdetermined that an eyewash station is needed, that station needs to conform toANSI Z358.1-2014, which has the following specifications:

   * Only eyewashstations that are capable of providing a flow of clean, potable water at a rateof 0.4 gallons per minute at 30 psi for 15 minutes are permitted. Someself-contained eyewash stations provide this flow requirement, but normallyplumbed eyewash stations are installed.

   * The flownozzles of the eyewash station must be mounted a minimum of 33 inches and amaximum of 45 inches above the floor, and a minimum of 6 inches from any wall,post, or other barrier.

   * Activation ofthe eyewash station must occur within one second or less of operating thecontrol valve, so this typically eliminates the faucet-mounted eyewash stationsthat require the operation of three -levers to obtain a balanced flow of water.The control valve must remain open on its own until it is intentionally turnedoff.

   * Approvedeyewash stations are required to be located within 10 seconds’ travel time (or55 feet) of the hazard, and the path to an eyewash station must not be hinderedor obstructed. The ANSI Z358.1-2014 standard has changed (for chemicals NOTconsidered to be corrosive) to allow one door in the path to an eyewashstation, provided the door cannot be locked and the door swings toward theeyewash station.

   * While thereis no standard that prohibits small, supplemental personal wash bottles, theycannot meet the flow rate requirements for a 15-minute flush, and therefore arenot a substitute for a plumbed eyewash station. They can serve as asupplemental aid, but the plumbed eyewash station still needs to be locatedwithin 10 seconds’ travel time (or 55 feet) of the hazard. The presence ofpersonal wash bottles may indicate a need for a plumbed eyewash station.

   * Thetemperature of the water must be tepid. The ANSI standard defines tepid wateras being between 60 and 100 degrees Fahrenheit. To achieve this temperaturerange, the organization may have to install mixing valves. Some accreditationorganizations allow water temperatures outside of this range, provided a riskassessment is conducted by qualified individuals who analyze the hazard and thetemperature of the water to flush the hazard. Qualifying individuals mustinclude an individual with clinical or medical training.

   * Weeklyactivation of the plumbed eyewash stations is required to clear any sediment orbacteria. There is no specified time that the water must flow. An annualinspection of the eyewash station is required to determine conformances withthe installation requirements are maintained.

Tipsfor evaluating compliance

   Here are some recommendations on evaluatingyour existing eyewash stations for compliance:

   * In ahealthcare setting, eyewash stations are typically found where cleaningchemicals are mixed (such as housekeeping areas); where plant operations takeplace; and in kitchens, generator rooms, boiler rooms, environmental servicesstorage rooms for battery-powered floor scrubbers, in-house laundries, dialysismixing rooms, and laboratories. Find out whether a risk assessment has beenconducted to determine the need for eyewash stations.

   * All requiredeyewash stations must be operated in one second or less. This means thefaucet-mounted type that requires turning aa hot water lever and a cold waterlever, and then pulling a center lever, is not permitted.

   * Access to theeyewash station must be within 10 seconds (or 55 feet) of the hazard. The individualseeking an eyewash station may travel through one door to get to an eyewashstation, provided the chemical is NOT corrosive and the door is unlockable andswings toward the eyewash station.

   * If an eyewashstation is observed outside of an area where one is typically needed, ask thestaff who work in the area why it is there. See if they have conducted a riskassessment that requires it to be there. Advise them that if there is no validreason for the eyewash station to be there, it can be removed, which may savethem the time and resources spent in maintaining it.

   * Eyewashstations may need to have a mixing valve to maintain a flow of water in the 60-to 100-degree Fahrenheit range. Ask to see the risk assessment to determinewhether a mixing valve is required.

   * Every plumbedeyewash station needs to be tested weekly by flowing water to clear anysediment and bacteria. There is no requirement regarding how long the watermust flow. Every eyewash station must be inspected annually to determinewhether the eyewash station still conforms to the installation parameters. Theweekly test and annual inspections must be documented.

   * The presenceof eyewash bottles indicates someone in the organization decided the bottleswere needed. Investigate and ask why the bottles are there. Determine whetherthere is a need for a plumbed eyewash station within 10 seconds’ travel time(or 55 feet) of the perceived hazard. Check the expiration date on the bottles.

   * Finally,always check with your state and local authorities to determine whether theyhave any additional requirements.

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TOKYO -- Mitsubishi MotorsCorp.’s fraudulent fuel-economy testing and the subsequent plunge in its stockprice and sales could cost Mitsubishi Corp., its second-largest shareholder,about 335 billion yen ($3 billion), as the Japanese carmaker’s disclosurereverberates.

