BCAB #1696 - Emergency Shower/Eyewash Connection to a Drainage System, Sentence 7.4.2.1.(1)

June 16, 2011

BCAB #1696

Re: Emergency Shower/Eyewash Connection to a Drainage System, Sentence 7.4.2.1.(1)

Project Description

This appeal involves the installation of three emergency shower/eyewashes in a pulp paper testing laboratory in an industrial building. The emergency shower/eyewashes are essentially overhead showers with a pull rod controlled valve and an eyewash device at a lower level. The shower will discharge 20 gpm and the eyewash will discharge 7 gpm. It is proposed to discharge the showers onto the slab-on-grade concrete floor which experiences frequent wetting during normal operations.

Reason for Appeal

With some exceptions Sentence 7.4.2.1.(1) requires every fixture to be directly connected to a sanitary drainage system. A fixture is defined as “a receptacle, appliance, apparatus or other device that discharges sewage or clear-water waste, and includes a floor drain.” Sewage is defined as “any liquid waste other than clear-water waste or storm water” and clear-water waste is defined in part as “waste water with impurity levels that will not be harmful to health.”

Appellant's Position

The appellant contends that the emergency shower/eyewash units are not fixtures because they do not discharge sewage or clear-water waste and that the Code does not intend emergency devices such as these to be classified as fixtures.

Building Official's Position

The building official maintains that the emergency showers are intended to wash contaminants off the worker so the discharge is sewage and the definition of fixture does not exempt devices intended only for emergency use. The building official recognizes the urgency for a worker to access the emergency shower/eyewash and the impracticality of containing the discharge with a direct connection to the drainage system so is willing to accept a floor drain near each one.

Appeal Board Decision #1696

It is the determination of the Board that the emergency shower/eyewashes are similar to a hose bib.  Therefore, Article 7.4.2.1 does not apply and there is no requirement for a floor drain.

George Humphrey, Chair