Building Successful Programs to Address
       Chemical Risks in Schools:
 A Workbook with Tempi?
•chniquos
                   EPA530 K-08-003
                   November 2GDB

                 hup: //www.epa.g o v/sc3

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This document is for general informational purposes only and should not be construed as advice concerning
any specific circumstances. The templates, tips and techniques provided in this workbook are intended solely
as examples of successful practices, do not impose legally binding requirements on EPA, states, or the
regulated community, and may not apply to a particular situation based upon the circumstances. You are
urged to consult appropriate experts concerning any specific situation or issue. Users are responsible for
knowing and complying with all applicable federal, tribal, state, and local requirements. This document does
not substitute for any EPA regulation and is not an  EPA rule.

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                         Table of Contents

Introduction                                                                 i


   Why does EPA care about chemicals in schools?                                i

   Why did EPA create this Workbook?                                           i

   What are the key components of a school chemical management program?          ii

   Who should you include as members of your SC3 Team?                         ii

   What are the steps to build a successful SC3 program?                          iv
Chapter 1 - Evaluate your Chemical Management Practices and Identify          1-1
          SC3 Program Goals
   Why should you evaluate your chemical management practices?                 1-1

   What does it take to get an SC3 program off the ground?                        1 -1

     Activity 1 - Find a manager and identify a champion for your SC3             1-2
               program

     Activity 2- Identify potential stakeholders, partners, and customers           1-3

     Activity 3 - Start building your core SC3 Team                             1 -6

     Activity 4 - Conduct a visual tour to get first impressions of your school's       1 -6
               chemical management situation, policies and practices

     Activity 5- Perform a comprehensive evaluation of your school's              1-8
               chemical management situation, policies, and procedures

   How do I figure out the issues or concerns that my SC3 program needs to        1-14
   address?

     Activity 6 - Identify issues and agree to SC3 program goals                 1 -14

   How do I develop goals for my responsible chemical management program?      1-14

     Activity 7 - Develop performance measures to track the progress of your      1 -16
               SC3 program

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                     Table of Contents fcont.)



   Summary                                                               1-18

   Additional Tools and Examples                                           1-19

      Worksheet 1-1: Evaluating Your School's Chemical Management             1-20
      Situation, Policies, and Procedures

      Worksheet 1-2: Defining SC3 Program Goals that Address Issues / Areas      1-24
      of Need

      Worksheet 1-3: Developing Performance Measures Based on Desired         1-25
      Goals


Chapter 2 - Decide What Your SC3 Program Will Look Like                     2-1


   Why should I define key components of my  SC3 program?                      2-1

   How can I determine if my SC3 program goals can be achieved?                 2-2

      Activity 1 - Define the activities your program will perform                    2-3

      Activity 2 - Create a timeline for starting and completing each activity          2-4

      Activity 3 - Identify the school / district personnel and potential partners        2-6
                who can  perform SC3 activities

      Activity 4 - Identify potential roadblocks and ways to address them            2-7

      Activity 5- Estimate the resources required to perform each activity           2-8

      Activity 6 - Identify potential sources of funding for the SC3 program           2-9

      Activity 7 - Enter into partnerships                                       2-11

   How do I recruit partner organizations to the SC3 Team?                       2-11

   How can everyone get the most out of an SC3 partnership?                    2-13

      Activity 8 - Identify any regulations that may affect your SC3 program         2-15

   Summary                                                               2-17

   Additional Tools and Examples                                           2-18

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                     Table of Contents fcont.)


      Worksheet 2-1: SC3 Activities and Performance Measures to Reach          2-19
      Program Goals

      Worksheet 2-2: SC3 Progress Report                                    2-20

      Worksheet 2-3: SC3 Staffing Plan                                       2-21

      Worksheet 2-4: Identifying Potential Obstacles and Solutions                2-22

      Worksheet 2-5: SC3 Labor Cost Estimate                                 2-23


Chapter 3 - Create and Communicate the SC3 Program Message                3-1


   Why is it important to publicize my SC3 program?                             3-1

      Activity 1 - Develop and deliver an effective program message with an        3-1
               informative program name or slogan

   Why should I  create a program  message?                                    3-1

   How do I develop an effective message?                                     3-2

      Activity 2 - Identify target audiences                                     3-3

   Who are the target audiences of the SC3 program message?                    3-3

      Activity 3 - Use existing communication channels to publicize your            3-4
               program

   How do I get people  involved and committed to the program?                    3-6

      Activity 4 - Consider the most effective time of year to perform                3-7
               communication and publicity efforts

   When is a good time to launch an SC3 program?                              3-7

   Summary                                                               3-8

   Additional Tools and Examples                                           3-9

   Worksheet 3-1: SC3  Program Components of Interest to Target Audiences       3-10

   Worksheet 3-2: Methods of Communication and Publicity for your Program       3-11
                Message

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                     Table of Contents fcont.)