MitsubishiCorp., which owns 10 percent of Mitsubishi Motors, is the first of theautomaker’s major shareholders to measure the potential impact of improper fueleconomy testing dating back 25 years. It also joined Mitsubishi HeavyIndustries Ltd., the carmaker’s biggest stock owner; in saying it can’t commentat this point whether to extend aid to the carmaker.

“We cannot say anythingparticular about the support, as we do not know the whole picture,” PresidentTakehiko Kakiuchi said at a briefing in Tokyo today. As a shareholder ofMitsubishi Motors, the fraud at the carmaker is “extremely regrettable,” hesaid.

Support from shareholders maybe crucial to Mitsubishi Motors’ weathering a scandal that could result in thecompany having to compensate customers, Japan’s government and minicar partnerNissan Motor Co. On Monday, Mitsubishi Heavy said it wanted to wait for theresults of an investigation into the fraud before deciding whether to extendaid. The heavy machinery maker hasn’t received any appeal for help from theautomaker in which it owns 12.6 percent stake, President Shunichi Miyanaga toldreporters in Tokyo on Monday, without elaborating.

“They are submitting a reportand we don’t know how that will turn out yet,” Miyanaga said. “We also have towait until the results of a third-party investigation.”

Mitsubishi Heavy andMitsubishi Corp. are among the Mitsubishi Group companies that bailed out themaker of Lancer sedans and Montero SUVs more than 10 years ago after it wasfound to have covered up safety defects. Orders for its vehicles in Japan haveplunged after the company first revealed it had overstated the fuel economy ofits minicars by as much as 10 percent.

“I think it’s the rightjudgment at this stage,” Takeshi Miyao, an analyst with Tokyo-based marketresearcher Carnorama, said by phone. “Even if you want to rescue MitsubishiMotors, it’s not good to make a decision before the facts are out. You may facecriticism from the public.”

Shares of Mitsubishi Motorshave tumbled about 44 percent since the announcement on April 20.

Japan’s transport ministry hasgiven Mitsubishi Motors until May 11 to re-submit findings from itsinvestigation of improper testing methods after saying an initial report wasinsufficient.

The government will also setup a task force to look into concrete measures to prevent irregularities invehicle testing, Transport Minister Keiichi Ishii told reporters on April 26.

Mitsubishi Motors hasestablished a third-party group to investigate the falsified fuel efficiency labelingthat will take about three months, the company said last month. The committeeconsists of three lawyers, including a former member of the Tokyo HighProsecutors Office.

Carmakers are bracing forincreased scrutiny of the way they label and advertise fuel efficiency andtailpipe pollutants after revelations in September that Volkswagen AG cheatedon diesel emissions. Since then, government fraud investigators have raidedFrench manufacturer PSA Group as part of broader checks into vehicle emissions,while Daimler AG said it initiated an internal probe into its certificationprocess at the behest of the U.S. Department of Justice.

Mitsubishi Motors delayed itsprofit forecast for the current fiscal year, saying it’s assessing the futureimpact from testing irregularities involving an untold number of models since1991. The automaker’s shareholders from the Mitsubishi group also includeMitsubishi UFJ Financial Group Inc., which holds a 4.2 percent stake, accordingto data compiled by Bloomberg.

Mitsubishi bailout

Mitsubishi Heavy, which spunoff the carmaker in 1970, bought 40 billion yen of preferred shares inMitsubishi Motors in 2004, part of a 496 billion yen bailout of the company.The automaker recalled more than 200,000 faulty vehicles and said it covered updefects.

Mitsubishi Corp. injected 140billion yen into the automaker from June 2004 through January 2006. The companyalso cooperates with Mitsubishi Motors to develop sales mostly outside of Japanand across related businesses, according to its statement.

Of the estimated exposure tothe carmaker, 125 billion yen was related to the value of Mitsubishi’sshareholding in the carmaker, and about 210 billion yen was from investments inrelated businesses as of March 31, according to Mitsubishi Corp. The companyhasn’t factored in the impact of the scandal in its current fiscal-yearforecasts.

“I’d say the Mitsubishi Group-- I’m not sure whether it’s going to be Mitsubishi Heavy -- would rescueMitsubishi Motors somehow in the end,” Carnorama’s Miyao said. “They don’t wantthe Mitsubishi name tainted and they have the means to do it.”



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