Safety Training in STEM and CTE Programs a Necessity

Safety Training in STEM and CTE, Why is it necessary? Why you should do it, and how often?

This is a common question from school districts, school building administrators, and teachers since there is some variation in the answer depending on the jurisdiction that you are in (certain states have different interpretations and regulations) and, ultimately, the frequency of safety training is determined by the employer (school district).

As you can imagine, this can be frustrating and difficult for stakeholders in educational systems to understand and schedule to be considered ‘compliant’ with federal, state, and local requirements. Let us investigate the most referenced safety standards that apply to science, STEM, and CTE teachers (and students) and their supervisors at the school and district levels. 

As a benchmark indicator, according to Dr. Roy and Dr. Love in their recently published ‘What the Data Tells Us’ research, 35% of Science, STEM, and CTE teachers have NEVER had formalized safety training (either during their preservice or initial hiring at the school district)  which is a frightening and preventable statistic with legal implications for teachers, principals, and superintendents in case of an accident or an injury to a staff member or a student.   

Research On Safety Training

One of the most interesting key findings from the 2021 Dr. Roy and Dr. Love study on safety in schools was that ‘There was an identifiable lack of safety training, as only 54% of participants reported receiving such training during undergraduate technical and teaching methods courses. This not only puts students at a higher risk of an accident but also does so for the teacher! 

Teacher preparation programs and mentor teachers should ensure safety is a core focus for all preservice teachers. Undergraduate and Faculty of Education programs should have a practical laboratory safety training component as a requisite criterion or condition of graduation where students are expected to be able to demonstrate competency and understanding of fundamental laboratory safety procedures and hazard identification coupled with risk assessment and exposure to legal, professional safety standards including the OSHA Laboratory Standard and the National Fire Protection Act (NFPA) at a minimum due to the inherent risks found in the science laboratories and CTE laboratories in schools across the land.   

Key Findings On Occupational Science Training

Another key finding from Drs. Roy and Love were that ‘there was also an identifiable lack of safety training provided by school districts. The Occupational Safety and Health Administration (OSHA) requires employers (school districts) to train employees (teachers) upon initial hiring, anytime thereafter when a new hazard is present (e.g., new equipment, new chemical, etc.), and when there is a new job assignment in the workplace (STEM or CTE lab). 

Further research featuring statistical analyses from the data in this study revealed that a lack of safety training, along with other factors, was significantly associated with increased accident rates. This is a preventable statistic with the proper grade and discipline-specific safety training provided at least annually to educators in science, STEM, and CTE programs. This is both a powerful and frightening fact when considering that there is no consistency in safety training and these teachers are the same people responsible for modeling proper laboratory procedures for students in the laboratory. Makes you think about the multiple failures in existing safety training strategies in school districts, doesn’t it?   

A Legal Perspective on Safety Training for Educators

K12 science laboratories are often perceived as ‘dangerous’ or ‘unsafe’ places for teaching and learning due to the inherent hazards and risks associated with a combination of biological, chemical, and physical hazards in these academic laboratories. OSHA recognized the need for a series of legal standards specifically for science laboratories and in 1990 (over 30 years ago) created what is collectively known as the ‘Laboratory Standard’ (29 CFR 1910.1450), which requires all employees working in laboratory settings (including special education teachers and paraprofessionals) to undergo safety training before they enter the lab.

This is to ensure employees are aware of and know how to work with chemical hazards in the work area. This is important – since there is no mention of physical or biological hazards mentioned in the regulation referenced, only ‘chemical’ hazards. The potential physical and health hazards associated with chemicals are the baseline for OSHA 1910.1450 and the requirement for a Chemical Hygiene Plan. The CHP must be tailored to reflect the specific chemical hazards present in the laboratory where it is to be used.

The OSHA Lab Standard clearly states that ‘Laboratory personnel must receive training regarding the Laboratory standard, the CHP, and other laboratory safety practices, including exposure detection, physical and health hazards associated with chemicals, and protective measures.’

