Responsible STEM Chemical Management

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How can you adequately encapsulate the topic of chemical inventory, storage, GHS labeling, Safety Data Sheets, and, of course, the associated hazards from the chemicals themselves in a compressed format and provide the necessary impact to the audience?  The topic of responsible STEM chemical management is one that many people in school districts are apprehensive about discussing due to the complicated and challenging nature of the legal and professional safety standards connected to having chemicals in the school laboratory and chemical storeroom.

Having a comprehensive chemical hygiene plan reviewed and edited annually and managed by an experienced and knowledgeable Chemical Hygiene Officer is an ideal situation and one that is as rare as a unicorn across the United States educational system. 

This scenario of having a CHP implemented by a responsible CHO needs to be changed for the safety of the staff, students, and stakeholders in the school district ecosystem. Let’s explore the fundamental pillars of responsible chemical management in a traditional school district environment looking specifically at your chemical inventory.   

However, to complete the mandated annual chemical inventory (or if you have not completed one before), key considerations and observations must be made first to ensure that this task can be completed in a safer environment. According to the safety committee at the NSTA, these are steps to consider before conducting a chemical inventory. 

Safety Pre-Screening For Responsible Chemical Management

Before you can effectively manage your chemical inventory, you need to assess the current status of your chemical inventory and the storage locations.

A safety pre-screening will identify unsafe conditions and practices such as sagging or damaged shelves, ignition sources, obstructed aisles, inaccessible shelves, corroded or unstable containers, the incompatible grouping of chemicals, availability of SDS sheets and an inventory, and the condition of the storage area.

Conducting a chemical inventory assessment will usually produce many surprises, including some of these situations:

• chemicals you did not know you had on-site
• chemicals in damaged containers
• chemicals in poorly labeled containers
• chemicals in containers without labels
• hazardous chemicals/ unstable chemicals
• toxic chemicals
• chemicals in need of special handling
• chemicals that are never used
• chemicals that are seldom used
• chemicals in excessive quantities
• chemicals in large containers

As a safer professional practice, recognize that if the chemical inventory pre-screening determines that it will be unsafe to conduct a chemical inventory due to existing hazards or risks, a trained professional should be contracted to correct any unsafe conditions as well as contracted to remove any hazardous chemicals which present an unsafe working condition.

Once it is established that it is safer to conduct the inventory, the process can begin. Your team should establish a plan for conducting the actual physical inventory. 

Summarizing Chemical Inventory Management

To summarize what is involved with chemical inventory management, it combines informed procurement practices, chemical storage, safer handling, and usage techniques, chemical regulatory compliance, and acceptable chemical waste management protocols.   

Chemical inventory is often overlooked until a dangerous and often preventable situation in the storeroom or when an official inspection occurs and deficiencies are identified. It is prudent to be proactive and follow the protocols and procedures in the CHP.

Creating an Accurate Chemical Inventory

An accurate chemical inventory that accounts for the products in the science and STEM department is central to responsible chemical management practices. Despite the legal requirement to have this current inventory in each school in the district, many schools today have a ‘mental listing’ of the chemical compounds on-hand in the minds of the chemistry teachers and often a department head. 

A reliable chemical inventory is important for three main reasons contributing to your overall awareness and management of these products.

Firstly, it is important to know which chemicals you have on hand, the volume or the amount of each chemical, and where they are stored in the stock room.

Secondly, you need to have this chemical listing available in case of a fire, flood, vandalism, or other situation that involves emergency services on-site at the school, who may need to know what chemical hazards exist before entering the chemical storage area. 

Ideally, this is digitally available online and can be shared as a spreadsheet easily in case of an emergency or upon request from the CHO or facilities personnel in the district. And thirdly, having an accurate chemical inventory can help reduce the purchase of multiple bottles of the same chemical due to not knowing what you have on hand.

