Ethylene oxide emergency alerts in hospitals

January 8, 1987
Ms. Nikki Peden
Safety Regulatory Manager
HCA Partenon Insurance Company
[Recipient address omitted]
Dear Ms. Peden:
This is in response to you letter of November 17, 1986 regarding an interpretation of the ethylene oxide standard, 29 CFR 1910.1047. Please accept my apology for the delay in responding to your request.
Your specific question related to a means of alerting employees during an EtO emergency situation in hospitals, 29 CFR 1910.1047(h)(2).
OSHA defines an EtO emergency situation as "an occurrence such as but not limited to equipment failure, rupture of containers, or failure of control equipment that may result in an unexpected significant release of EtO sufficiently to produce acute toxic effects in exposed employees constitute such an emergency."
29 CFR 1910.1047(h)(1) requires written plans for emergency situations to be developed for each workplace where there is a possibility of an emergency. These plans shall be written in accordance with 29 CFR 1910.38 (Employee emergency action plans and [29 CFR 1910.39] fire prevention plans.)
Section (h)(2) of the standard requires some method of alerting employees of an emergency promptly. OSHA gives the employer the flexibility to choose any effective method of alerting employees including communication systems, voice communication system, or a bell or other alarm. However, if the employer choose to install an emergency alarm system, the system must meet the requirements of 29 CFR 1910.165 (Employee alarm system). It should be mentioned that 29 CFR 1910.165(b)(5) states the following:
For those employers with 10 or fewer employees in a particular workplace, direct voice communication is an acceptable procedure for sounding the alarm provided all employees can hear the alarm.
Therefore, such sophisticated alarm systems might be unnecessary for some facilities such as small hospitals with only one EtO sterilizer.
If we can be of further assistance regarding this matter, please feel free to contact us.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations

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[Requester letter reproduced on OSHA page; omitted here.]