Hernando County Schools
Chemical Hygiene Plan
for School Laboratories
Public and private schools over the past few years have had to comply with various Hazard Communication or "Right to Know" laws. These laws were written for industrial production facilities, and did not address the specific safety concerns found in a laboratory setting. In 1990, the Occupational Safety and Health Administration (OSHA) instituted "The Laboratory Standard"-Occupational Exposure to Hazardous Chemicals in Laboratories. This new "Laboratory Standard" has been designed to address the specific safety needs of the laboratory.
The Laboratory Standard ensures that employees who work in a laboratory setting will be protected from any chemical exposure that exceeds permissible exposure limits and that employees will be educated in the hazardous nature of the chemicals they use in the laboratory. To achieve this goal, the Laboratory Standard requires the school district to develop, implement, and monitor a chemical hygiene plan.
School District Responsibilities
The school board and the school district superintendent have ultimate responsibility to ensure the institution complies with the Laboratory Standard. Several of these tasks are:
1. Record all employee exposures to hazardous chemicals.
2. Train employees to:
3. Provide access to all employees:
E. Permissible exposure limits of hazardous chemicals used in the laboratory. (Consult your Flinn Chemical Catalog/Reference Manual)
4. Upon receipt of chemical:
A. Make sure you have the MSDS (make them accessible to the employee).
B. Make sure the label is proper and contains the minimum amount of information.
1) Chemical name.
2) Hazard information.
3) Name and address of the manufacturer.
* Note: You must follow these steps for all chemicals and chemical solutions made and stored in your laboratory or chemical storeroom.
The Chemical Hygiene Plan--An Overview
The Chemical Hygiene Plan is the major ingredient of the Laboratory Standard. Your school district should develop and carry out a written Chemical Hygiene Plan which is capable of:
Chemical Catalog/Reference Manual for specific chemical permissible exposure limits.)
The Chemical Hygiene Plan must be readily available to employees. The school district shall review and evaluate the effectiveness of the Chemical Hygiene Plan at least annually and update it as necessary. The Chemical Hygiene Plan should include each of the following elements and should include specific measures the employer will take to ensure laboratory employee protection.
Before you adopt any Chemical Hygiene Plan, first consult your state regulating agency. Modifications or alterations may have to be made to have your Chemical Hygiene Plan conform to your state's specific regulations.
CHEMICAL HYGIENE PLAN
I. Standard Operating Procedures
II. Employee Training.
III. Exposure Evaluations.
IV. Medical Evaluations.
VI. Emergency Evacuation Plan.
Hernando County Schools
Chemical Hygiene Plan
I. Standard Operating Procedures
A) General Employee Rules and Procedures
B) General Laboratory Rules and Procedures
Your first aid policy must be written down.
8 air changes per hour). Air for laboratory ventilation shall directly flow into the laboratory from non-laboratory areas and out to the exterior of the building. Ventilation must be checked a minimum of every 3 months.
D) Protective Clothing Requirements
E) Housekeeping Rules
F) Spill and Accident Procedures
G) Chemical Storage Rules and Procedures
and expensive styrofoam cubes).
Storage Requirement--Compressed Gas Handling Instructions
Storage Requirements-Flammable Chemicals Handling Instructions
Storage Requirement--Corrosive Materials Handling Instructions
H) Procedure Specific Safety Rules and Guidelines (for extremely hazardous chemicals)
I) Prior Approval Procedures
There may be some procedures which require prior approval before an instructor attempts to perform them. These procedures must be determined by cooperation and communication between the Science Department and the Chemical Hygiene Officer.
J) Safety Equipment Inspection
There are many safety items necessary for compliance to the Laboratory Standard. They include but are not limited to:
One of the most important sections of the Laboratory Standard states that all safety equipment in the facility must always be in good operating condition. While the Laboratory Standard requires some safety equipment and highly recommends other equipment, the standard is very clear on the point that if you have a piece of safety equipment, it must be functional at all times. This statement applies to all safety equipment, required or recommended.
All of the above items and all safety equipment must be inspected every three months at the minimum. Any safety equipment failing this quarterly inspection or reported to be out of order at any time must be repaired immediately. Any safety equipment found to be out of order is a serious violation of the Laboratory Standard.
II. Employee Training
The Hernando County School Board provides ongoing training sessions for our employees. Our training includes:
III. Exposure Evaluation
It is the communicated policy of the Hernando County School Board to investigate all suspected overexposures to chemicals in a prompt and timely fashion.
In the event of an overexposure, after the immediate event, we must document all chemicals and circumstances involved in the overexposure. This information should be used to change safety practices to further improve lab safety. It is our obligation to maintain these files and make them accessible to the employees.
Signs of overexposure are numerous. They include:
If monitoring of the air is determined to be necessary, the results of the monitoring must be made available to the employees within 2 weeks.
IV. Medical Evaluations
It is the policy of the Hernando County School Board to make medical consultation and examination available to our employees when:
We will provide the physician with the names of the chemicals used, circumstances of the exposure and all signs and symptoms of the exposure.
