Do Your Emergency Eyewashes and Showers Comply With ADA Regulatory Requirements?

Posted by admin on 8/3/2015
If an organization has only provided emergency eyewash and shower equipment for the fully abled people, they are not adequately prepared for all potential users. This lack of foresight could result in liability issues and potentially very damaging lawsuits. It is better to prepare rather than attempt to undo irreparable damage.

The selection of emergency eyewash and shower equipment is often a complicated process. In addition to addressing design and engineering issues, designers must be aware of regulatory requirements and compliance standards. A common reference point when selecting emergency equipment is ANSI/ISEA Z358.1-2014, “Emergency Eyewash and Shower Equipment.” The provisions contained in the standard are widely accepted for the proper design, certification, performance, installation, use and maintenance of various types of emergency equipment (showers, eyewashes, drench hoses, etc.). However, in the case of emergency wash stations, the standard does not specifically address designing for people with disabilities. It is currently left to the organization to evaluate how their facility’s emergency washing equipment should be designed.

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ANSI/ISEA Z358.1-2014 is primarily applicable where workers are handling particularly strong acids, caustics or other materials where the consequences of a spill or splash would be very serious. As we know, chemicals are used in many different environments; such as labs, factories, and schools. In all of these environments, people of differing abilities can be found working. Therefore compliance with the requirements of both the Americans with Disabilities Act (ADA) and ANSI is of utmost importance if there is any possibility of handicapped individuals being in the area. Although, it is not a requirement in most states, this is slowly changing. In California, for instance, “policy 98-03 now requires a disabled-accessible shower and eyewash in every laboratory classroom, for all school modernization or new construction projects that receive state funding”.

Some have commented that emergency shower & eyewash equipment has no "accessible" dimensional requirements, because this type of equipment is not mentioned in the A.D.A. Accessibility Guidelines. Some have gone so far as to disregard the accessibility of this equipment entirely. This misconception could be the result of a fundamental misunderstanding of the A.D.A. 

If the A.D.A. and the A.D.A. Accessibility Guidelines (ADAAG) were just another plumbing or building code, then we need not pursue anything that is not specifically required of us in print. However, the A.D.A. is not a plumbing code. It is a civil rights law, which prohibits any form of discrimination against people with physical disabilities.

The A.D.A. states that "No individual shall be discriminated against on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place of public accommodation". So to deny a disabled person free and unfettered access to anything within a facility, that is freely available to any non-disabled person, is a violation of that disabled person's civil rights. Equal rights in this case, mean equal access.

If the disabled cannot be denied access to the laboratory to utilize the lab equipment at an accessible workstation, and thereby be exposed to the chemical hazards present, then would the Court find that the disabled person's civil rights would be violated for denying him access to the only lifesaving emergency shower and eyewash in that laboratory room? Would the Court rule in favor of the disabled if they were considering the issue after a laboratory accident, and subsequent injury of a disabled person?

The dimensional requirements that would make emergency shower and eyewash accessible are clearly defined in the ADAAG Standards, in the form of general dimensional requirements for the wheelchair, and for the wheelchair user's space requirements.

ADAAG Standards "Space Allowance and Reach Ranges" covers the minimum floor space, the width of approach, and the maximum forward reach and side reach ranges. Although, while ADAAG Section calls for a 30" wide (minimum) approach for the wheelchair, Section A4.2.1 states that "if the wheelchair must be turned at the opening or if 'sudden' movements are needed then a clear width of 32" is adequate clearance." The 32" wide approach allows for a slightly larger margin of safety, so a 32" minimum should be used for all design considerations wherever emergency equipment, life safety and emergency egress is an issue.

Sections 4.2.5, and 4.2.6, covers the forward and side reach ranges of the wheelchair user, and that if the eyewash were to be 20" long or less, that the pull rod handle would have to be 48" above the floor (or less), but that if the eyewash were longer than 20", then the pull rod handle could be no higher than 44" above the floor.

Additional maximum and minimum dimensional information is mentioned including, the standard 27" minimum knee clearance.

Wall mounted "Protruding Objects" (like eyewashes), and objects that hang down into the "Head Room" space (like shower heads), are covered in Section 4.4.

