Sorting out OSHA and ANSI

During a recent presentation to a Maintenance Roundtable group composed of local manufacturers, CTI’s principal was presented with a problem that came down to figuring out how to sort out OSHA requirements and ANSI guidelines for eyewash stations. In this particular case, company personnel were struggling inter-departmentally over how to comply with an OSHA safety regulation that doesn’t supply the “how-to” details.  So, they turned to the ANSI guidelines for the “how-to”.  Their dilemma: how many of the ANSI guidelines should we follow if some don’t seem to fit for our company?

This case involved a maintenance department manager and an HR manager struggling over emergency eyewash station inspection frequency. They were on-board with the ANSI guidelines about how to locate and set up their eye wash stations, but they differed over the suggested guideline for performing weekly inspections. HR personnel wanted the weekly inspections since the company had already followed all of the other ANSI guidelines to comply with OSHA’s requirement for “…suitable facilities…….for immediate emergency use”, but maintenance personnel struggled with the personnel and budget necessary for doing weekly inspections. Maintenance wanted to do monthly inspections, when time and personnel were already allocated for fire extinguisher inspections. Which side can find support under the regulation?

Without getting too deep into a discourse of the OSHA eyewash regulation and the ANSI supporting guidelines in this short article, OSHA has not adopted the ANSI standard recommendations for eyewash stations and, therefore, does not cite facilities for not following ANSI. Thus, if this company prefers to do monthly inspections, then OSHA cannot cite this activity as a violation of the regulation, even though it is an ANSI guideline.

By all means, the company must thoroughly review its eyewash station safety program to ensure that its program is providing “…suitable facilities…….for immediate emergency use” in all appropriate respects, or they may be liable to citations under the General Duty Clause.

(Editor’s note: CTI has OSHA reference materials in regard to this topic. Please contact the company to receive additional information, or to pose a question in regard to your own regulatory compliance issue.)


Published by Stephen Kovatch

Senior Client ManagerĀ  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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