Responsible Chemical Management Part 2

Responsible Chemical Management in K12 Education       

Based on a recent article published on responsible chemical management for school districts, some questions about the accountability, liability, and responsibility of having chemicals in your schools were left unanswered. 

Chemical inventory management refers to managing chemicals throughout their lifecycle. Proper management includes the purchase, receipt, storage, handling, dispensing, activity, disposal, and waste management (and the necessity of safety training for those involved). However, do you know who is specifically responsible for managing the chemical hygiene activities and how that can impact your overall risk management program? 

Key Factors For Responsible Chemical Management

To better understand these important aspects of chemical management, there are some key concepts to be aware of and how different personas have different roles in the overall lifecycle of the chemicals in your school science departments. 

Remember that a designated Chemical Hygiene Officer at the district level should manage and implement this safety program for educators and schools through a multi-dimensional approach. This approach includes safety training, the chemical hygiene plan, safety acknowledgment forms, annual laboratory inspections, and secure storage of chemicals. In addition to the responsible chemical and SDS management for each site across the school district, a chemical hygiene plan is the foundational core for better chemical management and safer practices.

Most Important Factors For Responsible Chemical Management

Safety is the primary driver in chemical management and having chemicals on hand in chemical storerooms in your science departments comes with inherent risks. Not all chemicals are hazardous or toxic and cause harm. However, many chemicals are classified as hazardous since they have health and environmental impacts and are safety concerns. 

Additionally, as referenced in the 16 sections of SDS, many chemicals are hazardous and can cause burns, fires, explosions, and toxicological health effects. A solid understanding of chemical hazards and the safety protocols in place are the foundation of your school’s chemical management program. 

Managing Chemical Risk

Managing your chemical risk strategy requires this specialized knowledge layered with accurate inventories so you can make decisions based on the risks for EACH chemical in the cabinets or shelving units in your science departments. 

An accurate inventory provides the pathway to manage the unique needs of each chemical and its storage handling and disposal requirements. This will also allow you to identify any exceptionally hazardous or recognized ‘banned’ chemicals that should be purged from the inventory for health and safety reasons.    

Proper Investment in Responsible Chemical Management

Another benefit to having an accurate chemical inventory and responsible chemical lifecycle management is that the schools ultimately save money. Imagine not knowing what you have in your kitchen cupboards, fridge, and freezer and constantly buying items you already have in your home. 

Furthermore, the same dynamic is true in the science department since reducing redundant purchases is possible when there is a shared understanding of what is in the chemical storeroom. Why are there five 100g bottles of sodium chloride in the room or found on the inventory report? It makes more sense to have only one bottle on hand (unless these are used to efficiently handle student workstations). 

Aggregating your chemical purchases and ordering smaller volumes and chemicals with the lowest molarity or concentration required helps reduce your overall volumes or quantity. This reduces the potential for chemical interactions and increases safety. 

Reduced Inventory & Responsible Chemical Management

Having a smaller inventory has a lower operating cost than managing a larger one and requires fewer safety cabinets and shelf space which saves money. A smaller inventory also typically reduces your annual fees for chemical waste disposal from the chemicals used during student experiments and teacher demonstrations. 

This cost-saving is also connected to sustainability and minimizing environmental impacts or chemical footprints, which has a larger value than the monetary offsets from having a smaller inventory. 

As discussed previously, typical high schools have, on average, 300+ different chemicals in their inventory. Yet research has demonstrated that a comprehensive and robust chemistry program can be achieved with as few as 60 chemicals.  

A dedicated section on chemical inventory management in your Chemical Hygiene Plan for the district should outline your standard operating procedures and inventory management systems.   

Risk Management & Responsible Chemical Management

Understanding that your chemical management plan and program are in place for legal and regulatory compliance mandates makes this a more important aspect for the school district from a risk management perspective. 

Avoiding fines and not wanting to have any legal entanglement with OSHA should not be the main reasons for implementing responsible chemical management practices; however, these are practical and beneficial to the school district. 

Under OSHA CFR 29 1910.1450 Laboratory Standard and the OSHA 1910.1200 Hazard Communication Standard (HazCom), it is a compliance requirement for employers (school districts) to provide employees with access to accurate chemical records. The appropriate compliance includes inventory, proper GHS-compliant labeling, the SDS for each chemical on hand, and medical or environmental testing results. 

