Sometimes, as design professionals, we must think outside of the box and develop solutions to problems that are before us but not always obvious or mandated by rules and regulations.
by David Dexter, FNSPE, FASPE, CPD, CPI, LEED BD+C, PE
Recently there have been many discussions about emergency equipment on the ASPE Connect Open Forum. This got me wondering about the origins and evolution of emergency equipment. As design professionals we are all obligated to protect the public’s health, safety, and welfare. Our designs should always be developed to do no harm and encourage the protection of those who work within and utilize our designs.
So, when was the first emergency shower invented? According to Wikipedia, the first mechanical shower was patented in London in 1767 by William Feetham, a stove maker from Ludgate Hill. Mr. Feetham developed a shower contraption that used a hand pump to force water into an elevated vessel, which was above the user’s head. (Sounds like the gasoline pumps of days gone by—yes, I remember and have used them). The elevated vessel had a bottom discharge, through a fitting or some type of head that would “shower” the user and dilute as well as wash away any hazardous materials with which the user had come into contact. Mr. Feetham made use of a chain mechanism that opened a valve to release the stored water upon activation.
Rules and Regulations
Over the years many changes and competing ideas have been developed and utilized to improve on and enhance Mr. Feetham’s patented shower. But it was not until 1981, 214 years after the original patent, when the International Safety Equipment Association (ISEA), working within ANSI (American National Standards Institute) guidelines, rules, and regulations, developed and issued the first national consensus standard regarding emergency equipment. The standard, known as ANSI/ISEA Z358.1, has undergone several revisions: 1990, 1998, 2004, 2009, and again in 2014 (the current edition). Each of these revisions was driven by changes within the industry’s understanding of the human condition and how to minimize injury and harm to a user who has been exposed to hazardous materials and chemicals.
Initially, emergency equipment was simply provided with a water supply—in the case of Mr. Feetham’s original patent, it was an elevated vessel—but over the years these pieces of emergency equipment became permanently connected to the domestic cold water system. As more was learned about how the human body reacts to various temperatures and exposures, the water supply was changed to a blend, or mixed tempered water temperature (generally defined as water between 85°F and 110°F).
However, as knowledge and experience grew, this temperature range was restricted to a tepid temperature (generally defined as water between 60°F and 100°F). Tepid means neither hot nor cold, or about room temperature; lukewarm is a synonymous equivalent. It has been determined that at this temperature the user of the emergency equipment will be able to remain within the water stream for the recommend amount of time without suffering thermal shock or leaving before receiving an adequate flushing of the affected area. It should also be noted that the desired water temperature should be coordinated with the owner’s medical/safety staff for the potential chemical hazards that might be encountered. Additionally, it is worth noting that there is an overlap between tempered tepid water temperatures, which does lead to some confusion on occasion.
The ANSI/ISEA Z358.1 standard establishes basic guidelines as to how emergency equipment should be constructed, operated, and maintained, acceptable operating temperatures, and testing. However, a standard is not prescriptive, unless and until it is referenced into law or the code. Some jurisdictions may not reference the complete standard, just some sections. The practice of selective acceptance or modification can lead to confusion and in some cases conflicts with other requirements. On the other hand, once a standard is referenced into the code or called out in law, it becomes mandatory.
OSHA (Occupational Safety and Health Administration) is the federal agency responsible for writing the set of regulations intended to protect the public, employees, and any others who might need such protections for their overall health and safety. OSHA references the ANSI/ISEA Z358.1 standard within its regulations, therefore making it mandatory for compliance (similar to many, if not all, model plumbing codes). The interesting thing about OSHA is that it does not include a “grandfather clause.” Hence, changes to the standard become mandatory upon public acceptance of the latest edition of the standard—meaning that owners and users of such equipment need to ensure that the equipment is operational and in compliance with the current standard at all times.
Applying Good Engineering Judgement
But, as we should understand, no code, standard, or law can address every possible scenario. Hence, as design professionals, we must apply engineering judgment and interpret the intent of the law or regulation. This is especially true of the OSHA regulations. As an example, the OSHA regulations do not specifically provide a definitive location for emergency showers and eye/face washes. The regulations describe the requirements and give guidance on their locations by stating a time interval between the points of possible contact with hazardous materials or chemicals and the relative protection of the safety equipment. They require a clear and unobstructed path, but the regulations do not specifically detail environmental conditions or appropriate drainage in the area of the emergency equipment.
While I am not aware of any requirement within ANSI/ISEA Z358.1, OSHA, or any of the model plumbing codes, drainage should be considered in association with emergency equipment. This would mean a floor drain beneath the emergency shower or a piped connection from an emergency eye/face wash. The emergency shower will provide a significant amount of water during its operation; it must have a flow rate of 20 gallons per minute (gpm) and operate for a minimum of 15 minutes or until emergency medical assistance arrives. This will dump at least 300 gallons on the floor. Thus, it would be good design practice to provide a means to waste this volume of water without adding to the potential damage of the surrounding area. This water can create “ponding” in the immediate area around the shower, in which an injured person could drown if they were to pass out or collapse from the traumatic shock of the exposure to the hazardous material or chemical. So, in the best interests of the injured person and from a public safety perspective, a floor drain should be provided.
