STEM Lab Inspections and Legal Requirements

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12Importance of STEM Lab Inspections

Many school districts know it is a legal requirement to regularly provide STEM lab inspections. A key part of this inspection is the chemical hygiene officer. A designated Chemical Hygiene Officer (CHO) is a legal obligation for school districts. It is the person who can best conduct your REQUIRED annual safety inspections in your school laboratories.

If you do not have a named, officially designated chemical hygiene officer in your school district, let me introduce you to the Superintendent, who by default is the CHO regardless of their experience, education, or background with responsible chemicals hygiene management.

Legal Liability

It is clear from OSHA under CFR 29 1910.1450 and an often-overlooked legal aspect until an accident or an injury in the laboratory. The school district’s lack of expertise surrounding these occupational safety and health requirements is evident.

Each laboratory, associated prep room, and chemical storeroom MUST be physically inspected annually, looking at plenty of criteria that will be documented for submission to OSHA or an equivalent regulatory authority.

Know the Criteria

The reality is that no consistent inspection reporting form is used. As a result, most chemical hygiene plans have a limited albeit basic inspection checklist at best. Let me begin with some questions that need answers to better understand your specific situation in your schools.

Do you have a designated Chemical Hygiene Officer in your school district?
Who is it? Do they have the necessary skills, training, and awareness for this role?
How long have they been in this position?
When was the last physical safety inspection conducted in the schools?
Where are these documented inspection forms? Are detailed images included with the reports?
Have you seen these prior annual inspection forms?
Do you know specifically what to look for during the inspection? And why?
Could you identify any potentially unsafe situations?
Do you have the necessary training and experience to conduct this annual physical safety inspection?
How comfortable are you with your current laboratory inspection templates?

These are all good questions to ask yourself and the leadership team at the district level and, as mentioned, require a response. Trust me when I say that you really should listen to the voice in your head that says, ‘I think we need some help’ or ‘It’s time for some comprehensive safety training’ since there is a tremendous amount of legal liability involved with having chemicals in schools.

Remember that conducting comprehensive annual safety inspections is only one component of your school district’s overall chemical safety program.

What to look for during an inspection?

Knowing that you must perform a safety inspection is a good first step in the process, but more important is knowing exactly what to look for and why. It is not useful to conduct a safety inspection using a spreadsheet or a checklist and not know why you are looking at different aspects of your safety infrastructure systems in the school science department. Some items may appear to be working properly at a distance, but when tested, you determine that there is insufficient water flow in the eye wash station or an inadequate charge in the fire extinguisher.

Many safety criteria can be classified as ‘common sense’ and may be apparent to certain inspectors but not others. Looking at some common laboratory safety inspection criteria, we notice commonalities used by inspectors from Maine to Montana and from Seattle to Sarasota.

Involving the Chemical Hygiene Officer

It is important to know that most laboratory inspections are conducted as a team, including the Chemical Hygiene Officer (also known as the Environmental Hygiene Officer in non-OSHA states), the school principal or building administrator, and the science department chair or lead chemistry teacher.

There need to be at least two people to complete the safety inspection and document the observations. Ideally, these people have the experience and education combined with specific CHO or lab inspection safety training to conduct these annual inspections appropriately.

If they do not, online services are available to provide the necessary chemical safety awareness training from trusted and reliable sources such as Science Safety and others. A typical secondary school annual safety inspection that is very comprehensive requires about 4 hours to complete.

Some available examples of laboratory inspection checklists that schools may find beneficial for Science and STEM labs can be found on the National Institute for Occupational Safety and Health (NIOSH) website. There are some key areas to focus on while moving through the science department, and we will explore some of these safety criteria in more detail here:

STEM Laboratory Inspection Key #1: Neatness and Clutter

An organized laboratory that is neat, clean, and uncluttered laboratory is a very important and legal requirement. Access to safety items such as fire extinguishers and eyewash stations must be unobstructed – that means nothing can be in the way of getting to these critical safety infrastructure items.

Obstructions are one of the first things an OSHA compliance officer will look for when performing a walk-through of your laboratory. A well-organized science department is a positive indicator of a safety culture.

Safety Signage

There should also be plenty of safety signage that identifies where specific safety items are located in the laboratory in case of emergency. It is a legal and professional safety housekeeping practice to maintain the lab bench tops, counters, and work surfaces free of debris, laboratory equipment, and apparatus and ensures that no chemicals remain in the room overnight.

These are key parts of the overall safety culture in your school and professional safety and housekeeping practices. The same applies in the chemical storeroom and the prep area – keep these zones clean, uncluttered, and organized, as this sets the tone for the whole department. Any slip, trip, or fall hazards are serious problems and must be remedied immediately, as this is a leading cause of accidental injury in laboratory environments.

STEM Laboratory Inspection Key #2: Fire Safety

Fire safety is a very important part of the overall program, and having key items as part of the fire safety plan. It includes items such as fire extinguishers, a fire blanket (used in some jurisdictions and not others), buckets of sand, a Class D fire extinguisher if reactive metals are on-site, and emergency fire exit procedures posted near the door are the core of this program.

