Consider the Benefits of a Chemical Hygiene Officer in Each Middle & High School

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Legal safety standards and better professional safety practices require school districts across the nation to have a district-designated Chemical Hygiene Officer.  Often called the CHO (or Environmental Hygiene Officer in certain states), they have the responsibility and accountability to enforce and manage responsible chemical purchasing, handling, storage, and disposal procedures across the district among many other regulatory and annual compliance criteria. These criteria are based on the documentation contained within the local, customized Chemical Hygiene Plan under OSHA’s Laboratory Standard (CFR 29 1910.1450). 

Schools task the district CHO with multiple responsibilities, which may be manageable across a reasonably sized school district depending on the number of locations. This article will explore the benefits of having a site-based (school building) Chemical Hygiene Specialist in addition to the school district CHO designate to add another layer of safety and compliance in each school, making our school instructional spaces safer.

According to multiple authorities, including the National Science Teaching Association, the National Science Education Leadership Association, The Council of State Science Supervisors, the American Chemical Society, OSHA, and NIOSH, ‘Academic science laboratories can be unsafe places for teaching and learning due to risks associated with biological, chemical, and physical hazards.’  Remember that a CHO is required for formal academic laboratories found in high schools and that they can serve as a consultant for the implementation of the OSHA 1910.1200 HazCom standard that applies to most elementary schools.

However, a few elementary schools may have formal science laboratories that use hazardous chemicals, which would place them under the OSHA Laboratory standard.  Thus, a Chemical Hygiene Officer would also be required at that level.

Understanding Your Laboratory

If you have ever been in a science department with the typical apparatus, equipment, chemicals, and related materials — which usually have potential inherent hazards and resulting risks, you will agree with this statement after looking in the multiple science laboratories, classrooms, prep area, and the chemical storeroom. It is important to note that even if there is no designated laboratory facility, the instructional space used for these activities falls under the same regulations. According to the current case law and a thorough understanding of risk management protocols employed in our school districts, we know that there are legal liability concerns associated with teaching science and STEAM, especially when negligence or recklessness is involved. 

This is a separate and important conversation regarding each jurisdiction’s overall chemical hygiene program. While appreciating that aspect, just imagine what having a trained, qualified, and informed Chemical Hygiene Officer in each secondary school building could do to the overall culture of safety awareness and responsible chemical management.  

Chemical Hygiene Officer Accountability

School districts need to have a Chemical Hygiene Plan (CHP) in place with all the mentioned criteria and components and the site-specific standard operating procedures for the unique equipment, apparatus, materials, and chemicals in the schools located in each local region. This is a legal requirement under Federal OSHA’s Laboratory Standard regulations (or equivalent OSHA-approved state safety program and/or a state department of labor OSHA standard adopted by reference ). This unique localized CHP is based on these legal safety standards and better professional safety practices and is connected to other recognized authorities, including the EPA and local municipal or county fire marshal guidance and wastewater pollution control thresholds for safer disposal practices for chemical wastes generated on-site in school buildings. 

Standards For Chemical Hygiene Plans

The standard operating procedures listed in the CHP are based on these approved practices and help to guide educators and administrators through aspects of responsible chemical management. Through the knowledge, interpretation, and experience of the Chemical Hygiene Officer, the school district can implement the CHP as part of the legal, safer, and professional standards and use this legal document as a central component of their overall risk management program covering activities involving chemicals in school laboratories. Remember that non-OSHA states are governed by a similar Environmental Hygiene Plan that accounts for chemical safety based on products found or created within school science departments.    

As a reminder, IF THERE IS NOT A DESIGNATED CHEMICAL HYGIENE OFFICER ON RECORD, THAT RESPONSIBILITY AUTOMATICALLY DEFAULTS TO THE SUPERINTENDENT OF SCHOOLS REGARDLESS OF THEIR EDUCATION, EXPERIENCE, OR UNDERSTANDING OF CHEMICAL HYGIENE PROTOCOLS.

The responsibilities of this position require the District Chemical Hygiene Officer (CHO) to:

Maintain Safety

• Develop and implement the Chemical Hygiene Plan (CHP) and the safety program for the district, including professional development and safety training, reporting, and other functions noted here.
• Work with administrators and teachers to develop and implement the district-approved safety program and make adjustments as necessary based on an abundance of safety and risk mitigation.
• Monitor the procurement, use, storage, and disposal of chemicals used in the schools’ science and STEM laboratory programs. This can include the creation of a ‘banned’ or an ‘approved’ chemical listing. 
• Perform inspections of equipment and space in the laboratory when appropriate and ensure accurate records of OH&S physical inspections.
• Provide technical assistance to schools and employees on the Chemical Hygiene Plan based on legal safety standards (e.g., OSHA, EPA, NFPA, etc.) and better professional safety practices (e.g., NSTA, NSELA, ITEEA, ACS, etc.) see reference links below
• Provide regular, formal chemical hygiene and housekeeping inspections.
• Provide regular, formal inspections of safety infrastructure, including eye wash stations, drench showers, fume hoods, ventilation systems, fire prevention equipment, and PPE supplies.
• Complete an annual physical inspection in each chemical store room and laboratory, classroom, prep area, and facility in the science department. This is to be shared with the school’s administration.
• Coordinate requests for the acquisition, use, or disposal of chemicals identified as explosive, carcinogenic, mutagenic, highly toxic, or otherwise unsuitable for general school laboratories.
• Determine the need for personal protective equipment beyond that specified for general laboratory use based on the particular lab activities and ensure that all individuals in the lab have appropriate PPE.