The medical examinations dealing with the overexposure must be documented and other employees working under the same conditions must be notified. All documentation must be kept on file and accessible by other employees working in this area.
All medical examinations and consultations shall be performed by or under the direct supervision of a licensed physician and shall be provided without cost to the employee and without loss of pay.
Monitoring will be necessary for substances regulated by a standard only if there is reason to believe that exposure levels for that substance routinely exceed the PEL for that substance. If you have no cause to suspect a hazard or an exposure, no monitoring is necessary.
If monitoring is performed and this initial monitoring shows no evidence of exposure, the monitoring may be discontinued. If initial monitoring indicates an exposure, steps must be taken immediately to reduce the exposure to permissible limits. Monitoring must then be performed periodically to verify the steps to reduce the exposure have been effective. Monitoring may be terminated after complying with the applicable
standard for the hazardous material.
All monitoring results and activities shall be fully accessible and in full knowledge of the employee(s).
VI. Emergency Evacuation Plan
Establish a chain of communication. John tells Sally, Sally tells Bill, Bill notifies the office, the office notifies the fire department, etc. Remember, notify before proceeding to handle the incident. It is often better to notify someone else than to proceed in addressing the problem at hand by yourself. Evacuation may or may not be necessary depending on the incident. Once it has been determined evacuation is necessary, proceed in an orderly fashion as you would in a fire drill evacuation. Send everyone to a predesignated area and then count heads to make sure everyone is out of the building.
Proper evacuation procedures must be thoroughly planned, detailed in writing, and properly communicated in advance. In case of an emergency, you will not have time to determine "What do I do next?". This evacuation plan will be part of the Chemical Hygiene Plan.
(School Name) Emergency Evacuation Plan
SEVEN STEP PLAN TO CLEAN UP YOUR CHEMICAL STORAGE AREA
For years you have wanted to clean up and organize your chemical storage area, but it's such a huge job, where do you begin? Our seven step plan will give the direction and guidance you need to get this job done safely, quickly and efficiently.
Before beginning, some ground rules need to be established:
STEP 1: TAKE AN INVENTORY
The most important step in cleaning up a chemical storage area is taking an accurate and complete inventory of every chemical in each chemical storage area, laboratory and classroom. Without a complete inventory you will not be able to proceed to step #2. Don't forget to check closets and drawers.
Critical information will be needed from your inventory. Most particularly, you will want to know: 1) the name of the chemical, 2) its shelf location, 3) the approximate amount of chemical estimated to be in each container. The shelf location of each chemical is important because it's likely the same chemical will be found in several locations. Shelf location information will help you track down and consolidate these chemicals.
STEP 2: WHAT CHEMICALS DO YOU REALLY USE?
It is fair to say that 40% of the chemicals you have in your chemical storage area have not been used in the last five years and probably won't be used in the next five years. Now is the time to decide which chemicals are really used. Once the inventory is completed, review your laboratory manuals, textbooks, demonstrations and science fair projects and decide which chemicals you don't use.
As you review your inventory, you may discover an excessive amount of some chemicals. Calculate what quantities of these chemicals you use every year and then decide to keep no more than a two to five year supply. Determining how much chemical to keep will be influenced by two factors: the chemical shelf life and the hazardous nature of the chemical. The poorer the shelf life or the more hazardous the chemical the less you will want to keep on hand. If the chemical is not hazardous and has an indefinite shelf life, keep a four to five year supply. However, if the chemical is hazardous and the shelf life is poor, keep only a one year supply on hand. Look carefully at each bottle, try to determine which bottle looks the freshest or has the best shelf life and only keep the amount you really think you need.
STEP 3: ORGANIZING YOUR CHEMICAL STORAGE AREA
You now know which chemicals you use, which chemicals you want to keep, and which chemicals you would like to get rid of. Let's now physically move all of the chemicals in the chemical storage area out into the laboratory area onto the lab benches. (The laboratory next to the chemical storage area works best). The right side of the laboratory will become an area for those chemicals which you either no longer use, or have in excessive amounts and would like disposed.
The left side of the laboratory will be those chemicals you want to keep. It's important that only authorized people working on this project be allowed to enter this room. Administrators, maintenance people and others must not be allowed into this laboratory area unless they are accompanied by one of the teachers involved in the cleanup project. This laboratory should be locked when not in use.
There are certain chemicals found on school premises considered to be "devils". A "devil" is any chemical which has a severe hazard alert. Severely poisonous, severely toxic, severely flammable, severely corrosive, strong oxidizer, carcinogen, or strong stench are all characteristics which may qualify a chemical as a "devil". To practice "devil control" purchase some clear heavyweight baggies with twist ties, cat litter and a selection of clean empty quart and gallon paint cans. The first step in practicing "devil control" is to place each chemical container considered to be a "devil" into a clear baggie. Secure the baggie with a twist tie. Should the bottle break, the spill will be contained in the baggie.
