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socrateaser, Attorney
Category: Business Law
Satisfied Customers: 38129
Experience:  Retired (mostly)
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Does the IIAR bulletin 109 apply to Cal OSHA psm regulations.

Customer Question

Does the IIAR bulletin 109 apply to Cal OSHA psm regulations. Specifically the requirement for an eye wash and deluge shower both inside and outside an ammonia engine room. We received a citation and are going to informal conference. I believe that the section cited 5161(c) does not apply. (the eye wash station is outside the self closing door to the engine room) I believe to have an eye wash station inside the ammonia system room is unsafe. I have been told there are no exceptions to the IIAR standard and that if there is a door between the eye wash station and the employee, it is considered obstructed... even if it is within 10 seconds.

I believe this is not the case and sound safety practices dictate we not put an additional eye wash station in this room.
Submitted: 7 years ago.
Category: Business Law
Expert:  socrateaser replied 7 years ago.

Ammonia is listed under 8 CCR 5194(F) as a "hazardous substance."


It would appear that secs 5161 and 5162, concerning eyewash stations, apply sec. 5194 by reference, therefore the requirements of sec 5162(c), that the station be within "10 seconds" from the injured person, applies.


Hope this helps.


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