Lab Safety Requirements and School Administrators

Now that you are aware of the legal safety standards and have accepted better professional safety practices regarding science instructional space laboratories and classrooms in your schools covered in Part 1 of this series, let’s explore the critical requirements for you as the site administrator/supervisor to ensure that you are meeting your regulatory compliance requirements.  Be aware that these requirements are not suggestions or optional but enforceable regulations under legal safety standards.  Remember that as the building principal or supervisor, you are ultimately responsible for occupational health and safety on-site and in the field (school-sanctioned events/trips/excursions), and there is potential for shared liability in the event of an injury or an accident. 

Ensuring Lab Safety

As a school employee, you are responsible for these critical components of the safety program:

1. Having a current written (annually reviewed) Chemical Hygiene Plan
2. Having a current Hazard Communication Standard and written safety plan (annually reviewed)
3. Ensuring annual appropriate safety training for ALL educator employees
4. Ensuring proper PPE for all occupants of the science, STEAM, and CTE instructional spaces
5. Duty of Care obligations
6. Access to a current and accurate chemical inventory for products on-site
7. Use of student safety acknowledgment forms
8. Completion of annual physical safety inspections in science, STEAM, and CTE instructional sites and related areas
9. Minimizing access to chemical storerooms and safety storage cabinets
10. Ensuring appropriate ventilation in science, CTE, and STEAM instructional spaces and related areas.
11. Equitable access to instructional spaces (laboratories) for students with additional needs
12. Performing a potential hazard safety analysis and resulting health and safety risk assessment PRIOR to any planned activity

If you are unaware of these requirements, you need to familiarize yourself with these compliance requirements immediately and develop a progressive plan to implement each of these criteria in your school in order to meet mandatory legal objectives and maintain a safer instructional space for teaching and learning.  This is not optional — this is your responsibility as the school administrator.   Here are some real-world examples to help illustrate the importance of these criteria and how these impact the school building administrator/supervisor. 

It is important to recognize that even if you claim you were unaware of these regulations and accountabilities, it is not an excuse or justification when an accident or injury results. 

Teacher Safety Responsibilities

Scenario 1:

A science teacher performs an activity involving methanol in the laboratory as a demonstration to entertain the students, unknown to the department chair and/or principal.  Due to the properties of methyl alcohol, flame jetting occurs, and several students and the teacher are severely burned.  No PPE or other safety measures, such as the use of a safety shield or conducting the demonstration in the fume hood, were utilized.  This activity had been performed previously to generate student interest in science.  The resulting lawsuit involved shared liability, including the chemistry teacher, department chair, school principal, school district Chemical Hygiene Officer, Science Supervisor, and Superintendent of schools.   Multiple failures exist in this scenario, including duty of care, hazard analysis & risk assessment, lack of communication about planned activities, appropriate safety training, PPE, and not maintaining a safer work environment (laboratory), resulting in shared liability costing millions of dollars and resulting surgeries and lifetime scars for the students and chemistry teacher.  This was entirely preventable under appropriate employee training and supervision!

Scenario 2:

A physics teacher was having students study projectiles and forces involving the use of model rockets.  Students built the rockets using kits in the science instructional lab space.  The teacher then had students go to the soccer field to test their calculated projectile trajectories. Rockets were placed on a launch rod anchored in the ground.  The teacher didn’t bother doing a potential hazard analysis and resulting risk assessment.  Instead, just provided a generic “be careful” statement.

One student stepped up to the launch rod while talking to another student.  He turned his head, which came in contact with the end of the launch rod, impaling his right eyeball.  In a fraction of a second – his sight in that eye was permanently destroyed.  Fast forward, the student’s parents sued the teacher and went up the “food” chain to the Superintendent.  The teacher failed to mention the safety actions needed for this activity, including appropriate personal protective equipment, distance for observers from the launch site, and more.  Under duty or standard of care, the teacher and the administration/supervisors involved in shared liability were primarily liable. 

Employer Safety Responsibilities

Under OSHA, employees can directly report unsafe working conditions.  OSHA will either make an unannounced visit to the workplace or send a registered letter to the school’s employer requesting information about the working conditions as was reported by the employee. 

• A few examples include the following OSHA guidelines for schools and their employers:
• Unhealthy working environment: A poorly maintained or incorrect storage of hazardous chemicals in science laboratories can be equated to a hazardous working condition covered by OSHA.
• Unsafe machines:  Requiring a STEAM teacher to work in a lab and use unguarded machines such as table saws can equate to a hazardous working condition covered by OSHA.
• Inability to execute an emergency action plan: Blocked emergency exits are an example of a dangerous and unacceptable workplace scenario covered by OSHA, which has clear fire safety regulations.

Employers need to be aware that employees have rights they are entitled to under OSHA, which they must support, including but not limited to the following examples:

• A safer work environment free from health and safety hazards/risks
• Share safety concerns with the employer without retaliation
• Ask for an OSHA visitation inspection and be allowed to speak to the OSHA inspector
• Report any illnesses or injuries sustained in the workplace
• Have access to copies of workplace injury logs and illness records
• Be provided safety training in a language that the employee understands
• Power machines and hand tools safe to operate or handle
• Be provided appropriate personal protective equipment as required
• Be protected from biological and chemical hazards

Employers are legally responsible for addressing these potential safety issues in the workplace. They can be fined and/or incarcerated under certain situations where employees are put at severe risk in the workplace!

Remember that NOT knowing a safety regulation or compliance requirement is no excuse when an accident or injury occurs.  The supervisor of the school and others, including department chairs, district officials, and classroom teachers, are often included in ‘shared liability claims,’ and the duty of care clauses and accountability under the ‘prudent person test’ are used in this determination.  Working collaboratively, we can make schools safer through understanding and recognition of the laws and procedures in place involving continuous appropriate safety training for all, maintaining an organized science department, minimizing chemical concentrations and volumes used, conducting safety inspections, using student safety acknowledgment forms, maintaining accurate inventory records for chemicals and equipment as well as keeping these areas secured at all times to prevent unauthorized access will go a long way towards having safer teaching and learning instructional space in your school buildings. 

Safety First.  Accidents Last.  Stay safer!  

References

• National Fire Protection Association (NFPA). 2015. Section 7.3.1.2 Occupant Load, Life Safety Code 101– 75.
• National Research Council (NRC). 2012. A framework for K–12 science education: Practices, crosscutting concepts, and core ideas. Washington, DC: The National Academies Press.
• National Science Teachers Association (NSTA). 2015a. NSTA Position Statement: Safety and School Science Instruction.
• Occupational Safety & Health Administration (OSHA). 1990. 29 CFR 1910.1450(f)(2). Occupational Exposure to Hazardous Chemicals in Laboratories.
• Occupational Safety and Health Administration (OSHA). 2012. Hazard Communication Standard.
• Roy, K., Love, T., 2021,  What the Data Tells Us, ITEEA Key Findings