Once the chemical bottle is in the baggie, spread a thin layer of cat litter in the bottom of a paint can, place the sealed baggie with the chemical container into the paint can and fill the remaining portion of the can with cat litter. Place the lid on the paint can and label the can clearly with the chemical name, chemical formula and hazard risk. Your "devil" chemical is now well protected! The metal paint can may be dropped, kicked, or even involved in a fire and the chemical container inside will not break. Should a leak occur, the cat litter will absorb the chemical and the spill will be contained inside the can. Devil chemicals can now be disposed of.
Most "devils" are not to be used in High School or Middle School Science Labs. You need to properly protect and then dispose of these chemicals. Bags and cans are a very effective, yet inexpensive way to protect these "devil" chemicals. If any devil chemicals are to be used in High School or Middle School Science Labs, you must receive the written, prior approval of the School District Safety Coordinator.
STEP 5: IMPROVE THE CHEMICAL STORAGE AREA FACILITY
Now that the chemicals have been moved out of the chemical storage area and into the laboratory, you have an opportunity to make some improvements to the chemical storage area. First of all, give the room a good cleaning. Make sure the shelves are firmly attached to the wall and are in good condition. If the shelves are not in good condition, some type of repair or replacement should be made. Check the shelf clips carefully to make sure they are in good condition and not corroded. Put "lips" on the shelves to prevent bottle roll off. Inspect the rest of the chemical storage area. Do any other improvements need to be made?
STEP 6: ORGANIZE CHEMICALS BY COMPATIBLE FAMILIES
Now that the "devil" chemicals have been bagged and canned, and the storage area has been improved, it's time to return the chemicals you want to keep back into the chemical storage area. Before these chemicals are moved back into the chemical storage area, you must decide how they are to be stored and organized. In the past, they may have been stored alphabetically. This is wrong! Chemicals should be stored and organized by compatible chemical families.
First, separate you chemicals into compatible families by dividing the chemicals into inorganic and organic families, then subdividing them further into their unique compatible chemicals families. For instance, oxidizers are broken into five different families. Nitrates are stored in Inorganic #3 except ammonium nitrate which is isolated. Chromates and permanganates are stored in Inorganic #8. Chlorates and perchlorates are stored in Inorganic #6, and nitric acid is stored separately in a dedicated acid cabinet.
Before the chemicals are moved back into the chemical storage area, it is very helpful to label each chemical bottle with the appropriate compatible chemical family storage number. It is also helpful to label each shelf with the compatible family number. Labeling both the chemical shelving and the chemical bottles with the appropriate Flinn compatible chemical family number will allow you to easily locate and return the chemicals to their appropriate storage location. Without this labeling, you'll soon find your chemical storage area in disarray.
STEP 7: CHEMICAL DISPOSAL--YOUR OPTIONS
Now that you chemicals have been properly bagged, canned, labeled and placed back into the chemical storage area using Flinn's Suggested Compatible Family Shelf Storage Patterns, your task is now complete...almost.
As you walk out of the chemical storage area feeling good about what you have accomplished, you soon realize you still have all of those chemicals that need to be disposed. What are your options for chemical disposal? Let's examine six chemical disposal options which have proven successful for many schools:
Contact your state department of education. Many states have a state science supervisor who may be able to make suggestions or offer advice about existing programs. We maintain a current list of state science administrative personnel. Write or telephone for the name and address of your state contact.
In many metropolitan areas, there are local sections of the American Chemical Society (ACS). Any area with a lot of chemical industry is likely to have a local ACS section. Contact these professionals. They may have some helpful insights.
Have you shared your list of excess chemicals with other schools in your system or other neighboring schools? Assuming some of the chemicals involved are still useful, perhaps another school can use what you consider excess. However, be a good neighbor. Don't pass your "junk chemicals" to someone else. Be responsible! Those excess chemicals are your problem. Don't pass your problem to someone else.
If your school is located near a college or university, that institution's chemistry department may be able to advise you about the disposal methods it employs. If the college has an established contract with a professional chemical disposal company, perhaps you could "piggyback" your chemicals with theirs and get them removed at one time. Offer to pay your fair share. You will want to prepare a complete list of the substances you consider excess. There is a chance the college itself may be able to use some of these materials. If the college can't help you, is there an industry in town which might use a professional chemical disposal company? If so, try to "piggyback" your chemicals with them.
Do the disposal work yourself. If you elect this option, read the disposal procedures we have developed and published in our Flinn Chemical Catalog/Reference Manual. Thousands of science teachers have found the disposal procedures to be a viable option.
If all of these avenues prove fruitless, you are left with only one option. Call the Safety Office to arrange a professional chemical disposal company to remove these chemicals. This is a very, very expensive option. Be sure to ask for references from such a commercial firm. Your liability does not end once these materials are removed, no matter how much you pay! There are reputable and reliable firms operating all over the USA. Just be careful in making your choice.
*We hope the seven step plan to clean up your chemical storage area has given you the direction and courage needed to improve the safety profile of your school. It's no small task to clean up a chemical storage area, but with a well defined plan and the support of your school administration this job can easily be done.