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Achieving OSHA Compliance in Eyewash Equipment Consistency is key BY ROBERT KURTZ


G


o looking for Occupational Safety and Health Administration


(OSHA) regulations concerning eye- wash stations and you might be surprised by what you find—or more likely what you will not find, says Cathy Montgom- ery, RN, CASC, president and managing partner of ASC and physician practice consulting firm Excellentia Advisory Group in St. Peters, Missouri. “The OSHA standard on eyewash stations is all of one sentence,” she says. That sentence—found in 29 CFR 1910.151(c) (https://goo.gl/GH7E47)— reads as follows: “Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.” Since all ASCs use corrosive mate-


rials, such as hydrogen peroxide, they need eyewash stations, Montgomery says. OSHA’s lack of guidance on eye- wash stations can make compliance tricky, she says. “OSHA has essentially adopted the American National Standards Institute’s (ANSI) recommendations,” Montgom- ery says. “ANSI is not a regulatory body. Rather, it has determined ‘best practice’ standards and OSHA has adopted them. If you read an OSHA interpretation let- ter (e.g., https://goo.gl/oyS8jg), OSHA will quote ANSI standards.” There are essentially two differ- ent kinds of eyewash stations, she says. Plumbed systems, which con- nect directly into an ASC’s water sup- ply, and self-contained systems. “They must be clearly visible in well-lit areas,” Montgomery says. “They must also be identified with signage.” ASCs are expected to inspect and test their systems and record the results, she says. “This process should be com-


an issue, the problem is documented and then we would call in a plumber. In her absence, our charge nurse or another staff member fills in.” Lambie says the assigned nurse pays close attention to the water tem- perature. “The last thing you want is someone to turn on the station and scalding water hits their eyes.” Another area to check is whether dust caps are in place, Montgomery says. “Sometimes stations will lose these caps. That can lead to dirt and dust in the water during those crucial initial seconds of an eye wash.” Eyewash station compliance is in


State and accreditation surveyors may be looking to ensure you have a platform to prohibit Legionella. While you cannot catch the disease through water contact with the eye, you can through accidental inhalation of water droplets.”


— Cathy Montgomery, RN, CASC Excellentia Advisory Group


pleted weekly. For plumbed systems, turn them on and make sure the water runs properly. For self-contained sys- tems, make sure they have not expired. Both must be able to run for 15 min- utes at a temperature between 60 and 100 degrees.” To help ensure compliance, Surgi- Center of Baltimore in Owings Mills, Maryland, assigns oversight of its eye- wash stations to a member of its nurs- ing team, says Administrator Rosemary Lambie, RN. “She keeps a log of every inspection and test,” Lambie says. “If she identifies


30 ASC FOCUS JUNE/JULY 2018 |www.ascfocus.org


the spotlight, she says. In June 2017, the Centers for Medicare and Medic- aid Services (CMS) issued a memo- randum requirement (https://goo.gl/ kp5vnT) instructing health care facili- ties to reduce the risk of growth and spread of Legionella. CMS issued a revised version, stating the requirement applied only to hospitals and long-term care facilities but leaving in language indicating the requirement applied to any Medicare-certified facility. “Some of the states are enacting this requirement for ASCs,” Montgomery says. “State and accreditation surveyors may be looking to ensure you have a plat- form to prohibit Legionella. While you cannot catch the disease through water contact with the eye, you can through accidental inhalation of water droplets.” While maintaining eyewash com- pliance is not a difficult process, Lam- bie says, doing so is critical. “It is a process to put in a tickler file and make sure to complete consistently. Hope- fully, your staff will never need to use an eyewash station but you must ensure it works as expected in case they must.”


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