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Specifically: Eye wash and shower stations: https://www.labmanager.com/lab-healt...s#.XEuwXHdFx9A. I have worked in a grade 'C' environment for many years and these regulations really bother me; I do not feel the current regulations are 'safe'.
The reality of it is that the first ten seconds of exposure are the most critical seconds to prevent injury. In a grade 'C' environment many of these stations have no drains. The reason for that is because drains produce microorganisms that will adversely affect our environmental monitoring. Also, once you use one of these safety devices, you must rinse for a minimum of 15 minutes. Keep in mind that the water must be between 60 and 100 degrees Fahrenheit. Have you ever stood in a 60 degree shower for 15 minutes? It is bad enough rinsing your eyes for 15 minutes in water that temperature. Moving past the temperature of the water; the water is dirty water (I mean that it is untreated water for a grade 'C' process) and to complete just the 15 minute shower, you would dump 300 gallons of dirty water on the floor of a grade 'C' building.
The net effect of these regulations is that you can have employees that are afraid to use the safety stations. I know that is no excuse and could lead to their dismissal or a denial of a claim. But should safety not be about safety and not regulations that are hard of difficult to follow?
To me logical regulations about the use of these eye and shower stations should read something like: You must immediately use them for a (unspecified) short period of time and then immediately move to the restroom shower where one can control the temperature, scrub, and remain there until for the fifteen minutes and longer if deemed necessary.
The first ten seconds of an exposure are the most important minutes to prevent a chemical burn. It is important that people do not have to think about getting fired for shutting down production or making a mess on a floor; they simply have to act and act fast. It's like getting a grease burn in your kitchen and you immediately plunge your hand into the cold water in the sink - you might avoid any signs of a burn.
So I am asking if anybody else has questioned these regulations and what are your feelings about them? I just feel that sometimes safety is not always safety; like the 844 passengers that were lost on the 'Eastland': https://en.wikipedia.org/wiki/SS_Eastland. Making a boat top heavy with lifeboats turned out to be a disaster!
I don't see a problem with the regulation as much as the lack of thought by the lab designers. A drain can be capped and sealed. Cleanout plugs seal drain access in almost every large structure. The "break glass to activate fire alarm" concept has been around for ages.
Build the eyewash station with a breakable glass floor over the drain pit. Hermetically seal the glass. In an accident, the employee rushes to the station, starts the water flow and steps onto the part of the safety glass that says "Step here to break glass and open drain." The glass crumbles down an inch into nuggets and access to the drain is opened.
In an accident, environmental monitoring is useless. Blood, guts, chemicals and vomit are going to contaminate far more than drain bugs.
The above is just one of a dozen ways to address the issue.
I don't see a problem with the regulation as much as the lack of thought by the lab designers. A drain can be capped and sealed. Cleanout plugs seal drain access in almost every large structure. The "break glass to activate fire alarm" concept has been around for ages.
Build the eyewash station with a breakable glass floor over the drain pit. Hermetically seal the glass. In an accident, the employee rushes to the station, starts the water flow and steps onto the part of the safety glass that says "Step here to break glass and open drain." The glass crumbles down an inch into nuggets and access to the drain is opened.
In an accident, environmental monitoring is useless. Blood, guts, chemicals and vomit are going to contaminate far more than drain bugs.
The above is just one of a dozen ways to address the issue.
Thanks for your suggestions. But I am not sure if that will ever happen. These companies spend hundreds of millions of dollars designing new buildings and this has never crossed their minds. They rely on other employees to grab wet/dry vacuum cleaners and try to deal with the 300 gallons of water on the floor in the event of an actual accident. A building could be shut down for days, maybe weeks, should one accident occur.
I just think that the regulations themselves should be rewritten. The reason that these eyewash and shower facilities are within ten seconds of locations where hazardous materials are used; is because they want them used immediately. They do not want employees thinking about the repercussions of using the safety equipment. I have worked for three different companies and at all three I have observed coworkers avoiding the equipment because they were more afraid of the use of it than the potential damage to themselves. I am not saying that is right, if they did suffer permanent damage; they would have been fired for not following directions. Fortunately the spills were not that bad and they had no problems.
Picture yourself working in this kind of environment and you have scrubs, Tyvek, safety glasses, googles, two pair of gloves, a set of Tyvek sleeves, face shields, hair nets, beard covers, face mask - you can sweat. But when working with chemicals; sometimes it is difficult to know whether that sweat is sweat or possibly a dangerous chemical. For safety sake you should immediately head to one of these stations and start your fifteen minuet rinse. But you have it in the back of your mind that you might shut down the building you are working in for a very long time and it might be only sweat! We need better regulations or better equipment.
Thanks for your suggestions. But I am not sure if that will ever happen. These companies spend hundreds of millions of dollars designing new buildings and this has never crossed their minds. They rely on other employees to grab wet/dry vacuum cleaners and try to deal with the 300 gallons of water on the floor in the event of an actual accident. A building could be shut down for days, maybe weeks, should one accident occur.
I just think that the regulations themselves should be rewritten. The reason that these eyewash and shower facilities are within ten seconds of locations where hazardous materials are used; is because they want them used immediately. They do not want employees thinking about the repercussions of using the safety equipment. I have worked for three different companies and at all three I have observed coworkers avoiding the equipment because they were more afraid of the use of it than the potential damage to themselves. I am not saying that is right, if they did suffer permanent damage; they would have been fired for not following directions. Fortunately the spills were not that bad and they had no problems.
