Top Violations of §5162: Emergency Eyewash and Shower Equipment in Data Centers

In my experience consulting with data centers across California, the adherence to §5162 of the California Code of Regulations, which mandates emergency eyewash and shower equipment, can be the difference between compliance and a costly fine. Let's dive into the most common violations I've seen and how to avoid them.

1. Inadequate Accessibility

The regulation is clear: emergency eyewash and shower stations must be accessible within 10 seconds of any location where hazardous substances are handled. Yet, I often find these stations tucked away in corners or behind equipment, making them less than the required 'unobstructed' path. To ensure compliance, consider the layout of your data center and place these stations strategically where they can be reached swiftly in an emergency.

2. Insufficient Maintenance

It's not just about having the equipment; it's about keeping it in working order. I've encountered numerous instances where the water in eyewash stations was either not flowing properly or was contaminated. Regular testing and maintenance are crucial. Based on available research, individual results may vary, but generally, weekly activation of the equipment is recommended to ensure it's operational when needed.

3. Lack of Signage and Training

Visibility is key. Without clear signage directing employees to the emergency equipment, response time can be dangerously delayed. Additionally, I've found that many data center staff are not adequately trained on the use of these stations. Implementing a robust training program and ensuring that signs are posted can significantly improve your compliance with §5162.

4. Improper Temperature Control

The temperature of the water in these stations is another area where I've seen violations. The water must be tepid, which means between 60°F and 100°F, to prevent thermal shock to the user. I recommend installing temperature control systems to maintain the water within these limits, ensuring both compliance and user safety.

5. Failure to Document

Documentation is often overlooked, but it's essential for proving compliance. I advise keeping detailed records of all maintenance, testing, and training related to your emergency eyewash and shower equipment. This not only helps in regulatory audits but also in demonstrating your commitment to safety.

By addressing these common violations, data centers can not only avoid fines but also enhance their overall safety culture. For further guidance, the Occupational Safety and Health Administration (OSHA) and the American National Standards Institute (ANSI) provide detailed standards and resources that can aid in achieving and maintaining compliance with §5162.