Series: Laboratory Safety What School Administrators Need to Know.

Laboratory Safety What School Administrators Need to Know – What School Administrators Need to Know about Science Safety

White microscope on top of black table
Science and Lab SafetyK-12Hidden

Lab Safety What School Administrators Need to Know

by Science Safety & Dr. Kenneth Roy
written by Science Safety & Dr. Kenneth Roy 8 minutes read
This entry is part 1 of 2 in the series Laboratory Safety What School Administrators Need to Know.

In 1990, Federal OSHA’s “Occupational Exposure to Hazardous Chemicals in Laboratories” came into effect. The “Laboratory Standard” (29 CFR 1910.1450) comprehensive Lab Safety standard outlines the responsibilities of employers, particularly educational institutions and school districts, in assessing potential laboratory safety hazards resulting in health and safety risks and the creation of a customized “chemical hygiene plans” to address appropriate safety actions for safer employee workspaces.  A pivotal component of the Lab Safety Standard (29 CFR 1910.1450) is the requirement for a designated chemical hygiene officer responsible for assisting in the development and execution of the chemical hygiene plan.

Based on legal safety standards and OSHA’s guidelines, a chemical hygiene plan is the cornerstone of school districts’ laboratory safety practices. 

As the administrator/supervisor on-site representing the employer, you are responsible for this regulation and its components regardless of your experience, understanding, or awareness of this legal safety standard. 

For those that don’t know: Compliance with OSHA’s Laboratory or Lab Safety Standard is essential and a legal requirement for those employers under OSHA jurisdiction.

Laboratories have a legal mandate to have a chemical hygiene plan that addresses all aspects of hazardous chemical handling, from procurement and labeling to usage, storage, and disposal; as a component of lab safety. Proper lab safety training and information dissemination for laboratory employees is integral to an effective chemical hygiene plan, ensuring adherence to OSHA’s Hazard Communication Standard. It should be noted that federal, state and OSHA equivalent lab safety standards apply based on the type of school (Public, private, charter, independent) and jurisdiction. The takeaway is that there are legal safety standards and accepted better professional safety practices that apply involving the Laboratory Standard’s for lab safety requirements in ALL schools nationally.

Who’s Covered Under OSHA Laboratory Safety Guidance 

It is also important to note that OSHA primarily covers employees, not students, within the work site. Nevertheless, strict adherence to the chemical hygiene plan and approved standard operating plans is vital to maintain a safer environment for science teachers and all instructional space (laboratory) occupants, including students. An adherence to safeguards for administrators/supervisors and teachers as employees prevent or reduces potential risks resulting from possible liability.

Furthermore, other OSHA standards, official interpretations of these standards, and national consensus standards may also apply to high school science instructional spaces (e.g., laboratories and classrooms) and related spaces (preparation rooms and storerooms). Additional standards include General Duty Clause, Occupational Noise Exposure Standard, Personal Protective Equipment Standards, and other regulations. Many of the aforementioned standards can be found on OSHA’s website, providing further guidance for ensuring safety within science instructional spaces. 

A listing of relevant safety standards and regulations that should exist inside each school science department are below.  Remember that you are legally responsible and accountable for these aspects of safety in the science department as the building administrator and supervisor of the school.

Pertinent OSHA-Related Standards for Lab Safety:

  1. Section 5. (a)(1) of the OSH Act, commonly called the General Duty Clause, mandates employers to provide employees with a workplace and employment devoid of recognized hazards that could lead to death or serious physical harm.
  2. Section 5. (a)(2) necessitates employers to adhere to occupational safety and health standards established under this Act.
  3. Occupational Noise Exposure Standard (29 CFR 1910.95) focuses on acceptable sound/noise levels within work environments.
  4. Personal Protective Equipment Standards (29 CFR 1910.132) pertain to protective gear for the body, including safety goggles, safety glasses, aprons, and gloves.
  5. Respiratory Protection Standard (29 CFR 1910.134) pertains to protective devices designed to shield occupants from respiratory-related exposures.
  6. Lockout/Tagout Standard (29 CFR 1910.147 and 1910.333) addresses the control of hazardous and uncontrolled energy sources, encompassing gas, water, electrical, and mechanical systems.
  7. Toxic and Hazardous Substances, 29 CFR 1910 Subpart Z: a. 1910.1000, Air Contaminants b. Table Z-1, Limits for Air Contaminants
  8. Hazard Communication Standard (29 CFR 1910.1200) focuses on managing potentially hazardous chemicals in the workplace.
  9. Bloodborne Pathogen Standard (29 CFR 1910.1030) addresses blood-related pathogens such as HIV and HbV.
  10. Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450) provides guidelines for the safer use of chemicals in laboratory settings.
  • Appendix A: Recommendations from the National Research Council regarding chemical hygiene in laboratories (Non-mandatory)
  • Appendix B: References (Non-mandatory)

Interpretations of Legal Safety Standards:

Standard interpretations are official responses to inquiries about OSHA safety standards. Many of these interpretations pertain to laboratory standards and can be accessed on OSHA’s official website.

National Consensus:

National consensus practices are not OSHA regulations or standards but represent better professional safety practices, offering guidance from originating organizations, e.g., NFPA, EPA, ANSI/ISEA, NSTA, etc. OSHA compliance officers often reference these practices when addressing safety concerns.

