Lab Safety

Anita BernhardtScience and Technology SpecialistMaine Department of Education 624-6835

Are Labs Worth The Risk?

America’s Lab Reporthttp://www.nap.edu/catalog.php?record_id=11311

• Yes, labs can facilitate “understanding the complexity and ambiguity of work”

• Not enough to simply have lab time - Integrated instructional units vs. “typical” lab experiences

• Integrated instruction units linked to gains in student achievement

Safety Survey Results Demonstrate Risks

• Not enough space – 45 /60 sq. ft.

• Lack of functional eye washes

• Lack of safety training

• Class size and safety

Laboratory Science Safety Checklists – America’s Lab Report

• Chief State Science Supervisors http://www.csss-science.org/safety.shtml

• National Science Teachers Associationhttp://www.nsta.org/about/positions/safety.aspx

• National Science Education Leadership Associationhttp://www.nsela.org/publications/publications2.html

• Flinn Scientifichttp://flinnsci.com/Sections/Safety/safety.asp

• Laboratory Safety Institutehttp://www.labsafety.org

Maine Dept. of Education Safety

Resources

• http://www.maine.gov/education/lres/scitech/resources.html

Student Safety Liability Teacher Duties

• Safety instruction – dangers, risks, procedures, appropriate behavior –adhere to professional guidelines

• Supervision – constant attendance, level of supervision (age of students and risk)

• Maintenance – inspections, reports, never use defective equipment, chemical handling guidelines

Chemicals in Schools

Ed Antz, School Construction

Maine Department of Education

Tele # 624-6886

Purpose of Presentation• To provide information regarding regulations and

programs here in Maine that deal with “chemicals in schools”, public and private:– In general, private schools in Maine are regulated to a

very limited degree, usually when a complaint is filed; very few outreach or education activities

– Public schools are more tightly regulated by 4 state agencies in Maine, but not really a priority:

• OSHA, through the Department of Labor• The Department of Education (Chapter 161)• The Department of Environmental Protection (Chapter 850)• The Department of Agriculture (Chapter 27)

Background• Chemicals is a broad term that includes a variety of

sources (art, maintenance, cleaning, labs etc.)• Several universities in New England were fined three

years ago for “chemicals” violations; no secondary schools (storage and disposal)

• Nothing is new here; most of the state rules have been in effect for more than a decade

• The Maine Legislature passed a resolve (LD1157) three years ago that tasked DOE/DEP to develop and carry out a plan that ensures that chemicals are safely managed in schools (existing rules that were basically ignored)

Background• The Resolve was issued due to several

chemical safety concerns in schools involving stockpiles of old chemicals; bomb squads were called four times in 2005 and 2006

• Four state agencies and others met to discuss the issues and develop a report on how best to proceed (this will be discussed later)

• Education had a position in the budget for 2007, but consolidation and budgetary concerns materialized so it was never acted upon, still hasn’t been

• The reality is that the state commits relatively few resources to the effort of chemical management in schools, and schools do not manage lab chemicals well in some cases

Chemicals in Maine News• Three years ago, several state agencies were chastised

for not enforcing their rules• DOE/DEP were tasked with developing an action plan to

ensure that chemicals are safely managed in public schools. A report went to the Legislature in January ‘06, with recommendations

• DOE/DEP are taking the lead; inventories were sent to DOE in ’05,’06 and ‘07; highly hazardous lab chemicals identified every year

• A statewide disposal of hazardous lab chemicals happened on ‘06 with nearly 60 public schools participating; schools funded; 50% off normal pricing; 12,000 pounds of chemicals disposed of.

Maine News (continued)• In ’06, 44% of middle and high schools had

unacceptable (risk) lab chemicals– Survey of 20 high schools in ‘07 showed that 90%

still had high to moderate risk lab chemicals in their schools.

• A stakeholders group recommended:– requiring environmental health and safety

managers in schools (local or regional)– an environmental health and safety coordinator in

Dep’t of Education

(neither has been implemented!!)

Applicable Rules• Maine’s DOL (Labor) regulates working around lab

chemicals, primarily through OSHA standards, and general chemicals through “Haz Comm” (employees only, not students)

• Maine’s DEP (Environmental Protection) regulates disposal and storage of hazardous and universal wastes (lab and others)

• Maine’s DOE (Education) regulates storage and purchase of lab chemicals (perhaps others?)

• Maine’s DOA (Agriculture) regulates pesticides, including insecticides, herbicides, and rodenticides

DOL Rules, Adopted OSHA, 1910.1450

• Lab Safety: (public and private schools)– Chemical Hygiene Officer must be trained and appointed– Chemical Hygiene Plan is required and annually updated– Monitoring required– A MSDS for each chemical is required– Labels must be intact on the original container– Fume hoods and vents must work– Persons who may be exposed need training and ppe (in

case of spills, exposures, etc.)– Haz Comm rules also apply in schools (1910.1200)

DEP Rules, Chapters 850 et seq.