Laboratory Safety Information Requirements

As responsible educators know, under CFR 29 OSHA 1910.1450, safety training must occur during the initial work assignment and prior to assignments involving new chemical exposure situations. All workers in the laboratory must be provided with access to relevant safety information and training that includes, at a minimum, the following criteria:

1. Access to the OSHA Laboratory Standard and associated appendices
2. Access to the Chemical Hygiene Plan (CHP), otherwise referred to as an Environmental Hygiene Plan in non-OSHA jurisdictions
3. Access to the Permissible Exposure Limits (PEL) in case of potential exposure to OSHA-regulated hazardous substances
4. Access to Threshold Exposure Limits (TEL) for chemicals in the laboratory inventory
5. Review of potential chemical exposure health and physical symptoms and signs awareness
6. Access to Safety Data Sheets (SDS) and associated safer handling and responsible chemical management practices involving storage, dispensing, disposal, and waste management.

Refresher On Safety Training

Additionally, OSHA mandates that the school district (employer) provide the following safety training topics initially and as part of the ongoing and ‘refresher’ safety training to all employees with access to the laboratory or chemical storeroom:

1. Monitoring and methodology are used to detect the accidental release of a hazardous or potentially hazardous chemical. This will include assessing odors, precipitate, and physical observations of chemicals and their storage system.
2. Identify the potential chemical hazards (physical and health hazards) for chemicals found in the inventory on-site.
3. A hierarchy of controls and measures is used to mitigate these chemical risks, including administrative controls, engineering controls, PPE, substitution, and elimination, as well as the laboratory’s standard operating procedures and emergency procedures.
4. Access to the Chemical Hygiene Plan and specific sections that apply to the role and responsibilities associated with the program being instructed.
5. Retraining and assessment when required (frequency to be determined by the employer)

Ensuring Your Chemical Hygiene Plan

The employer is required to review the chemical hygiene plan (CHP) or environmental hygiene plan (EHP) annually and make edits and enhancements. It is a responsible practice to provide these updates and some form of safety training to fellow educators in the form of a ‘safety refresher’ training on the contents of the CHP.

Certain jurisdictions require that at science and STEM department monthly meetings that a portion of the time is allocated to safer practices and conversations of legal and professional safety practices that apply to the department and formal documentation for these training sessions. 

Many factors contribute to the safety training schedule, which will be unique to each school and district, yet the requirement for progressive, ongoing relevant safety training exists. Ensure that all department members acknowledge the safety training content being discussed as a mechanism to reduce legal liability and potential legal entanglement.

Key Elements of Safety Training for Educators

According to the official NSTA position paper on ‘Safety and School Science Instruction,’ there are some key elements to be aware of regarding safety training in these program areas. Comprehensive safety programs are important tools in reducing injury during science activities.

School district leaders are responsible for developing and adopting a comprehensive safety program that includes safety policies and procedures that are consistent with better professional practices and legal safety standards.

NSTA recommends school districts develop safety programs based on the following guidelines:

• Safety programs should be consistent with the Duty of Care (NSTA Safety Advisory Board 2014a) as applied to engineering controls (e.g., fume hoods, fire extinguishers, etc.), administrative procedures (e.g., chemical management policies and emergency procedures), and personal protective equipment (safety goggles, gloves, etc.).
• Safety programs should include a Chemical Hygiene Plan to properly manage hazardous chemical and biological materials (e.g., appropriate selection, storage, inventory, use, and disposal).
  • Program procedures should meet or exceed existing standards adopted from federal government agencies, such as the Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA); professional material standards associations, such as the National Fire Protection Association (NFPA), International Code Council (ICC), and the American National Standards Institute (ANSI); professional teacher associations, such as NSTA, the National Science Education Leadership Association (NSELA), and the American Chemical Society (ACS); and appropriate state and local agencies.
• All school employees, independent contractors, and emergency personnel should have direct access to Safety Data Sheets (SDS) or other similar updated guidelines for all hazardous chemicals used in instruction. SDS set forth guidelines for the safer handling and use of chemicals. OSHA publishes these guidelines and has adopted a new system titled the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
• School districts should designate one or more chemical hygiene officers or someone equivalent who has the knowledge and training to monitor and oversee the implementation of a Chemical Hygiene Plan. The NSTA encourages all school districts, including those not covered under OSHA’s Laboratory Standard (OSHA 1990), to comply with this laboratory standard for safer working and learning environments for teachers and students.
• School district officials, such as principals, assistant principals, science supervisors, superintendents, and board of education members, must share the responsibility of establishing, promoting, maintaining, and updating safety programs to include changes in legal safety standards and better professional practices.
• School district officials should inform teachers of the nature and limits of applicable professional liability and tort insurance held by the school district (NSTA 2007a).

