Eyewashes and ADA requirements

By their current definition, Americans with Disabilities Act guidelines do not provide accessible dimension requirements for either emergency drench showers or eyewashes. However, failure to recognize ADA accessibility guidelines when designing an emergency eyewash and drench shower system could have serious consequences. It's important to remember that ADA is not just another plumbing or building code. ADA is a civil rights law, which prohibits any form of discrimination against people with physical disabilities.

Although the American National Standards Institute provides design configuration, capabilities and access guidance for the installation, operation and maintenance of emergency showers and eyewashes via ANSI Z358.1, that standard does not specifically distinguish between handicapped and nonhandicapped accident victims. Therefore, the assumption can be made that the ANSI guidelines apply to all accident victims, handicapped or not. This, in turn, leads to a reasonable assumption that designs probably should comply with the requirements of both ADA and ANSI, in any situation where handicapped individuals might be in the area.

In its General Requirements (Section 36.201), ADA states, "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." That means that disabled persons must be given free access to anything within a facility that is freely available to someone who is not handicapped. Furthermore, it easily could be interpreted that access to a specific feature of a facility also should be provided in the time frame established as a safe maximum for the nonhandicapped. Consider the ANSI requirement for 10-second transit time to the nearest eyewash and/or shower station, and all of the other associated requirements in the context of ADA. It can pose a significant challenge to system designs for laboratories or other facilities where handicapped individuals might be employed. "Equal rights" can be interpreted as "equal access."

For example, a disabled person cannot be denied access to laboratory equipment at an accessible workstation, thereby potentially exposing him or her to hazardous substances. At the same time, that handicapped person must then, logically, be afforded the same access to emergency response resources available to a nonhandicapped individual. This is the point at which ADA and ANSI Z358.1 overlap: Equal access is a civil right per ADA, and measurement of access is a function of ANSI Z358.1, which makes no distinction between handicapped and nonhandicapped individuals.

More and more government and private entities are taking steps to comply with both ADA accessibility guidelines and ANSI. California's DSA 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.