Key Professional Organizations and Their Enforceable Lab Safety Standards:

  • American National Standards Institute (ANSI): ISEA International Safety Equipment Association
    • Standard Z358.1-2014 encompasses provisions for designing, performing, installing, using, and maintaining various emergency equipment, including showers, eyewashes, and drench hoses. General considerations also apply to emergency equipment.
    • Eye and Face protection (ANSI/ISEA Z87.1-2020), the American National Standard for Occupational and Educational Personal Eye and Face Protection Devices, is the latest edition of the standard for eye and face protection. – Safety glasses with side shields are to be used when dealing with solids (e.g., projectiles and glassware).  – Indirectly vented chemical splash goggles are to be used when dealing with hazardous liquids (e.g., acids, bases, alcohols).  *Approved certified chemical splash goggles can also be used in lieu of safety glasses with solids.
  • Foot Protection (ANSI Z41.1-1991 and Z41.1-1999) The American National Standards Institute’s Z41 Committee on Personal Protection-Protective Footwear has merged into ASTM International’s Committee F13. With this merger, F13 oversees the redrafting of ANSI Z41 performance requirements and test method standards for safety footwear.
  • Hand Protection (ANSI/ISEA 105-2016) The American National Standard for Hand Protection rates gloves and other cut protective clothing on a consistent numeric rating scheme for mechanical, thermal, chemical, dexterity, and other performance criteria. Therefore, the availability of appropriate gloves of various sizes should be made based on the chemicals encountered (vinyl, nitrile, heat-resistant, etc.).
  • American National Standards Institute (ANSI) / American Industrial Hygiene Association (AIHA):
    • Standard Z9.5-2003, Laboratory Ventilation, serves employers, architects, occupational and environmental health and safety professionals, and others concerned with airborne contaminant control. It covers performance tests, air cleaning, preventative maintenance, and work practices. The standard highlights requirements and good laboratory practices, along with references and guidance on selecting ventilation designs.
  • American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE):
    • Standard 110-1995 outlines a quantitative test procedure for evaluating laboratory fume hood performance. It involves releasing tracer gas at specified rates and positions, then monitoring exposure in the breathing zone. A performance rating is based on tracer gas release and average exposure.
  • International Code Council (ICC):
    • The 2003 International Codes include standards relevant to laboratories, particularly the International Fire Code. This code addresses fire department access, fire safety systems, hazardous materials storage, and fire-safety requirements for new and existing buildings.
  • National Fire Protection Association (NFPA):
    • NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals, is applicable to laboratories handling or storing hazardous chemicals.
    • NFPA 101, Life Safety Code is applicable for many aspects in the science department including occupancy loads, fire extinguishers, fire safety equipment among others.

References

  • International Code Council (ICC). 2012. IBC: 1004.1.1 Areas without fixed seating: Table 1004.1.1 Maximum Floor Area Allowances Per Occupant.
  • Motz, L. L., J. T. Biehle, and S. S. West. 2007. NSTA guide to planning school science facilities, Second Edition. Arlington, VA: NSTA Press.
  • 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) Safety Advisory Board. 2013. Safety in the Science Classroom, Laboratory, or Field Sites.
  • National Science Teachers Association (NSTA) Safety Advisory Board. 2014a. NSTA-Duty or Standard of Care.
  • National Science Teachers Association (NSTA) Safety Advisory Board. 2014b. Overcrowding in the Instructional Space.
  • National Science Teachers Association (NSTA). 2007a. NSTA Position Statement: Liability of Science Educators for Laboratory Safety.
  • National Science Teachers Association (NSTA). 2014a. Duty of Care.
  • National Science Teachers Association (NSTA). 2014b. Overcrowding in the Instructional Space.
  • National Science Teachers Association (NSTA). 2015a. NSTA Position Statement: Safety and School Science Instruction.
  • National Science Teachers Association (NSTA). 2015b. Managing Your Chemical Inventory; Parts 1, 2, and 3.
  • NGSS Lead States. 2013. Next Generation Science Standards: For states, by states. Washington, DC: National Academies Press.
  • Occupational Safety & Health Administration (OSHA). 1987. 29 CFR 1910.1200 Hazard Communication Standard (Right to Know Law).
  • Occupational Safety and Health Administration (OSHA). 1990. 29 CFR 1910.1450. The Laboratory Standard, Part Q (Chemical Hygiene Law).
  • Roy, K. 2006. Proactive safety. Science Scope 30 (1): 72, 74.
  • West, S. and L. Kennedy. 2014. Science Safety in Secondary Texas Schools: A Longitudinal Study.
  • West, S., and L. Kennedy. 2014. Safety in Texas Secondary Science Classrooms. Texas Academy of Science (58).
  • Connecticut-High-School-Science-Safety/OSHA-Laboratory-Standard
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Chemistry glassware, flasks and a microscope on a lab bench in front of a dark chalkboard covered in hand-drawn chemical formulas and molecule diagrams, soft si
K-12HiddenScience and Lab Safety

Lab Safety Requirements and School Administrators

by Science Safety & Dr. Kenneth Roy
written by Science Safety & Dr. Kenneth Roy 6 minutes read
This entry is part 2 of 2 in the series Laboratory Safety What School Administrators Need to Know.

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
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