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”
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 worksrs from chemicals needed in classrooms, research laboratories and healthcare delivery settings:
Performance-based standards, common in other safety standard 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.
Prescriptive standards, on the other hand, require fixed interval inspection testing and maintenance so that the inspection event is chargeable time. Prescriptive standards are comparatively easy for compliance officers to enforce compared with performance standards. Some standards developers such as the National Fire Protection Association recognized the burden prescriptive standards place upon the user interest so they produce two different versions of one of its flagship products:
NFPA 101 Life Safety Code (Prescriptive) and NFPA 101A Guide on Alternative Approaches to Life Safety (Performance)
We monitor code and standard development among 250+ US-based standards developers every day and can assert with some authority that this standard in the ISEA suite — not all ISEA standards; just this one — is as clear an example of “market-making” by inspection, testing and maintenance stakeholders as we can find. There was never any data science that informed the original (weekly) testing intervals. This has been documented in previous posts and in an article published by an education facility trade association*
Not all is bad news, however: the level of debate has been elevated. We are tracing some proposals that align (somewhat) with our #TotalCostofOwnership agenda for the user-interest in the education facility industry have been picked up by other consensus standards developers — notably by the International Code Council – and described in previous posts (below). Our colleagues at Northwestern University, working through the Campus Safety and Environmental Health Association have also proposed that compliance agencies adopt a European performance standard linked below:
European Standard EN 15154 – Safety showers | This document is a product specification, giving performance requirements for emergency safety body showers connected to the water supply. It is applicable to plumbed-in body showers only, located in laboratory facilities. It is not applicable to emergency safety showers used on industrial sites or in other such areas. Requirements are given in respect of the performance, installation, adjustment and marking of the showers as well as installation, operation and maintenance instructions to be given by the manufacturer. NOTE Attention is drawn to national regulations which may apply in respect of the installation and use of emergency safety showers.
Note that this is a 2006 consensus document produced from central European regulator that may inspire leading practice discovery and safety promulgation in other nations.
The landing page for the ISEA standards program is linked below:
We understand that the 2019 revision of ISEA Z358.1 is now in process and, based upon information posted on the ISEA website, the technical committee may have made some progress at the ISEA Annual Conference. November 28-30 in Alexandia, Virginia. As of this posting, we have not found any notification from either ANSI or ISEA regarding the status of this standardization project. We encourage our colleagues in the Sonoma County California region to attend the ISEA Annual Executive Summit May 5 – May 7 at the Fairmont Sonoma Mission Inn and Spa (CLICK HERE for more information
We sweep all laboratory safety related standard every month; with an eye toward calibrating risk from the user-interest. See our CALENDAR for the next laboratory codes and standards online teleconference. Use the login credentials at the upper right of our homepage.
Issue: [13-28] and [16-69]
Contact: Mike Anthony, Richard Robben, Mark Schaufele, Ron George