By Ken Roy
Posted on 2023-07-24
This blog post will be published in two parts. It will address the things that both teachers and administrators must do to keep students, staff, and visitors safer in the science/STEM instructional spaces. The blog post will focus on two main items including assessing safety and developing/maintaining Standard Operating Procedures (SOPs). The concepts outlined in the blog post are intended to give you a framework so you can provide a safer learning environment for you and your students, staff, and visitors.
With the new 2023–2024 school year drawing near, it is time once again to make sure our instructional spaces (Science, Technology Education/Engineering, and STEM/STEAM laboratories; classroom and field sites) are safer for teaching/learning activities. Our students need to explore their curiosities and develop their skills in a hands-on, inquiry-based environment that is safer and up to date. Under the teacher’s responsibility through Duty or Standard of Care, it is critical that students, staff members, and visitors are protected by providing safer instructional spaces. To do this, teachers and administrators must take the time before school begins to assess safety related to critical components such as engineering controls (e.g. ventilation, emergency eyewash and shower, GFI (ground fault interrupter)–protected electrical circuits, etc.), administrative protocols (e.g., Chemical Hygiene Plan and/or Hazard Communications Safety Plan safety rules, etc.), and personal protective equipment (e.g., eye protection—safety glasses with side shields, indirectly vented chemical splash goggles; hand protection—vinyl or nitrile gloves; body protection—e.g., non-latex aprons, lab coats) and address any issues they discover.
When an issue is found, it must be communicated and logged, in writing, so a record of the requests made and the work done is available for anyone to inspect. The written record also serves as a tool to keep the issues in the forefront, as teachers and administrators have too many responsibilities and too little time to rely solely on their memory of a spoken conversation. This written record can also document that the teacher was fulfilling their duty or standard of care should an accident occur. If an issue is discovered, do not perform an activity that is influenced by the issue until it is corrected.
One final thought on assessing safety: A well-thought-out checklist should be used when inspecting instructional spaces. This checklist should be the result of careful planning and include the input of all science and safety experts in the building. A signed copy of the inspection should be available for anyone using the instructional spaces and kept on file in case anyone should have any questions.
Why are SOPs needed for instructional spaces? SOPs help make for safer teaching/learning activities for both students and teachers in the instructional space by consistently reinforcing proper methods and strategies to promote and maintain safer educational spaces. Teachers need to make sure SOPs are in place and followed before conducting any hands-on activities in instructional spaces. They need to be established, followed, and enforced at all times.
SOPs originate from legal safety standards established by the Occupational Safety and Health Administration (OSHA), the National Fire Protection Association (NFPA), etc., and better professional safety practices developed by NSTA, the American Chemical Society, the National Science Education Leadership Association, the International Technology and Engineering Educators Association, and other professional associations. The most referenced legal safety standard–based SOPs for science, technology education/engineering, and STEM/STEAM instructional spaces are derived from OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories or Lab Standard-29 Code of Federal Regulations (CFR) 1910.1450 (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1450) and OSHA’s Hazard Communication Standard 29 CFR 1910.1200 (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200). Better professional safety practices–based SOPs originate from professional associations as noted, such as the NSTA Safety Advisory Board’s laboratory practices resources (https://www.nsta.org/topics/safety#tab).
Remember SOPs are absolutely necessary not only because they are based on laws and better professional safety practices, but also because they make it safer for all occupants in an instructional space. This extends to those who will clean and maintain the room when the teacher is not present in the classroom. Following SOPs will keep these staff members safer as well.
Federal OSHA and most, if not all, OSHA-approved State Plans have adopted the Occupational Exposure to Hazardous Chemicals in Laboratories Standard, also known as the Lab Standard, which requires a written chemical hygiene plan with SOPs for all science/STEM/STEAM laboratories. Technology Education/Engineering shops or laboratories generally fall under OSHA’s Hazard Communications (HazCom) standard. Be aware that even non-OSHA states sometimes adopt the OSHA Lab Standard and/or HazCom standard by “reference.” Therefore, it is essential to find and learn your local and state standards. If you do not know where to find them, consult your Chemical Hygiene Officer or your local Fire Marshall.
The following is a sample list of essential SOPs based on legal safety standards and better professional safety practices.