Having duplicates or triplicates of the same chemical impact the overall chemical inventory volume and contributes to the overall potential for chemical interactions in the storeroom.

1. You will need to select an inventory system, a database, or a spreadsheet that contains a wealth of information on each one of your chemicals. Commercial inventory systems are available from various vendors and science suppliers, or you can create a simple version yourself.
2. Your team will need to record the following data for each chemical; the list should be modified according to your specific needs. The inventory team should include at least two people for safety and compliance. From a practical perspective, one person can assess the chemical bottle, label, amount on hand, storage, age, and usage. In contrast, the other person creates a record for each chemical.

• Name of the chemical
• Type of container
• Concentration, or molarity
• Estimated quantity (mass or volume)
• Purchase date
• Disposal date (often called an expiration date)
• Note if the chemical will remain in the inventory
• Note if the chemical will be disposed

3. The inventory system you choose needs to have ease of operation and ease of input and display of data that is simple and communicates the key information.
4. Once the inventory is complete, the information should be entered into your inventory program. The chemicals can then be reviewed for health hazards, physical/ chemical hazards, and environmental hazards.
5. Ensure that there is a corresponding SDS for each chemical in your inventory and as a safer professional practice, have a hard copy printed in a reference binder in the prep area for use when handling, dispensing, or storing chemicals.

It Starts With the Chemicals in the Your Cabinets

There is a well-known saying in chemical hygiene programs that there is ‘only one truly safe chemical storage system, and that is when you have only one chemical.’ Adding one other chemical to the inventory on hand increases the potential for chemical interactions.

The logic is that the greater the number of chemicals in your inventory, the greater the potential for chemical hazards and risks for the school science department. 

This is a serious problem in schools since there are typically chemicals past their ‘best-before’ dates, multiple bottles of the same chemical, and often chemicals on-site that have not been used for years. Each chemical inventory aspect has unique concerns and is a genuine cause for pause in the department. 

The typical high school has over 300 individual chemicals in its inventory but only uses 55-65 chemicals at least once a year.   That means abundant chemicals are stored, causing potential chemical reactions and interactions that provide no educational utility.

Imagine the real estate on the chemical shelving units and in the safety cabinets and the increased efficiency resulting from having a smaller, more manageable inventory. Your Chemical Hygiene Office would agree with this.

Importance of Chemical Storage

There are chemical storage requirements based on legal safety standards meaning that you cannot just put chemicals in a room, on a shelving unit, or leave them on the countertops in the prep room or chemical storeroom. Most school science departments have a dedicated storage area for chemicals, including a combination of chemical safety cabinets and open shelving. 

Having a chemical storage system in place is very important. However, from a physical perspective, some crucial observations must be made to facilitate the safer storage of your chemical inventory.   Ensure that all shelving is solid, sturdy, and securely anchored to the wall to prevent accidental tipping. 

You should look for corrosion on metal shelves in cabinets which is a result of chemical spills or a chemical interaction (this is usually the result of acid + a base being stored in the same cabinet resulting in salt and water created, which causes accelerated corrosion (oxidation) and the fine white precipitate powder found in the cabinets and on the bottles stored in them) and also inspect the shelf supports for corrosion, termite damage, cracking or sagging shelves and that open shelving has a raised lip on the front side to prevent accidental chemical ‘walking off.’  

Organizing Your Chemicals

Storing your chemical inventory in proper cabinets and shelving is important and is covered by multiple legal, regulatory, and compliance standards. Here is the summary of safer professional practices for your chemical inventory storage. Please consult the methodology used in your local jurisdiction in your Chemical Hygiene Plan.

Acids – Not all acids can be stored together! Isolate Nitric Acid and concentrated aids such as Sulfuric from others using a system that separates organic and inorganic acids. Keep these acids in specialized corrosive storage cabinets with a lock to prevent unauthorized access. Using secondary spill catchers in case of a broken bottle will contain the spill and allow for a safer clean-up in case of accidental release of the chemical(s) in the cabinet.  