There are very specific criteria for each part of this fire safety plan, including having the ABC dry powder type extinguisher mounted on the wall and not on the floor, having a service tag checked monthly, and the gauge indicating that it is in the 100% charged position.

Collaboration With Fire Marshalls

As a reminder, the local Fire Marshall and the regulations specific to your school supersede the NFPA 101 Life Safety and OSHA regulatory documents. The chemical hygiene plan will identify your school’s fire safety plan, what to do in an emergency involving fires, and how to respond immediately as the responsible person in the room under your Duty of Care obligations.

Ideally, using risk mitigation strategies such as a hazard analysis before any activity in the laboratory will assist in preventing potentially dangerous situations arising from fires or associated concerns from using flammables.

STEM Laboratory Inspection Key #3: Eye Safety

A fully functional plumbed eyewash station that is ANSI/ISEA approved and allowed for 15 minutes of hands-free operation of tepid water is required for chemistry laboratories and any laboratory that uses chemicals. (ANSI/ISEA Eyewash Z358.1-2014 ) The eyewash station must be accessible, and no obstructions are permitted that would impede someone from reaching and using the eyewash station.

It should be noted that the portable hand-held saline water filled 1 liter sized bottles are not acceptable as an ‘eyewash station’ but can be used to flush the eye while getting to the plumbed-in version. Some schools have a very prominent independent eyewash station, and some use a faucet-mounted version of an eyewash that can be turned on with the push of a button into a functional emergency eyewash when needed.

Meeting OSHA Requirements

Provided this is a certified or approved version, it will meet the OSHA lab inspection requirements. When looking at the eyewash station, if there is some scale formed on the eye cap or nozzles, you can have these cleaned with TSP or CLR and rinsed well before testing. The eyewash must be run for five minutes weekly to remove any stale or stagnant water. It must operate independently to allow the user to hold their eyelids open and have their eyes flushed for at least 15 minutes at room temperature (tepid) clean water.

STEM Laboratory Inspection Key #4: PPE

Looking at the personal protective equipment evaluation criteria used in the laboratories, most of these observations are based on using common sense criteria when making your evaluations. Understand that there are differences between safety glasses and goggles used in very different situations.

For any laboratory using heat, glassware, liquids, or chemicals, you must only use approved ANSI/ISEA Z87.1 D3 indirectly vented chemical splash goggles for every person in the room. For physical science or laboratories not using liquids, heat, glassware, or chemicals where safety glasses are allowed, these must be ANSI/ISEA-approved impact safety glasses with side shields.

Ensuring Preventable Hazards

Recent studies indicated that not all schools are following this mandate. A snapshot indicated that 84% of schools had adequate safety glasses (still not 100%) and that only 50% of schools had certified chemical splash safety goggles – a preventable hazard.

A goggle sanitation plan for cleaning and disinfecting goggles after use is important in today’s climate. Additional safety protective items to look for include rubberized lab aprons or lab coats and protective gloves such as nitrile or vinyl, depending on the intended usage. The last factor to consider in this area is that the PPE must be available in sizes that accommodate the different sizes and shapes in the laboratory.

Having all medium-sized lab coats would not be appropriate, seeing that there are people larger and smaller than a size medium. Never substitute a cheaper non-certified version of protective gear due to the price difference, as the legal liability from using known these will result in a significant lawsuit based on negligence and potential recklessness. Always use PREMIUM, CERTIFIED, FITTED APPROPRIATE PPE. If you have any liability questions, read that last sentence again.

STEM Laboratory Inspection Key #5: Engineering Controls

Certain safety mechanisms and infrastructure are in place, referred to as ‘engineering controls,’ which refer to anything that is built into the science department designed to separate people from biological, chemical, or physical hazards. These include the master control switches and valves, the emergency drench shower, the fume hood and ventilation systems, and the eyewash described above.

The master shut-off control system is often found at the front of the room or the lab instructor’s desk, with variations that have a key and lock system or as simple as a valve for turning on the laboratory’s water and natural gas systems. These controls must be working properly for a multitude of safety reasons. The fume hood is designed to remove odors from chemical reactions and prevent these vapors or smells from entering the laboratory environment. It must have a face velocity draw of at least 80-100 cubic feet per minute (CFM) to be considered ‘functional.’

Proper Facility Management

There are specialized companies that can inspect the HVAC systems in the laboratory, including the fume hoods, to ensure that there is 100% fresh air being introduced to the labs with no recirculation and that these systems are functioning as designed. These engineering controls are in place to reduce potential exposures and to remediate any emergency that may arise in the laboratory or STEAM department which can be anticipated. Typically the facilities or maintenance personnel in the school are responsible for the safer operation of these control measures.

VERY IMPORTANTLY, if you discover that these safety controls are not working properly or are damaged, you CANNOT conduct any lab activity involving chemicals or other hazards until this has been resolved. If the eyewash station is not working, you cannot use chemicals in that room until it has been repaired and is fully functional if needed in an emergency.

