Emergency Shower & Eyewash Testing | Standards Michigan

Emergency Shower & Eyewash Testing

The first question the user will be asked by the compliance officer is "How can you possibly be against safety?"


Emergency Shower & Eyewash Testing

May 15, 2019
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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:

Standard for Emergency Eyewash and Shower Stations: ANSI/ISEA Z358.1-2014

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:

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:

ISEA Standards

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


* Price Discovery in Workplace Safety

Who Are “Incumbent Stakeholders”?





Hunter College Laboratory | Our position has been to specify more of these rather than more of them in laboratory building hallways.

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