Picture yourself working in this kind of environment and you have scrubs, Tyvek, safety glasses, googles, two pair of gloves, a set of Tyvek sleeves, face shields, hair nets, beard covers, face mask - you can sweat. But when working with chemicals; sometimes it is difficult to know whether that sweat is sweat or possibly a dangerous chemical. For safety sake you should immediately head to one of these stations and start your fifteen minuet rinse. But you have it in the back of your mind that you might shut down the building you are working in for a very long time and it might be only sweat! We need better regulations or better equipment.
I'm going to put this as gently as I can. Humanity survived, not because of hundreds of millions of dollars, but because humans had the capability of thinking in the future perfect tense. If a dinosaur with the untelligence of a lamp has a hundred million dollars and can hire work done, that does not insure its survival.
Physics has rules. One of those rules is that certain chemicals do not play well with eyes. When a regulatory body has an ah-hah moment, recognizes this, and sends warnings to dinosaurs, the onus is on them to figure it out and how to adress it or die - whether from direct exposure or lawsuit.
I don't picture myself in your scenario because I CAN think in the future perfect tense.
I'm going to put this as gently as I can. Humanity survived, not because of hundreds of millions of dollars, but because humans had the capability of thinking in the future perfect tense. If a dinosaur with the untelligence of a lamp has a hundred million dollars and can hire work done, that does not insure its survival.
Physics has rules. One of those rules is that certain chemicals do not play well with eyes. When a regulatory body has an ah-hah moment, recognizes this, and sends warnings to dinosaurs, the onus is on them to figure it out and how to adress it or die - whether from direct exposure or lawsuit.
I don't picture myself in your scenario because I CAN think in the future perfect tense.
Like I pointed out with the case of the 844 dead on the Eastland because of the, then new lifeboat regulations, just because a regulation tries to address a safety issue; does not mean that it creates a safer working environment. Another example of 'safety regulations' that can kill more than it saves are the regulations some states, like mine, have about clearing your roof of ice and snow. The idea is that we prevent accidents from sheets of ice flying off trucks and killing or injuring the motorist behind them. The legislation has good intentions; but it does not provide drivers with a safe means to accomplish the tack. In large freight yards it works because they install roof plows for the big trailers; but many trailers are parked at smaller docks with no equipment for the drivers to safely remove the snow and ice. 13'6" is a long fall from a very slippery and windy roof. There is a good chance that more truck drivers would die from trying to comply than the number of motorist saved (that only had to not tailgate).
Regulations are written to be rewritten when new equipment and new knowledge becomes available. I know that I am not the only person that works in this kind of environment. I am also sure that others have questioned the regulations. Many of the jobs I am referring to are covered by our FDA's 'CGMP'. That stands for: "Current Good Manufacturing Practices". They are not inflexible regulations; they expect businesses to utilize better tools and methods as they become available.
I'm not suggesting that all regulations are automatically best practice, simply that the one you focused upon was more an example of building designers not thinking about how to handle conflicting needs.
An example of a regulation/safety concept that needs work is the one that locks auto doors to prevent them opening in an accident. A latched door is minimally more likely to open, but with current electric auto lock and window opening systems, occupants of a vehicle that lands in a canal or river are almost guaranteed to be held in place until they drown.
I'm not suggesting that all regulations are automatically best practice, simply that the one you focused upon was more an example of building designers not thinking about how to handle conflicting needs.
An example of a regulation/safety concept that needs work is the one that locks auto doors to prevent them opening in an accident. A latched door is minimally more likely to open, but with current electric auto lock and window opening systems, occupants of a vehicle that lands in a canal or river are almost guaranteed to be held in place until they drown.
Because of my experience in the industry I truly feel that this regulation should be reviewed.
Because of my experience in the industry I truly feel that this regulation should be reviewed.
Fair enough, but with review with regulators, industry, and outside arbitrators with access to problem solvers all working towards a better implementation. There is no way I am going to suggest that blindness in employees is a viable route of reducing regulation cost, nor am I going to suggest that termination of employees protecting their own health is valid. I am still of the opinion that industry is playing stupid to save pennies. The historical precedent is not deniable.
Fair enough, but with review with regulators, industry, and outside arbitrators with access to problem solvers all working towards a better implementation. There is no way I am going to suggest that blindness in employees is a viable route of reducing regulation cost, nor am I going to suggest that termination of employees protecting their own health is valid. I am still of the opinion that industry is playing stupid to save pennies. The historical precedent is not deniable.
It is not uncommon for the industry to spend half a billion dollars or more on one of these buildings. Nothing is simple and they try to comply with all government regulations; the buildings have to be licensed by the government before they can start operations. There are multiple government agencies that the engineers deal with in the design of the buildings. Once a building is licensed; it takes almost an act of Congress to change any part of the operations. You cannot simply add on the building or change any equipment that the building was licensed and validated for. Everything has to be studied and again validated and then again presented to the proper agencies for licensing - all a very expensive procedure.
It is not uncommon for the industry to spend half a billion dollars or more on one of these buildings. Nothing is simple and they try to comply with all government regulations; the buildings have to be licensed by the government before they can start operations. There are multiple government agencies that the engineers deal with in the design of the buildings. Once a building is licensed; it takes almost an act of Congress to change any part of the operations. You cannot simply add on the building or change any equipment that the building was licensed and validated for. Everything has to be studied and again validated and then again presented to the proper agencies for licensing - all a very expensive procedure.
Which is part of why jobs go out-of-country. However, that doesn't address or excuse not having a method to deal with rinse water. Another idea to do so might be a giant one of those newfangled high tech things called a "bucket" That would require no structural change. Sorry, but over the years I have heard far too many excuses and far too much blame shifting for stupidity and laziness to accept such whinging at face value.
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