We found one university-affiliated hospital with ~900 beds
was monitoring compliance of ~900 eyewash stations
— i.e. an eyewash station for every “paying customer”
Since 2013 we have struggled for years to install performance-based inspection, testing and maintenance methods into this particular regulatory product developed by the International Safety Equipment Association which is intended to protect occupants from chemicals needed in classrooms, research laboratories and healthcare delivery settings:
Performance-based standards, common in safety assurance regimes elsewhere in the world, permit site-specific risk calibration based on national, state, or scientific guidelines, benchmarking against similar organizations, the public’s or leaders’ expectations, or other methods.
Performance standards permit organizations responsible for worker safety to scale their conformance resources across a fully dimensioned risk-space. In other words, in many organizations, there may be far greater risks that require remediation than the eyewash and emergency shower stations that must be installed every 75 feet, supplied with water between 68 and 72 degrees, and tested every week (CLICK HERE for more information about plumbing higher education laboratories).
Prescriptive standards, on the other hand, require fixed interval inspection testing and maintenance (i.e. chargeable time). Prescriptive standards are comparatively easy for compliance officers to enforce compared with performance standards.
We assert, without hesitation, that prescriptive standards make litigation easier. Risk management professionals in higher education are characterized, broadly speaking, by their risk aversion. Nothing necessarily wrong with that but many organizations are unable to finance the resources for a cross-cutting point of view that hastens decisions on balancing risk. Inspection expertise is organized into “silos” which do not offer well-meaning safety inspectors a fully dimensioned view of risk across the full sweep of assets and operations.
In laboratory chemical safety, the dominant standard for emergency showers and eyewashes is the subject ISEA consensus product; widely referenced in many other related consensus products. Like many ISEA consensus products, it is developed according to ANSI’s Canvass Method of standards development; not our favorite method for the user-interest in leading practice discovery but better than no method at all.
Of the two technologies covered in this product we find that the emergency shower requirement is especially burdensome; though safety equipment manufacturers have developed products to reduce the testing risk.
Late last year ISEA released a public request for data to inform the 2019 revision as described in the link below:
In early 2020 ISEA announced that it is assembling another canvass committee to re-affirm Z358.1 . The word “re-affirm” may well indicate that the updated revision will be identical to the previous version; maybe not. ISEA expects to initiate consensus balloting by the end of 1Q 2020.
We encourage our colleagues in the education facility industry to communicate directly with Christine Fargo (firstname.lastname@example.org). The landing page for standards action on other ISEA consensus products is linked below:
We are happy to drill into any consensus product affecting #TotalCostofOwnership of the safety and sustainability agenda of the education facility industry any day at 11 AM Eastern time. Additionally, we also host a dedicated work session on Laboratory Safety and Sustainability and our Risk Management standards teleconferences. See our CALENDAR for the next online meeting.
Issue: [13-28] and [16-69]
Contact: Mike Anthony, Richard Robben, Mark Schaufele, Ron George