The laboratory work stations, noted in Section 4.1.3, are required to meet Section 4.32. And when we look in that section we find the same 27" high knee clearance that we have seen repeated throughout the ADAAG. The counter tops though are allowed to be between 28" and 34" in height, which affects all counter mounted eyewashes. However, given a 5" to 7" deep sink, where ledge-mounted pivoting eyewashes would typically be used, and allowing for the 27" high knee clearance, the counter tops could not be lower than 32".

It is important to note that ANSI Z358.1, allows for the eyewash spray heads to be as low as 33", even for the non-disabled person, so when we consider all of these dimensional ranges we can see that they allow for a single shower & eyewash that can serve either the able bodied or the disabled.

Since there is typically only one emergency shower and eyewash per laboratory room or laboratory classroom, and since one accessible device can serve either the able bodied or the disabled, specifying that it be disabled accessible will help to protect the health and safety of the disabled and the able bodied, while protecting the liability exposure of the specifier, and the property owner.

The use of some types of emergency eyewash that are recessed into the counter top, would require that the counter be no lower than 32", regardless of whether a sink is used or not.

The following paragraphs present an overview of ANSI and ADAAG guidelines for the performance and installation of emergency eyewashes and showers:

Emergency Eyewash Design Criteria

Eyewash stations usually protrude from a wall and will need to be approached directly by the injured person who may be walking or in a wheelchair. As such, this station design could benefit by giving consideration to the guideline 4.4 Protruding Objects of the ADA guidelines. This guideline specifies that if the object protrudes from the wall at a height between 27 and 80 inches, the protruding object should stick out no more than 4 inches. If the object is below 27 inches, however, there is no restriction. Since eyewash stations would be above 27 inches they should be set into a wall in order to prevent protruding out more than 4 inches. Eyewash stations will be approached by wheelchairs from a forward position, meaning that the wheelchair should be able to pull up to the eyewash station. Because of this it is important that the user is able to reach forward and use the station. Designers should note that ANSI Z358.1, Section 5.4.1 allows for the eyewash spray heads to be as low as 33 inches, even for the non-disabled person. That means that a single shower and eyewash can serve either the able-bodied or the disabled, in installed recognizing both ANSI and ADAAG guidelines”.

Emergency Shower Design Criteria

While the emergency shower must the above mentioned standards, it is also important to make sure that the emergency shower has appropriate wheelchair turning area and a pull cord that can be reached. The pull cord must fall within 15 to 48 inches above the ground in order to meet the forward reach guidelines 4.2.5 (Appendix B). Furthermore, the wheelchair turning area must meet the guidelines in Section 4.2.1 (Appendix B) that specify a 60-inch diameter area. These designs can all be combined to meet the needs of a wide group of users.


If these guidelines are followed, employees of varying abilities will be positively affected. Not only will these guidelines benefit people who are considered physically disabled, but it will also help others who, previous to a chemical accident, may have been able-bodied but were temporarily disabled by the accident. These guidelines help to make any emergency situation easier to solve by avoiding design pitfalls. However, simply installing emergency equipment is not a sufficient means of assuring worker safety. Employees must be trained in the location of emergency equipment and in its proper use. Emergency equipment must be regularly maintained (including weekly activation of the equipment) to assure that it is in working order and inspected at least annually for compliance with the standard. Most importantly, employers should develop a response plan to be used in the event that an accident does occur. The focus of the response plan should be to provide assistance to the injured worker as quickly as possible. There are a variety of alarm systems on the market that can be installed in conjunction with emergency equipment which serve to alert personnel and summon assistance if an eyewash or shower is activated. Nevada Technical Associates recommends installing an alarm unit with any emergency eyewash or shower unit.



Date: 8/2/2016
Does ANSI, ADAAG, OSHA, or any other standard that you are aware of require that you are able to utilize both the shower and the eyewash at the same time?
Andrew Gil
Date: 11/8/2016
How can anybody interpret the height and distance reach of a seated person's arm with the same for their eyes! The self-asserted arrogance of referencing those reach limitations in the ANSI code as some sort of proof that such individuals' needs with respect to the use of an emergency eyewash are indeed specified in the standard is little more than a failure to understand the human body

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