Generally, we think of emergency equipment being located within a building envelope. However, there are many applications where consideration must be given to providing emergency equipment out and away from a building enclosure. One such example would be where there is bulk storage of chemicals or fuel storage as well as the loading/unloading areas for such storage. These locations can create some unique challenges, as the equipment will be remote from the facility’s utilities, cold/hot water, and electricity or other heating source. These locations also will most likely be exposed to the environmental elements of the open air.
It has been my experience that the standards, codes, and OSHA do not address any specific requirements for such exterior applications, so it it again falls upon engineering judgment to design an appropriate application to protect the public good, while doing no additional harm to an injured person. Exterior applications require that the design professional consider such things as environmental conditions and how those conditions could impact the injured person, where and how this equipment will be provided with the necessary utilities (water, electricity, or other heating source), and how notification of equipment activation can be provided to the appropriate personnel to ensure that emergency medical assistance arrives promptly.
A Case Study
As an example, I’ll discuss a project for a multi-national corporation in which I became involved. The firm had been asked to provide appropriate drainage for a fuel-unloading facility to serve a bulk fuel farm. The appropriate drainage will not be discussed here, as this discussion is about emergency equipment.
As this unloading area was several hundred feet away from the plant facility itself, getting appropriate utilities to the unloading zone needed to be discussed. The emergency equipment would need a water source for both hot and cold to provide the required tepid water to the shower and eye/face wash equipment. Additionally, this facility was in a northern Midwestern area, so freezing conditions would exist for at least part of the year. After much discussion, it was agreed that a domestic cold water service would need to be extended from the facility to the unloading location. This would protect the water piping from damage as well as minimize the risk of it freezing. As for the need for hot water, it was determined that it would not be practical to extend hot water along with the necessary return circulating line for the facility. Therefore, it would be necessary to extend electrical power to the unloading area with the service having sufficient capacity to provide for an onsite water heater. For risk and health safety concerns, a communications link would be needed to notify the facility’s safety office of an emergency event should the equipment be activated.
Now we had the necessary services to the area for the emergency equipment. But what type of equipment would be necessary for this location? After all, the water service, water heating equipment, and emergency shower and eye/face wash equipment needed to be protected from potentially freezing conditions. This conversation also led to discussions about protecting the person who might need to utilize this emergency equipment. The project manager, understanding that the cost was growing, did not see any requirements within the standards, codes, or OSHA that mandated providing an unobstructed enclosure. Thus, it was necessary to point out that as professionals, engineers must hold the public’s health, safety, and welfare above all other considerations. In addition, this design and the associated equipment must not add to or do any further harm to the person using the equipment. The area in which this project was located could see zero-degree temperatures with winds up to 30 miles per hour in worst-case conditions. I do not know any person, injured or not, who would remain under tepid water for a minimum of 15 minutes in these conditions. So the project manager finally relented and agreed that an enclosure was necessary.
As we selected and specified the emergency equipment package, choices had to be made. Should the hot water be provided by a storage tank type heater or an electronic instantaneous? Both would provide the necessary tepid water. The storage-type heater would pull a smaller electrical load but would require an emergency-type tempering valve along with a bigger footprint for the tank. On the other hand, the electronic instantaneous unit would demand a higher electric load (larger wire sizes and circuit breakers, etc.) but would take less floor space and not need a tempering valve. Ultimately, it was decided that the electronic instantaneous unit provided the best approach even though the electrical requirements were larger. It would minimize the risk of Legionella from growing in the potentially stagnant water in the hot water storage tank.
The final selection of the exterior emergency equipment package included an enclosure for the electronic instantaneous water heater, electrical switchgear, an electric heater to prevent freezing within the equipment side of the package, and a heating unit for the “wet” side of the package in which the shower and eye/face wash equipment was located. The equipment side of the package was self-contained and accessible through a locked access door. The emergency side was accessible through lightweight spring-loaded doors, so as not to restrict or minimize access to the safety equipment. The safety enclosure provided protection from the elements along with an acceptable temperature for a person standing under a continuous shower supplying tepid water. The communication circuit to the safety office provided the necessary notification of an emergency condition, activating a response by the emergency staff and first responders.
Needless to say, this was not an inexpensive package. Such packages can run between $75,000 and $100,000 in addition to the infrastructure needed to provide the support services. While not specifically mandated directly within the standards, codes, or OSHA regulations, it was necessary to protect the public (employees) and minimize the owner’s risk and liability toward protecting their employees and the delivery staff.
Sometimes, as design professionals, we must think outside of the box and develop solutions to problems that are before us but not always obvious or mandated by rules and regulations. In other words, sometimes we must apply logic and common sense.
About the Author
David Dexter, FNSPE, FASPE, CPD, CPI, LEED BD+C, PE, is a Registered Engineer, Certified Plumbing Inspector, and Certified Plans Examiner with more than 40 years of experience in the installation and design of plumbing systems. He specializes in plumbing, fire protection, and HVAC design as well as forensics related to mechanical system failures. Dave serves as Chair of ASPE’s Main Design Standards Committee, Chair of the Bylaws Committee, and Co-Chair of the Professional Engineer Working Group. He also was the 2010–2011 President of the Ohio Society of Professional Engineers.
The opinions expressed in this article are those of the author and not the American Society of Plumbing Engineers.