STEM Laboratory Inspection Key #6: Chemical Storage

A current chemical inventory is exceptionally important, and a critical component of the laboratory safety inspection, and so is having that inventory stored appropriately. Chemicals must be stored in segregated chemical safety cabinets that isolate them according to their ‘family,’ such as acids, bases, flammables, toxins, oxidizers, and even more specific storage requirements.

Understand that you cannot store all your acids in a designated acid cabinet, despite being acids. For example, you must isolate nitric acid from ALL acids. Storing incompatible chemicals together is one of the main observations you should make when inspecting the chemical storage facility.

Organization is Key

Keeping your chemicals stored in an organized manner that provides separation between incompatible chemicals and facilitates locating chemicals for use in student experiments is very important. When looking at the chemical storage cabinets, if there is a fine white residue on the bottles and the shelves, this indicates that an acid and a base are reacting, creating salt and water as the product.

Odors are also very good telltale indicators to alert you to incompatible chemical storage practices. There are thousands of chemical storage guidance resources available to research, and as always, refer to the specific chemical storage standard operating procedures found in your chemical hygiene plan. Many safety criteria are involved in inspecting a chemical storage area, and having a solid chemical understanding and experience will greatly facilitate your laboratory inspection.

Complying With Your School’s Plan

Certain school districts have adopted a ‘banned’ listing of chemicals that identifies products that should not be found in the school due to their specific risks. It is important to know what you are looking for when inspecting the chemicals on hand since they can become more or less reactive over time and pose certain risks to those nearby. A solid understanding of responsible chemical management and an accurate inventory is critically important to your safety and compliance in the school.

STEM Laboratory Inspection Key #7: Labels and SDS

In the chemical storeroom, each chemical bottle should have a legible, GHS-compliant label and an associated Safety Data Sheet (SDS) for every chemical in the inventory. No exceptions are allowed and having on the stock bottles of diluted hydrochloric acid, diluted sodium carbonate, or sodium hydroxide used in grades 9-12 is also required.

It must be properly labeled if there is a chemical in your inventory, regardless of the molarity, concentration, volume, and the vessel (bottle) used. This can include a workplace label for those chemicals decanted and those in Erlenmeyer flasks. Having a printed SDS for each chemical is a better professional safety practice. It should be encouraged despite having online access to a library or database of these chemicals in your inventory.

Keeping Proper Documentation

As a reminder, for those older MSDS (material safety data sheets) which existed until 2015, the school is required to keep a copy of those records for 30 years – which means that the chemical records going back to 1993 are legally mandated to be available should an employee develop a chronic health condition and need to validate that they have had or potentially have had exposure to a particular chemical found on-site in the school during the past 30 years.

The OSHA Hazard Communication Standard 1910.1200 applies to maintaining a current inventory and chemical labels to identify potential or known hazardous substances for employees and being a better professional safety practice. Another reminder is to ensure that no chemicals are stored in food-grade jars or bottles in the chemical storeroom or safety storage cabinets. Only use approved, appropriate chemical storage bottles designed for storing chemicals.

Lab Inspection Recap

Conducting a laboratory inspection is an annual requirement for OSHA compliance. It should be completed by at least two members (ideally one being the CHO) of the school science safety team with experience and understanding of the multiple occupational health and safety aspects of responsible chemical hygiene and management practices.

Knowing what to look for and identifying any areas of concern found throughout the laboratories, prep rooms, and chemical storerooms are the main reasons these annual snapshots of the science department are conducted.

Utilizing Comprehensive Templates

It makes sense to use a comprehensive template for safety inspections that allows for images and anecdotal notes to be taken and used to complete the inspection report, as well as connections to the multiple health and safety regulations for the various safety items found in the science department for consistency and compliance with OSHA (or equivalent) submissions.

It typically requires a half day to complete a science department physical safety inspection properly and then some time afterward to create the reporting documents by the inspectors that identify any deficiencies and areas of concern.

Remember that conducting these annual inspections is required and must occur to prevent a non-compliance sanction or fine against the school or school district.

Utilize A Checklist

In the words of Dr. Ken Roy, initiate a laboratory safety inspection by reviewing and answering questions on the checklist as they apply to your laboratory. This will provide an assessment and direction as to where work needs to be done for a safer teaching/learning environment. Be sure to share the results of the physical safety inspection with the administration to ensure all safety issues are addressed.

If safety issues exist that make teaching/learning activities unsafe resulting from exposure to potential hazards and resulting risks, lab activities and/or demonstrations must be temporarily stopped. If not, and someone gets hurt, both the teacher and the administration have potentially serious legal liability.

References

Science Safety

Science Safety provides a comprehensive digital STEAM, CTE, and Lab Safety Platform for K12 Schools and School Systems. Empowering education schools and school systems with the knowledge and tools necessary to integrate safety seamlessly into STEAM, CTE, and Lab curriculum and ensure a safer and more compliant learning environment for all students.
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