Recognize the Importance of Regulation

Regulations are used nationally, with some variations in certain state jurisdictions that are even more strict than the OSHA standard. NFPA fire safety standards apply due to certain flammable or combustible chemicals in your schools.   

Providing appropriate chemical safety training to newly hired employees or employees with changed assignments is another regulatory requirement for all employees with potential access to or exposure to hazardous chemicals. 

As employers, school districts are obligated to provide this safety training and emergency response control for spills (often called ‘accidental release events’) and to detect possible symptoms resulting from potential hazardous exposure.  

Not having an accurate chemical inventory can result in a state-level or federal sanction or monetary fine being levied against the school district for non-compliance. Ensure that you have an accurate chemical inventory for your science departments that reflects your actual on-hand chemical products.  

Collaborative Responsible Chemical Management in K-12

According to the safety committee at the NSTA, responsible chemical management results from many individuals working collaboratively towards a safer chemical hygiene program for all stakeholders in the school district. 

Key Stakeholders in Responsible Chemical Management

Chemical management is a process that encompasses the identification, management, and reduction of risk through all stages of chemical purchasing, storage, distribution, use, and disposal. 

To understand this concept properly, accept that there is not one singular answer to the central question for school districts. Who is responsible for managing the chemical inventory? This is because many individuals throughout the school system have an important role in managing the chemical inventory:

Board of Education

Should establish a Chemical Hygiene Officer position and adopt a Chemical Hygiene Plan that addresses chemical management.

Superintendents

Creates a budget line for safety and ensures that science safety is a priority. All Superintendents should ensure the Chemical Hygiene Plan is implemented and addresses responsible chemical management. It is also their responsibility to handle any deficiencies identified across the school district with a sense of urgency.

Chemical Hygiene Officer

Consults with the administration and teachers to promote the safer operation of science classrooms and laboratories. They should focus on the employer’s chemical hygiene plan by organizing appropriate safety training and chemical management and performing physical safety inspections in laboratories and prep areas.

Principal or School Building Administrator

In concert with the Chemical Hygiene Officer, the principal acts as a safety advocate for the school and teachers. They manage the chemicals in the science and STEM departments and provide a layer of instructional supervision to oversee all activities performed in the school.

Science Chairperson/Supervisor

Oversees the evaluation, purchase, storage, disposal, and safer use of chemicals in the instructional program with the assistance of the Chemical Hygiene Officer and School Principal under a Duty of Supervision obligation for educators.

Teachers

Responsible for storing, using, evaluating, disposing, and purchasing chemicals. Elementary and middle school science teachers should seek the assistance of the district Chemical Hygiene Officer in cooperation with leadership if available for chemical management concerns.

Business Manager

Establishes procedures for purchasing chemicals throughout the year and works to address loss control issues, including hazardous chemical risk management issues in science facilities.

Facilities Manager

Assist relative to the disposal of chemicals by a licensed waste hauler or other environmentally approved and appropriate means. They also provide a chemical bunker or chemical storeroom on-hand in the school. OSHA requires that you have an SDS for each hazardous chemical in the inventory (OSHA Brief: Hazard Communication Standard: Safety Data Sheets)

Safety Data Sheets

Better professional practices encourage SDSs for all chemicals in your inventory, not only the recognized hazardous chemicals. A Safety Data Sheet is the standard documentation for every hazardous chemical manufactured or sold in the United States. It contains information in a specific format so science teachers, emergency personnel, and other users can find needed information.

This cannot be stated any more clearly: Every chemical in your inventory must have an SDS sheet. When chemicals are ordered, an SDS sheet needs to accompany the order. The shipment must have an SDS sheet to be accepted. Everyday items used in your classroom, such as baking soda, vinegar, and ammonia water, if part of your inventory, require an SDS sheet once inside the school.

Dr. Roy’s Three R’s of Responsible Chemical Management

Besides creating an accurate inventory of the chemicals that will remain in your inventory and identifying the chemicals in your inventory that needs to be disposed of. You also need to consider the three R’s of chemical management: reduce, reduce, reduce. Maintaining small and limited quantities of chemicals will promote the prudent and effective management of your inventory. 

You should ask: ‘How do I develop a plan to maintain small and limited quantities of chemicals to meet the curricular objectives in the science programs?’

Purchasing Chemicals

Firstly, your district needs to consider a Purchasing Plan. The plan needs to include two essential components. Moreover, the first component is to only purchase chemicals in quantities that will be consumed during the current school year, with any remaining quantities (hopefully a minimal amount) to be consumed the following year. 

