Anhydrous Ammonia – Emerg. Shower

[vickyp]

#102612

Forum: Community

G`Day All
We are a small facility in Ont. Canada. This company works with (small amounts of) Anhydrous Ammonia in one of their processes.
They are almost in total compliance with the OHSA regs & M.O.L standards as in ventilation, water hose supply, signage, SDS`s posted, etc….ButThey are reluctant to install an Emergency Shower. This Company`s mind set is that since they only use a 40 second blast, coming out of a very small Tank (personal BBQ size) that it is NOT necessary to spend the money and have one put in. Our Ontario Codes dictate that an Emerg. Shower is needed to be implemented within a 10 second radii of this chemical substance. I can NOT find any other regs that state othwerwise.
Can someone give my definitive direction & undisputable information so I can bring this back to our CEO and show them they need to have an Emerg. Shower installed at this sight.
please n thank Q
H & S Coordinator
T.C 

[vickyp]

#102989

Long story short, I think you’re right. Regrettably, the Ontario OHS Regs give you a lot less “CEO ammo” than most other jurisdictions would.Let me walk you through it. Although you don’t specifically say, it sounds like your facility is covered by the Ontario OHS Regs. for Industrial Establishments, Reg. 851. So I’ll answer accordingly.
Starting Point: Reg. 851, Sec. 125
125. Where a worker is exposed to a potential hazard of injury to the skin due to contact with a substance, a quick-acting deluge shower shall be provided.
Next Step: The Proposed MOL Revisions–Sec. 282 of Reg. 854 
Unfortunately, the current Regs. don’t go into specific detail re: the design and performance of the shower (other than that it be “quick acting”) But in Feb., the MOL proposed bringing the Reg. 851 requirements into line with current requirements for mines under Reg. 854, specifically Sec. 282(2) which says:
(2) At every mining plant where poisonous or dangerous compounds, solutions or gases are present, there shall be kept or installed in a conspicuous place, as near the compounds, solutions or gases as is practical, (a) antidotes and washes; (b) eye wash fountains; and (c) where necessary, showers for treating injuries received from such compounds, solutions or gases.  R.R.O. 1990, Reg. 854, s. 282 (2).
Notice that the Sec. 854 requirements require that the showers be installed in “a conspicuous place” as near the [ammonia] as possible. But the MOL proposal goes further by requiring that:
*The eyewash facility or emergency shower  be located or installed not more than 17 metres (55 feet), from where the substance is being used or kept in the workplace.
*A worker’s access route to the methods of protection mentioned above be unimpeded
* Workers be instructed or trained in the use of the protection methods in their workplace
Supplementary Use of Washes & Antidotes
The proposed MOL amendments would also give employers more flexibility in determining appropriate protection methods by allowing for the use of antidotes, flushing fluids and washes, in addition to (but not instead of) eye wash facilities and emergency showers as long as they’re readily accessible to workers and located in a conspicuous place as near as practicable to where the substance is kept or used. In addition, instructions for their use would need to be kept as near to this location as practicable.
****
Note that the MOL proposed revisions have not yet officially been approved. The fact that they were proposed by the predecessor Liberal administration could bode ill for their adopting under the PC regime. Also keep in mind that the OHS Regs. aren’t the only source. Thus to the extent your facility is subject to industry or voluntary standards, e.g., the “codes” you allude to in your question, they need to be part of the CEO briefing equation. Here are a couple of resources to check out:
*The MOL Proposal: http://www.ontariocanada.com/registry/showAttachment.do’postingId=26446&attachmentId=36844 (scroll down to p. 22)
*A recent OHS article on the MOL proposals and how they impact current eyewash/emergency shower policies: https://ohsinsider.com/topics/first-aid/ontario-compliance-alert-part-4-make-8-changes-to-your-eyewash-station-policy-to-comply-with-new-rules
*OHSI Model Eyewash Policy which incorporates the MOL revisions https://ohsinsider.com/tools/biohazards-chemicals-eyewash-stations-emergency-showers-policy-ontario-version
Hope that helps. Get back to me if you have any follow up Qs or concerns. Glenn glennd@bongarde.com

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