By Ken Roy
Posted on 2023-01-04
When a safety compliance officer/consultant inspects school laboratories for science, technology education/engineering, art, and similar subjects, typically all sorts of excuses are provided as to why there is limited or no use of eye protection when a potential hazard analysis and resulting risk assessment clearly indicate the need for a safety action. One reason for the excuses is that some teachers don’t conduct potential hazard analysis/risk assessments to begin with. Instead, they tend to make assumptions based on past experiences in the laboratory. This certainly can be dangerous, to say the least.
A second excuse is because when teachers and students are working with hazardous chemicals, safety glasses are used in lieu of the required indirectly vented chemical splash goggles. Some teachers believe safety goggles and glasses basically provide the same protection for the eyes.
A third excuse is because the school’s chief building administrator (principal) or superintendent of schools basically tells teachers to “wing it and don’t worry about it: They can’t be sued.” This statement is usually related to budget cuts that result in little to no funds being provided for eye protective devices. Unfortunately, teachers can be sued if shown to be negligent or worse—reckless!
The last most common excuse is that although employees must have safety training on personal protective equipment requirements and use—as required by employers under the Occupational Safety and Health Administration (OSHA) Laboratory Standard and Hazard Communications Standard—the mandated training is unfortunately not always provided by the employer. Every one of these excuses can be characterized by one word: Denial. Each one not only puts the students and teachers at risk safety-wise for an accident, but also puts the teachers and the administration at risk for legal issues should someone get hurt setting up a lab activity, doing the activity hands-on, or dismantling it.
To the administrator who says, “Don’t worry; you can’t be sued,” I respond, “Seriously?” Duty or Standard of Care is defined as an obligation, recognized by law, requiring conformance to a certain standard of conduct to protect others against unreasonable risk. (Prosser et al. 1984) “The breach of a particular duty owed to a student or others may lead to liability for both the teacher and the school district that employs that teacher.” (Ryan 2001)
Better professional safety practice in addition to legal safety standards require appropriate personal protective equipment (PPE) in the form of eye protection when there is potential exposure to biological, chemical, and physical hazards in the workplace, including in school science and science, technology, engineering, and math (STEM) labs. An example of how a legal standard might address this issue is as follows: Any person who is working, teaching, observing, supervising, assisting in, or engaging in any work, activity, or study in a public or private elementary or secondary school laboratory or workshop where the process used tends to damage the eyes or where protective devices can reduce the risk of injury to the eyes concomitant with such activity shall wear an eye protective device of industrial quality in the manner in which such device was intended to be worn. (1)
Too often science teachers ignore the need for appropriate PPE, and should a safety incident occur, can find themselves in legal entanglements, including negligence, or even worse, recklessness. As stated, teachers have what is known as duty or standard of care for their student. If a teacher does not state the potential hazards and resulting risks associated with the hands-on activity, doesn’t remind students about the need for eye protection, and doesn’t enforce eye PPE use, the teacher is severely at risk for ignoring their legal responsibilities in student care. This also applies to other employees or volunteers in the laboratory during the activity.
One of the first things teachers need to do before beginning a hands-on activity or demonstration in the lab is to conduct a potential safety hazard analysis and resulting risk assessment. (https://static.nsta.org/pdfs/ManagingYourChemicalInventoryPart3.pdf) This will help determine what safety action must be taken, including using appropriate PPE.
PPE for eyes must meet minimum standards for the design, construction, and quality of eye protective devices. Any eye protective device used in such school laboratories should be designed and constructed to resist impact, provide protection against the particular hazard for which it is intended, fit snugly without interfering with the movements of the user, and be durable, cleanable, and capable of frequent disinfection by the method prescribed for such device by the school medical adviser. All indirectly vented splash goggles and safety glasses with side shields need to comply with one of the following standards per OSHA as applicable: American National Standards Institute (ANSI) Z87.1-1989, ANSI Z87.1-2003, ANSI/International Safety Equipment Association (ISEA) Z87.1-2010, and ANSI/ISEA Z87.1-2020 Occupational and Educational Personal Eye and Face Protection Devices. The current 2020 edition now includes testing, performance, and marking for anti-fog lenses and includes relaxed optics criteria (as an option) in response to end-user needs. (https://blog.ansi.org/2020/04/ansi-isea-z87-1-2020-safety-glasses-eye-face/#gref)
One final precaution should be noted. Be careful when selecting straps or bands for eye protective devices. These are often made of latex elastic material, and some students and teachers may be allergic to them.
Protective eyewear needs regular cleaning for chemicals (e.g., corrosive residue) and physicals (e.g., dirt or grime), as well as sanitizing or disinfecting for biologicals (disease-causing viruses and microbes). This is especially true if eyewear is shared in the lab and must be sanitized after each use.
In the case of potential physical hazards, labs have many possibilities. For example, with the meter stick, there can be an uncontrollable or accidental operation of a lever system that can cause injury. A quick turn by one student holding the stick could result in the end of the stick getting in the eye of another student. If the glassware should shatter, flying projectile pieces could land in students’ eyes.
Projectiles such as rockets may be on a trajectory that could injure the unprotected eyes of observers. Walking in the woods has its own safety issues, but one for certain is the potential for being struck in the eye by branches during a school field lab activity. In these cases, eye protective devices (e.g., safety glasses with side shields or safety goggles) need to be worn by students, teachers, and any other observers.
The bottom-line is that science teachers need to know the legal safety standards (e.g., OSHA, state statutes, etc.) and better professional safety practices (e.g., ANSI/ISEA, NSTA, National Science Education Leadership Association, International Technology and Engineering Educators Association, American Chemical Society, etc.) required by their employers, appropriate government standards, and professional associations’ protocols. When there is any chance of injury to the eye, it is better to be safer than sorry! All lab occupants (e.g., teacher, students, paraprofessional, etc.) should wear the appropriate sanitized eye protection.
Also remember that additional PPE may be required at times, such as gloves, aprons, close-toed shoes, and other protective items. Make sure the PPE are quality built to meet appropriate safety standards. PPE must be worn during the three segments of a lab activity: setup, hands-on activity, and take down.
(1) Connecticut High School Science Safety Prudent Practices and Regulations
Regulations Concerning Eye Protective Devices as Authorized by Section 214a of the Connecticut General Statutes
American National Standards Institute
OSHA Personal Protective Equipment Standard
Submit questions regarding safety to Ken Roy at firstname.lastname@example.org. Follow Ken Roy on Twitter: @drroysafersci.
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