By Ken Roy
Posted on 2023-03-01
After 40 years of teaching chemistry, a high school science teacher decided to retire at the end of the academic year. Eventually, a young first-year chemistry-certified teacher was hired. About two weeks before school started, the excited new chemistry teacher was examining all the cabinets, drawers, and other storage areas in her assigned chemistry lab. Much to her surprise, she discovered two large cabinets in the back of the laboratory filled with a myriad of what seemed to be old chemical bottles. There were no dates on about 40 of the chemical containers, and some had decomposing labels along with crystals growing on the caps.
Not knowing what protocol to follow for each chemical, the new teacher contacted the science chairperson. The supervisor told the new teacher not to touch any of the chemicals and contacted a chemical waste removal company. Within one week, the company came, submitted the manifest along with the agreed-upon quote, and initiated the removal of all the hazardous chemicals found in the laboratory. In addition, the local fire marshal was called in, along with a hazmat team, to remove several bottles of picric acid, a known peroxide builder and potential explosive.
A few days later, the head of security contacted the science supervisor and shared a recording of a camera stationed on the high school soccer field. Evidently the chemical contractor decided the field would be ideal to unload many of the chemicals removed from the chemistry lab. Legal action was threatened by the school district after sharing the recording, and the contractor decided it would be best to clean up the chemicals from the soccer field and place them in the originally agreed-upon location.
This situation actually happened in a school district and is just one example of a “cradle to grave” safety issue that started even before procurement of the hazardous chemicals. How could all of this have been avoided? There are a number of issues and checks and balances that must be addressed before hazardous chemicals are ordered.
For the purposes of this blog post, hazardous chemicals are defined by the Occupational Safety and Health Administration (OSHA) Hazard Classification Guidance (OSHA 3844-02 2016; https://www.osha.gov/sites/default/files/publications/OSHA3844.pdf) order. Better professional safety practices and legal safety standards characterize procurement protocols for hazardous chemicals. Before beginning the procurement process, consider the instructions in this list.
A. Develop a list of “approved chemicals” that the school district science teachers are allowed to purchase.
B. Develop a review and approval process for securing additional chemicals to the existing list of approved chemicals. Include both the Chemical Hygiene Officer for the building and the science/STEM supervisor in the approval process.
C. Determine the amounts of each hazardous chemical on the list that are allowed to be procured.
D. Determine the amount of appropriate space available to store the hazardous chemicals. This will limit the amount that can be procured.
E. Make sure there is an active inventory of existing hazardous chemicals that reflects not only the name and type of chemical, but also the current quantities available, along with locations.
F. Develop a receiving process linked with the inventory system so it can be updated in actual time.
G. Develop a standardized hazardous chemical order request and approval form.
H. Have a shared documentation system for all procurement processes made available to all science/STEM faculty who need access to it.
I. Never accept chemical donations from any source. This includes donations of chemicals, glassware, experimental tools (i.e., spatulas), or anything that may have been used previously in an experiment.
J. Have a formalized staff professional development training program on roles and responsibilities, along with procedures for procuring hazardous chemicals for the school laboratories.
A. Any hazardous chemical to be added to the approved list must undergo a potential hazard analysis and resulting safety risk assessment. All approved chemicals added to the list must be approved by your local Board of Education, if required.
B. Make sure the legal safety standards and better professional safety practices are addressed via the resulting safety action in the hazard analysis/risk assessment process.
C. Have a definitive process to confirm all chemicals procured are on the approved chemical list. This is a fail-safe to ensure unapproved chemicals are not received, stored, or used by the school.
D. All purchase orders for hazardous chemicals must be reviewed and approved by appropriate safety compliance personnel (i.e., Chemical Hygiene Officer and/or Health and Safety Officer).
E. Have all staff trained annually regarding addressing potential safety hazards and resulting risks.
F. Only accept hazardous chemicals that have access to Safety Data Sheets (SDSs).
G. Make sure all hazardous chemicals are handled, stored, and disposed of properly and in a timely way.
H. All chemicals must be properly stored in a chemical storeroom’s shelving using an acceptable storage system (e.g., Flinn Shelf Chemical Storage Pattern system: https://www.flinnsci.com/api/library/Download/993b9838c5f54c08b16785b4f9eef970).
I. Use appropriate safety cabinets for chemicals such as corrosives, acid, flammables, etc.
J. Chemical amounts stored in the laboratory or storeroom should be minimized, as specified by National Fire Protection Association (NFPA) 45 and OSHA.
K. Incompatible chemicals must be segregated according to hazard class. Hazards should be indicated both on the chemical container label and the SDS (https://www.osha.gov/sites/default/files/publications/OSHA3636.pdf) accompanying the chemical. Chemicals need to be segregated, at a minimum, into the following major categories:
L. Laboratory chemical storage shelves should have a raised lip along the outer edge to prevent containers from falling. (See https://www.nsta.org/blog/safer-storage.)
M. Chemicals should be stored in accordance with the manufacturer’s recommendations and NFPA 45 standard requirements for chemical storeroom and laboratory ventilation, including 100% air replacement, continuous air flow, temperature, and humidity levels. Chemicals should not be stored near heat sources, such as steam pipes or laboratory ovens. Chemicals should never be stored in direct sunlight.
N. Deal only with credible chemical suppliers who are knowledgeable about chemical hazards, risks, and safety. Make sure they can answer safety questions about chemical use, storage, and disposal.
O. Use the appropriate OSHA labeling system on all chemical containers (Globally Harmonized System [GHS] of Classification and Labeling of Chemicals—https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200) required under the Hazard Communication Standard and OSHA Laboratory Standard.
P. Adopt “just-in-time” ordering to eliminate excess stock of hazardous chemicals, thus reducing appropriate storage capabilities and disposal costs. Check out this NSTA resource for “just-in-time” procedures: https://static.nsta.org/pdfs/ManagingYourChemicalInventoryPart2.pdf.
Q. Ensure school personnel who receive hazardous chemical shipments are trained under OSHA Hazard Communication Standard requirements to safely handle and deliver hazardous chemical shipments to the laboratory storage site.
R. Develop an accurate chemical inventory management system linked with purchasing and procurement.
S. Develop an annual chemical recycling/disposal program, including use of a reputable chemical disposal contractor. An example of this type of chemical waste program can be found at https://ipo.rutgers.edu/rehs/labwaste-chemical.
T. Provide appropriate levels of security to prevent unauthorized personnel access to hazardous chemical storage areas.
U. Chemicals may not be stored on the floor at any time.
V. Flammable chemicals are never to be stored in domestic-type refrigerators. Use only explosion-proof or flammable material refrigerators to store these chemicals within a laboratory environment.
W. Fume hoods should not be used as general storage areas for chemicals. This practice can impair the ventilating capacity of the hood.
X. The Chemical Hygiene Officer and/or Safety Compliance Officer must conduct periodic inspection of laboratories for appropriate storage and use of hazardous chemicals.
To ensure a safer teaching/learning laboratory environment, procurement of hazardous chemicals needs to involve “cradle to grave” planning based on legal safety standards and better professional safety practices. The planning must start before the activity is approved and implemented in the course of study, lesson plans, or classroom. Proper planning includes considering the purchasing, storage, use, cleanup, and disposal, with standard operating procedures implemented before procurement takes place.
Safety Blog Acknowledgement. NSTA Chief Safety Blogger Dr. Ken Roy wishes to 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.
Submit questions regarding safety to Ken Roy at email@example.com. Follow Ken Roy on Twitter: @drroysafersci.
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