Bases – Ensure that you store your caustics in a dedicated corrosive cabinet for ‘base’ chemicals without any acids in that cabinet. Keep the solids on the top shelves and the liquids on the lower shelves, and secure these chemicals with a lock and key to prevent unauthorized access. Using secondary spill catchers in case of a broken bottle will contain the spill and allow for a safer clean-up in case of accidental release of the chemical(s) in the cabinet. 

Flammables – the NFPA requires that you keep your flammable liquids and reactive metals in a certified flammable safety storage cabinet with a secure lock. 

Open chemical shelving units are used for the majority of the chemicals found in your inventory, such as sugars, salts, starches, and other relatively inert compounds typically used in middle and secondary school science and STEM programs, but there needs to be a chemical inventory storage system in place that provides direction on the segregation and placement of each chemical by family within the chemical storeroom. 

Safety Data Sheets are Required

This is a very simple requirement. For each chemical in your inventory, you MUST have the associated Safety Data Sheet (SDS). 

You should not have a chemical without an SDS, and if you have an OSHA or labor/workplace inspection and it is determined that this situation exists, the school will be sanctioned or fined for non-compliance. This is for EVERY chemical in the inventory.  

The older (pre-2015) MSDS must be kept for health regulations for 30 years (which means that today you will need these older MSDS from 1993 onwards to reference in case an educator develops a chronic condition as a result of chemical exposure) in either a printed or digitally archived version to meet this OSHA 1910.1450 Laboratory Standard mandate. 

The supplier or distributor you ordered your chemicals from is legally required to provide a current SDS for each chemical purchased and to only provide you with a properly GHS-labeled chemical.

Some suppliers provide digital access through their online SDS library database for their chemicals, and others provide a printed paper hardcopy of the SDS with every chemical shipment. The bottom line is that the school needs to have these SDS documents available. 

Keep Your SDS on Hand

As a safer professional practice, having a printed copy of the SDS for the chemicals being used in the laboratory is ideal in case of a chemical spill, splash, or other situations since the 16 sections of the SDS provide a tremendous amount of information to the reader. 

Ideally, the SDS and chemical should be from the same supplier. OSHA requires that you have an SDS for each hazardous chemical in your inventory (OSHA Brief: Hazard Communication Standard: Safety Data Sheets) however, as a better professional practice, ensure that you have an SDS for ALL chemicals in your inventory and not only the chemicals recognized as hazardous.

This includes the consumer commodities such as WD-40, baking soda, vinegar, or other items purchased at a grocery store, pharmacy, or another establishment from the moment that product crosses the threshold of the school door. It legally becomes a workplace chemical. 

The Last Word on Chemical Inventory in Schools

Understanding that schools are legally the custodians of the chemicals for their entire lifecycle, from purchase and delivery to storage, consumption, and disposal, having an accurate chemical inventory is an important component of the responsible chemical management program aligned to the current CHP in your school district.

From a legal liability perspective, having an accurate inventory helps identify known hazardous chemicals and their potential impact on the health and safety of the staff and students in your school. Access to this pertinent inventory information and the associated SDSs is especially important in an emergency and is a legal requirement that should increase the importance of completing and annually (at least) reviewing each chemical bottle in your science and STEM department.

Ensure that you have an accessible, accurate chemical inventory with the associated SDS for each product and that all staff is trained in chemical management, including hazardous chemical emergency procedures and a current Chemical Hygiene Plan that captures these standard operating procedures and protocols for your school district. 

References:

• Managing Your Chemical Inventory Part 1
• Managing Your Chemical Inventory- Part 2
• Chemical Management
• Scope on Safety: Yes, you need a Chemical Hygiene Officer
• Science Safety- Chemical Hygiene Plan Checklist
• Science Safety- Chemical Hygiene Officer Accountability
• NFPA- Life Safety Code®