The second component is the method to accomplish this: “Just in Time Purchasing.” Chemicals are purchased at various times during the year when needed and in quantities needed for particular activities. This method limits the quantities in storage, eliminates excessive quantities of chemicals, and reduces future disposal costs.  

Thirdly, remember to purchase what you will need and what you will use in your activities. Investing in planning for chemical procurement is invaluable to your overall chemical management program.

Again, using these steps, schools can better manage their inventories and minimize the amounts or volumes of chemicals by examining their unique chemical needs with a critical lens. The key criteria are listed here for your consideration:

Determining Chemicals Needed By Program

1. From your program, review the list of proposed or accepted student activities.
2. What activities will require the use of chemicals?
3. Which chemicals will be required for the activities?
4. Is the chemical appropriate for the students, the teachers, and the facilities?

(Assess the hazards and associated risks and complete a hazard analysis first!)

Determining the Quantities or Volumes Needed

1. Review the quantity of the required chemicals that are currently in the existing inventory on hand. By discipline (chemistry, biology, physical science, technology, etc.) and grade level,
2. By discipline (chemistry, biology, physical science, technology, etc.) and grade level, determine the chemicals needed for the school year based on the quantities required and the quantities available in the current inventory. Ensures that established maximum quantities are not exceeded before purchasing additional amounts of a specific chemical. See better professional practices in the chemical safety management resource ‘Rehab the Lab.’
3. Chemicals should be purchased by “Just in Time” procedures. At times, based on a particular need, some chemicals may be purchased quarterly.
4. Generally, attempt to restrict the quantity (solids) to a container no larger than 500 g. If larger quantity containers are requested, a reason should be provided and approved for that specific chemical.
5. Restrict the quantity of a solution to a 500 mL container or a 1 L container maximum. Ordering the appropriate concentration or molarity needed is ideal.
6. All concentrated acids should not exceed 1 L size containers. All acids should be purchased “Just in Time” as needed throughout the year in the lowest molarity needed to minimize safer storage and possible chemical interactions.
7. Concentrated ammonium hydroxide should not exceed a 500 mL container.
8. Flammables should be purchased “Just in Time” throughout the year.

Processing Chemical Requests

1. Materials on the “Acceptable Chemical List” are the only chemicals that can be purchased. (All school districts should develop an “Acceptable Chemical List”). See better professional practices noted in Rehab the Lab.
2. Provide the catalog number, quantity, and cost for each chemical requested.
3. All chemicals need to be assessed for hazards. (TLV [PEL], LD 50, health hazards, physical/chemical hazards, environmental hazards, National Toxicology Program [carcinogens], disposal)
4. For all chemicals purchased:
5. A) An appropriate storage facility shall be available. (proper chemical safety storage cabinets, isolation chambers, locked and secured rooms)
6. B) Engineering controls shall be available. (fume hoods, eyewash, shower, and other measures to reduce exposure to chemical hazards)
7. C) Personal protective equipment shall be available. (approved goggles, hand protection, aprons, face shields)Before issuing purchase orders, all chemicals must be approved by the Chemical Hygiene Officer or safety offices.

The Last Word on Responsible Chemical Management

First, with this understanding of the multi-dimensional approach to providing responsible chemical management as part of your school district’s overall risk management strategy and the various stakeholders involved with managing different aspects of chemical hygiene practices, you can make more informed and intelligent decisions regarding chemicals in your school district. 

Next, by using these safer chemical management strategies in your schools, safety awareness should increase through safety training. Furthermore, reductions in redundant purchases and wastes generated, increased regulatory compliance through OSHA hazard communications, and understanding of chemical spill and splash procedures are all connected to accurate chemical inventory using chemicals. 

Finally, there are specific and safer procedures for having chemicals in your schools to protect the teachers and students from accidents and injuries resulting from chemical handling or potential exposures. Your school district’s designated Chemical Hygiene Officer is a valuable asset and a critically important person to help you achieve your safety and risk management objectives. 

References

• Managing Your Chemical Inventory P1, NSTA
• NSTA Managing Your Chemical Inventory P2
• Chemical Management, NSTA
• Chemical Hygiene Plan Checklist, Science Safety,
• Science Safety, Chemical Hygiene Officer Accountability
• LNI, Rehab the Lab
• NFPA, Codes, and Standards
• C0SSS, High School Science Safety