• DEP regulates Hazardous and Universal Wastes– Hazardous Waste: Storage, labeling,

manifesting, and disposal requirements (waste solvents, oils, paints, flammables, degreasers, and lab chemicals)

-Universal Waste: Storage, labeling, manifesting, and disposal requirements (cathode ray tubes, fluorescent bulbs or lamps, PCB ballasts, mercury products, batteries (not lead batteries))

– Rules are comprehensive and complex

Hazardous Wastes

• Hazardous components in each!

Universal Wastes

Ag Rules, Chapter 27

• Agriculture regulates applicator licensing and integrated pest management in schools – Applicators must be licensed by Agriculture– SAUs must have an IPM coordinator and plan– SAUs must notify Parents/staff before pesticide

applications, post warnings, and use pesticides only after an IPM decision matrix has been considered (think first and spray last!)

– SAUs must notify parents of availability of IPM Plan (annually)

– SAUs must keep records for 2 years

Pesticides

Schools CAN Use Certain Pesticides:

1. Disinfectants used in routine cleaning

2. Emergency stinging insect control

3. Repellants for personal protection

4. Non-powered application of paints & stains

Education Rules, Chapter 161• Purchase and storage requirements:

– A purchase screening process is required• Common and chemical name• Amount needed for the year• Storage, use, and waste disposal requirements• Amount and age of any existing stock

– Chemicals are limited to a 2-years supply– Lab chemical inventories must be

submitted annually to Education

Chapter 161 (continued)

– Chemicals must be stored securely and accessible only to trained personnel

– Storage area shelves shall be steel or wood (acid resistant paint), labeled, securely anchored, and equipped with safety lips to prevent spillage

– Chemicals shall be labeled and stored, consistent with the MSDS (material safety data sheets), and only with other compatible chemicals

Proper Lab Chemical Storage (Flinn or Other)

Chapter 161 (continued)

– ABC fire extinguisher (10 lbs) is required within 50 feet of the storage area

– Spill control materials and equipment shall be provided

– Eye wash, shower, and room venting are recommended

Chapter 161 (continued)– Failure to comply may result in a Notice

of Violation or in subsidy withholding until the deficiencies are corrected

– The Department’s goal is voluntary compliance!!

– Realistically, enforcement in SAUs is not a high priority or a politically favorable practice, so it is not common

– However, liability and publicity are issues for schools should an employee or student get hurt due to negligence or error

Chapter 161 Revisions

The DOE is revising Chapter 161 and should be done this spring. Some changes include:

• Regulating chemicals used in academics only (art, labs, voc ed, etc) since OSHA/DOL regulate others under Haz Comm

• Chemical storage will be based on risk; some chemicals (several hundred) will be banned, most others can only be stored for 5 years

• “Chemical Hygiene Plans” will be required and will apply to students as well

Chapter 161 Revisions

A formal purchasing form will be required:-names of chemicals-amounts of existing stock and request-projected 5 year total based upon annual usage-hazards of the chemical as determined by the MSDS

Form must be signed by the CHO or designee

Chapter 161 Revisions

Storage requirements- many new requirements; chemicals must be stored as per MSDS in one of 5 separate areas:-special acids (sulfuric, nitric, chromic)-corrosive acids (hydrochloric, acetic, etc)-corrosive bases (ammonium and pot hydroxides, etc)-flammables-general storage: chemicals stored by various hazard categories (similar to Flinn suggested shelf pattern)

Chapter 161 Revisions

• Disposal:

-chemicals must be disposed of after 5 years UNLESS the CHO substantiates in writing that the chemical is safe and can be stored safely in excess of 5 years

-chemicals listed in Appendix A are banned and existing stock must be disposed of by 12/31/09.

-hazardous waste contractors must be used for packaging and disposal

Chemical ManagementPrograms

• Good chemical management programs should consider following: -Buy only the quantities that you need for the near future (2-5 years maximum) – Don’t “buy bulk” just because it saves money– Substitute “green” chemicals whenever

possible in all areas (custodial, art, labs, maintenance, pesticides, voc ed, etc.)

– Labs try “micro-scale” experiments; smaller quantities of chemicals, usually in “lab-kits”

Planned and Possible Future Actions

• Revised Chapter 161

• Report on Joint Standing Committee on Natural Resources – “Hazardous Chemicals in Our Schools”

• Create a manual that provides an integrated, coherent overview of the regulations and best practice to guide laboratory safety