Train Employees and Lead Safety Initiatives

• Develop and implement the Chemical Hygiene Plan (CHP) and the safety program for the district, including professional development and safety training, reporting, and other functions noted here;
• Ensure that employees have received appropriate safety training that is grade and discipline-specific to the available courses and has been properly documented for insurance and liability purposes;
• Assure that the Chemical Hygiene Plan is reviewed at least annually and revised as needed so that it is always in compliance with current legal safety standards and better professional safety practices;
• Implement appropriate training with regard to chemical hygiene for all district employees whose normal work locations include laboratory areas.
• Ensure that employees have access to the Chemical Hygiene Plan, SDS (safety data sheets), and other suitable reference materials to provide a safer teaching and learning environment;

Next Steps for Superintendents, Supervisors, and Chemical Hygiene Officers

Understanding the importance of the Chemical (Environmental) Hygiene Plan and the designated CHO at the school district to manage the overall implementation, safety training, document reviews, and on-site annual instructional space safety inspections, and the additional necessary legal aspects of the CHP, you should ask these relevant questions:

1. Is there a current CHP in the district?
2. Who is the designated Chemical Hygiene Officer?
3. How accountable do you feel for your district’s chemical health and safety?
4. Would having site-based Chemical Hygiene Officers add an additional layer of safety to the schools and overall risk management program in your district?

The answers to these questions will help you determine what your next steps will be as you develop your risk management program and use the Chemical Hygiene Plan as the foundational component of the safety plan in the science and STEM programs in your district. Please consult with your Science Supervisor, Chemical Hygiene Officer, School Science Department Heads, local fire marshal, Facilities Directors, and professionals with a comprehensive understanding of chemical hygiene plans and the intent and impact these documents have on the overall safety program. The bottom line is that ensuring teachers have access to this annually reviewed, current chemical safety document is extremely important to your risk mitigation and legal liability.   

Site-Based Chemical Hygiene Specialists Across the District

Looking at the listing of responsibilities incumbent on the CHO, having site-based Chemical Hygiene Officers or Chemical Hygiene Specialists appears to be a concept that should add another dimension of safety and compliance to the overall district safety or risk management program. For example, in New York State, it is a DOE requirement to have a CHO or Chemical Hygiene Lead in each high school with formal laboratories and hazardous chemicals on-site to minimize chemical exposures and peripheral concerns by having an appointed person on-site. 

This level of experience and understanding required of these on-site, school-based chemical hygiene specialists should provide increased levels of safety awareness and minimize legal liability and provide accurate, informed, and responsible chemical management.  

While this approach lends itself to larger districts where it is not possible for a single CHO to physically visit each school and provide the level of insight, observation, and assistance, it also makes logical sense that the smaller school districts could benefit from this approach and have people with this specialized knowledge or skillset in each secondary school proactively. 

Also noted is that in addition to having a chemical hygiene officer, if appropriate, the employer may establish a Chemical Hygiene Committee. The purpose of the Chemical Hygiene Committee (CHC) is to review, recommend, and develop policies and procedures to establish safer work practices involving laboratory chemicals.

Advantages of a Site-Based Chemical Hygiene Officer

There are multiple advantages to this approach, and it should be a consideration for all schools since the reduction in potential chemical issues is an advantage, as is the benefit of having a knowledgeable person available to immediately remedy any possible situation involving hazardous chemicals to reduce the impacts to the school community. Areas under the OSHA Hazard Communication standard, like art, technology education & engineering, agri-science, maintenance, etc., would especially benefit from having a site-based chemical hygiene officer, even if only in a consultant role.

Site-based Chemical Hygiene Specialists would need to have the necessary safety qualifications and experience to be effective in their roles. Safety in school environments is critically important, and adding this additional layer of site-based CHO Specialists would be a great addition to your existing safety and risk management program. 

Pathways to Training a Chemical Hygiene Officer

There are appropriate safety qualification programs that exist which provide this level of training and information to perform this role, such as the CHO / CHL Pathway at Science Safety Inc. that would prepare an educator for this new role and provide the necessary review and refresher for existing CHO’s or Chemical Hygiene Specialists.   Having these specialists in each school building would benefit the entire school ecosystem and add an additional dimension of safety and regulatory compliance that is often found or required in the industry. It should naturally be found in our school systems. 

The future is safer when it is human-led and technology-enabled, providing the intelligent landscape to make informed decisions that benefit all involved, which is why the ‘Site-Based CHO Specialist’ role just makes logical sense. As educators, we are in the business of intelligence — so let us start making more intelligent, forward-looking decisions, including having site-based Chemical Hygiene Specialists in our high schools. 

References

• Minimum Safety Practices and Regulations for Demonstrations, Experiments, and Workshops, NSTA
• NSTA Position Statement: Liability of Science Educators for Laboratory Safety
• Addressing Safety and Liability in STEM Education: A Review of Important Legal Issues and Case Law
• The Importance of Chemical Hygiene Plans in School Districts
• NSTA Position Statement: Safety and School Science Instruction
• Responsible STEM Chemical Management
• Science Safety CHO / CHL Safety Qualification Training Program