Safety training is essential to ensure that science activities are conducted in the safest manner possible. NSTA recommends the following actions for ongoing science and STEM educator safety training programs:

• All teachers and others responsible for the safety of students and other personnel should receive necessary, appropriate, and ongoing training related to the operation of the engineering controls, personal protective equipment, safety procedures, and all components of the safety plan.
• School districts, as employers, have the legal responsibility to conduct districtwide science safety training for all K–12 teachers of science upon their initial assignments to classrooms, labs, or storerooms where hazardous chemicals are present and prior to assignments involving new exposure situations.
  • In addition, training should occur annually so teachers can review, discuss, and update the safety program, share experiences and better professional practices, and receive legal updates and other information related to science instruction and safety.
• All science teachers should have the opportunity to participate in the design and implementation of safety training programs that meet the goals outlined in the school district’s overall safety program, including the Chemical Hygiene Plan.
• Safety training programs should cover the legal duty or standard of care owed by teachers to students (NSTA 2007b) and include state safety regulations and all school board policies applicable to the science classroom.
• Safety training programs should include ways to reduce the potential risk of injury from exposure to bloodborne pathogens and other potentially infectious materials (OPIM) (OSHA 1992).
• Safety training should include strategies for accommodating students with academic, remedial, or physical needs and English Language Learners.
• Safety training programs should help teachers learn how to understand and apply the contents of SDS or other guidelines in preparation for hazardous chemical use.

Safer Actions for Educators

Knowing that there is a legal requirement for relevant safety training in K12 schools and across school districts in the USA, according to Dr. Ken Roy, there are some actions that can be taken to increase the level of ‘safety awareness’ about appropriate (grade and age as well as subject-specific) safety training. 

The following is a brief list of action items that should be shared with employers to protect teachers and students in the academic science laboratory. The list is based on both legal standards and better professional safety practices. It is a starting point for improved biological, chemical and physical hazards notification/awareness, understanding, action, and protection. The comprehensive list includes the following:

Chemical Hazards (toxins, corrosives, flammables, and reactives):

1. Require an active inventory of all hazardous substances used in the lab and directly accessible SDS for each one.
2. Require a hazard communication program addressing the use of SDSs, proper labeling, storage, use, disposal, and employee training.
3. Require labeling on all containers for hazardous substances with pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification. Hazardous substances transferred to another container must have a limited amount of information when used more than one shift or out of the originator’s possession during the shift.

• This label must contain two key pieces of information: the identity of the hazardous chemical(s) in the container (e.g., chemical name) and the hazards present. It is a responsible practice to have the GHS-compliant label on the container (vessel) at all times.

       4. Require employee training on hazardous substances, including:

• • Explanation of SDS – what it is and how to use it.
  • Employee’s “right to understand!”
  • Location of biological, chemical, and physical health hazards in specific work areas and protective measures to be used.
  • Details of communication program, including labeling system, inventory system, and SDSs.
  • Access and review of a communication program for hazardous substances.

Biological Hazards (microbes, animals, plants, and genetically modified agents):

1. Require a written exposure control plan for occupational exposure to bloodborne pathogens and other potentially infectious materials (OPIMs).
2. Require employee training for Biological hazards resulting from Bloodborne pathogens, including:

• • Access and review of the plan.
  • Explanation of epidemiology and symptoms of Bloodborne diseases.
  • Explanation of the modes of transmission of Bloodborne Pathogens.
  • Explanation of appropriate methods for recognizing tasks and the other activities that may involve exposure to blood and OPIMs.
  • Explanation of use and limitations of methods that will prevent or reduce exposure, including engineering controls, standard operating procedures, and Personal Protective Equipment or PPE.
  • Information on types, proper use, location, removal, handling, decontamination, and disposal of PPE.
  • How to select appropriate PPE.
  • Specific information on Hepatitis B and vaccines is available.
  • Information and protocol to follow in case of an emergency involving blood or OPIMs.
  • Protocol to follow for an exposure incident.
  • Explanation of signs, labels, and color-coding.
  • How to obtain information on types, selection, proper use, location, removal handling, decontamination, and disposal of PPE.
  • Who to contact during an emergency.
  • Awareness of biological hazards in working with microbes, animals, plants, and genetically modified agents.