A. Instructional Space Security. All instructional spaces (laboratories/classrooms) and support areas (storerooms, preparation rooms, etc.) containing potential biological, chemical, or physical hazards must remain locked in the absence of a designated employee. Unsecured instructional spaces or support areas allow for potential accidents and/or thefts of equipment, materials, chemicals, etc., by intruders, as well as potential liability issues in the form of lawsuits for teachers, staff, and administration. Schools are responsible for all the chemicals and biologicals from “cradle to grave” (i.e., purchase to discard). See the NSTA Safety Blog post “Procuring Lab Chemicals—A ‘Cradle to Grave’ Safety Issue.” School employees can be held liable if the chemicals or biologicals are removed from their unsecured instructional spaces or support areas, even with the school’s permission. (See Science Classroom Safety and the Law, A Handbook for Teachers by Kelly Ryan, 2001.) The rule of thumb is if a reasonable and prudent person would keep the room locked, so should the professional assigned to that room.
B. Pre-Lab Procedures. Before assigning a hands-on instructional space activity, it is critical to conduct a potential safety hazard analysis, and a resulting health and safety risk assessment, to determine the resulting safety actions to be taken. Safety Data Sheets (SDSs) for all chemicals are great resources for this action. These can be printed copies or electronic versions. Review all precautionary notes provided on SDSs with students before doing the hands-on activity or demonstration. Women of childbearing age must wear gloves when working with chemicals to prevent potential exposure to hazardous chemicals, which could be reproductive toxins. Inspect all engineering controls (e.g., eyewash, shower, ventilation, fume hood) required by the SDSs to ensure safer proper operation (use owner’s manual for more information) before conducting any laboratory activities.
Most of the equipment used in instructional spaces may need repair or replacement. If a piece of equipment is not in working order, do not use it: e.g., beaker, goggles, GFI, machine guards, etc. If an engineering control (e.g., safety shower, gas shutoff, ventilation, etc.) is not in working order, hands-on activities or demonstrations should not be done. If an activity is performed with faulty equipment, including engineering controls, and an accident or an injury occurs, the teacher and administration have joint liability and can be legally and financially held responsible. Again, if a reasonable and prudent person would not conduct the activity because of faulty equipment, neither should the teacher. It is the instructional space teacher’s responsibility to make sure everything is working appropriately before class sessions begin. This equipment includes, but is not limited to, glassware, lab equipment, hand and power tools, and safety equipment (including but not limited to fire extinguishers, fire blankets, eyewash stations, fume hoods/spray booths, doors, windows, safety showers, goggles, gloves, aprons, etc.).
Additionally, OSHA requires an up-to-date chemical inventory. When maintaining the inventory, any chemicals that have exceeded their shelf life must be disposed of, following the proper disposal procedures found in the SDSs for that chemical.
Finally, check in with the school’s Chemical Hygiene Officer (CHO) and make sure the school’s Chemical Hygiene Plan (CHP) is up to date. This includes an annual editing process that must be approved by your local Board of Education. It is the CHO and teachers’ shared responsibility to know if any changes are required for the plan. The updated plan must include what the SOPs are in the instructional spaces or support areas, if any new chemicals or biologicals have been added to the banned list, and what to do in an emergency or if an accident occurs.
C. Hazardous Chemical Care. All hazardous chemicals should be reviewed and approved by the CHO before they are purchased. Flammable liquids are to be stored in approved containers and amounts in, for example, a designated flammable liquid cabinet. Laboratory fume/exhaust hoods and spray booths are not intended for storage. Fume hoods or spray booths that are used inappropriately are subject to an OSHA fine during an inspection. Before and during the use of chemicals that produce potentially toxic or noxious vapors, the ventilation system must be checked to ensure proper operation. Use the chemicals SDSs to determine if a fume hood must be used. The same ventilation check must be used for spray booths before spraying paints, stains, etc.
Use only explosion-proof refrigerators for storage of flammable materials requiring lower temperatures. Make sure refrigerators have designated storage use for either hazardous chemicals and biologicals or food for human consumption. OSHA requires that they are labeled appropriately on the outside of the door. More importantly, if the signage is not used and/or not followed, food and drink can become contaminated.
D. Food and Drink. Given the potential for cross-contamination from chemical or biological residue, food and drink are not allowed in the instructional spaces, save authorized exceptions by the CHO. These exceptions must be communicated in writing. Signage must be posted to reflect this SOP in science/STEM spaces.
Next month, we will continue with our list of Standard Operating Procedures teachers and administrators need to have in place to make their instructional spaces safer.
Submit questions regarding safety to Ken Roy at email@example.com. Follow Ken Roy on Twitter: @drroysafersci.
NSTA Chief Safety Blogger Dr. Ken Roy wishes to sincerely thank nationally recognized District Supervisor of Science Kevin S. Doyle, Ed. D., Morris Hills Regional District, Rockaway, New Jersey (firstname.lastname@example.org) for his professional review of and contributions to this commentary.
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