Physical Hazards (heating devices, noise, projectiles, fire, cold, electrical, etc.):

1. Require employee training for physical hazards.
2. Appropriate use of personal protective equipment.
3. Awareness of electrical hazards – fire and shock.
4. Awareness of compressed gases – explosion, projectiles, flammables.
5. Awareness of mechanical hazards – moving machinery, projectiles, springs.
6. Awareness of radiation hazards – ionizing and non-ionizing radiation.
7. Awareness of working with thermal hazards (heat sources).
8. Appropriate machine guarding on power tools.

The noted suggestion list is a start to help raise the level of awareness and understanding on the part of both the employer and the employee relative to working with biological, chemical, and physical hazards in the academic laboratory. Science education is meant to be fun and engaging– but also safer by having a well-informed school administrator, science faculty, and student body. 

Additional Considerations For Safety Training

As a reminder, school districts, as employers, have the legal responsibility to conduct districtwide science safety training for all K–12 teachers of science upon their initial assignments to classrooms, labs, or storerooms where hazardous chemicals are present and prior to assignments involving new exposure situations. In addition, progressive training should occur annually so teachers can review, discuss, and update the safety program, share experiences and better professional practices, and receive legal updates and other information related to science / STEM instruction and safety.

So there is the answer to the frequency of safety training. ANNUAL safety training is the safer choice and the most practical for teachers, CHOs, school building administrators, and other staff members. By having a current, compliant, cost-effective, consistent, and comprehensive safety training and risk management system in place, you can reduce the risks and provide a safer and multi-dimensional hands-on experience for your students. This safer learning environment will provide a platform for students to explore the world around them and select a future trajectory based on the innate curiosity found within them, rooted in these safer learning experiences originating in the science laboratory. 

Remember that there is no ‘fine line’ between safe and unsafe, therefore having appropriate, relevant, annual (ongoing) safety training is a necessary component of your instructional program from a legal and professional perspective for school principals, department heads, teachers, and all other stakeholders in the educational ecosystem.  

Summary Thoughts on Current Safety Training  Practices

One of the most interesting key findings from the 2021 Dr. Roy and Dr. Love study on safety in schools was that ‘There was an identifiable lack of safety training, as only 54% of participants reported receiving such training during undergraduate technical and teaching methods courses. This not only puts students at a higher risk of an accident but also does so for the teacher! Teacher preparation programs and mentor teachers should ensure safety is a core focus for all preservice teachers.

There was also an identifiable lack of safety training provided by school districts.

The Occupational Safety and Health Administration (OSHA) requires employers (school districts) to train employees (teachers) upon initial hiring, anytime thereafter when a new hazard is present (e.g., new equipment, new chemical, etc.), and when there is a new job assignment in the workplace (STEM or CTE lab).

Further research featuring statistical analyses from the data in this study revealed that a lack of safety training, along with other factors, was significantly associated with increased accident rates. 

This is a preventable statistic with the proper grade and discipline-specific safety training provided at least annually to educators in science, STEM, and CTE programs.

Ensure that your risk management program includes ANNUAL safety training for your schools’ science, STEM, and CTE teachers. You have a responsibility under your’ duty of care obligations to provide safer learning and teaching environments and regulatory and legal obligations under OSHA, NFPA, and other professional standards to do the same. It is a priority to reduce liability through hazard and risk mitigation in schools, and proper safety training and awareness is the best method to achieve this objective.       

James Palcik, OCT, Former Director of Education, Safety & Compliance
‘Safety First. Accidents Last.’