Chapter 4 - Implementing Your SC3 Program                                 4-1


   Overview                                                                4-1

   How do I put my SC3 program into action?                                   4-2

   Section 1 - Program Management                                          4-3

     Activity 1 - Begin to put your SC3 program into action                      4-3

                Pull together SC3 program planning materials                   4-3

                Do what is most important for your school right now              4-4

   Where can we have the greatest impact now?                                 4-4

   How do we set priorities for the first year?                                    4-6

                Manage and coordinate initial SC3 activities                     4-8

   How do we get team members started?                                      4-8

   How do we keep our SC3 program running smoothly?                         4-10

                Track progress and tell your story                            4-11

   How do we track progress in the first year?                                  4-11

   When should  we tell everyone what we are doing?                            4-12

     Activity 2 - Establish and modify existing chemical management            4-15
                procedures

                Establish procedures and integrate them into a chemical         4-15
                management plan
     Activity 3 - Train appropriate groups on  responsible chemical               4-17
                management

                Identify what your chemical management training will look like     4-17

   Who needs to be trained?                                                 4-17

   What topics should I include in my SC3 training?                              4-18

   Who will perform the training?                                             4-20

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                   Table of Contents fcont.)


How can I best plan training events?                                         4-20

Section 2 - Special Chemical Management Projects                           4-22

   Project 1 - Perform an inventory of all chemicals and chemical products       4-22

Why should I conduct a chemical inventory?                                   4-22

What is involved in performing a chemical inventory?                           4-23

What steps do I take after completing a chemical inventory?                     4-25

   Project 2 - Secure a chemical cleanout professional                        4-26

Why should I conduct a chemical cleanout?                                   4-26

How do I get started on a chemical cleanout?                                  4-26

         Sub-Activity A - Evaluate your chemical inventory and create a list      4-27
              of chemicals to dispose (a disposal list)

         Sub-Activity B - Identify a qualified professional(s) to assist in the       4-29
              cleanout and disposal process

What is a request for proposal?                                              4-30

How do I advertise an RFP?                                                4-31

How do I select a qualified professional?                                     4-31

How do I estimate cleanout  and disposal costs?                               4-33

Are there ways to lower disposal costs?                                      4-34

         Sub-Activity C - Prepare for chemical cleanout and disposal            4-35

         Sub-Activity D - Take additional steps to reduce the need for future     4-36
              chemical cleanouts

   Project 3 - Implement a green curriculum                                  4-37

              Putting together a green curriculum                            4-37

What is a "green curriculum"?                                               4-37

How can I start a green curriculum in my school?                              4-38

How should we design our green curriculum?                                 4-40

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                     Table of Contents fcont.)


                Roll out your green curriculum                                 4-42

   How do we incorporate green curricula into our classes?                       4-42

   Summary                                                               4-43

   Additional Tools and Examples                                           4-44

      Worksheet 4-1: Identify Low Cost, Quick Fixes to Chemical Management      4-45
      Situations

      Worksheet 4-2: Identify SC3 Priorities for the First Year                     4-46

      Worksheet 4-4: Measuring Behavioral Change                             4-47

      Worksheet 4-7: SC3 Training Topics by Target Audience                    4-48

      Worksheet 4-9: Post-Inventory Evaluation of your Chemical Management      4-49
      Situation

      Worksheet 4-10: Chemical Disposal List                                  4-50

      Exhibit 4-11: Sample RFP                                              4-51

      Exhibit 4-12: Vendor Qualifications Checklist                               4-58

      Exhibit 4-13: Sample Price Quote                                        4-59

      Exhibit 4-14: Examples of Cost Saving Techniques                         4-60


Chapter 5 - Sustain Your SC3 Program                                       5-1


   What can I  do to sustain my program?                                        5-1

      Activity 1 - Evaluate and measure your program's progress, methods          5-2
                and capabilities

      Activity 2 - Keep chemical management policies and procedures up- to-       5-3
                date

   How can I keep my chemical management policies and procedures               5-3
      up-to- date?

      Activity 3 - Conduct periodic training                                     5-4

   What should our training program look like over time?                           5-4

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                  Table of Contents fcont.)



   Activity 4 - Communicate progress and success to keep enthusiasm and       5-6
             awareness high

Is communicating program progress important to sustaining success?             5-6

   Activity 5 - Maintain Relationships with Partners                            5-7

How do I maintain an effective ongoing relationship with my partner?              5-7

   Activity 6 - Estimate staffing and funding requirements and continue to         5-9
             look for new funding sources for ongoing SC3 activities

What kind of funding do I need to maintain my SC3 program?                    5-9

Summary                                                             5-10

Additional Tools and Examples                                         5-11

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                    Table of Contents fcont.)
Partner Appendix: Why Become Involved in School Chemical                  A-1
Management?
   Why become involved in school chemical management?                       A-1

      What are the benefits of being a partner in school chemical management?      A-1

      How can your organization improve chemical management in schools?        A-2

      How can my organization benefit from partnering with a school?              A-3

      How can my organization benefit from partnering with EPA?                 A-3

   How do I get involved in a school chemical management project?                A-6

      What are some things to think about when approaching management?        A-6

      How do I get started?                                                 A-7

      How will EPA and my organization work together?                         A-8

      How will EPA help my organization?                                     A-9

      How should I approach the initial meeting with a school or school district?     A-10

      How should I follow up an initial meeting with a school?                    A-13

      Sample Partnership Agreement                                       A-14

   How can I  continue to help schools improve chemical management?            A-16

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                  Table of Exhibits and Figures

Exhibit 1: Checklist for Building an SC3 Program                               v

Exhibit 1-1: Evaluating Your School's Chemical Management Situation,           1-9
          Policies and Procedures

Figure 1 -1: Blank Material Safety Data Sheet (MSDS) (Example)                1 -12

Figure 1-2: Chemical Safety Label                                         1-13

Exhibit 1-2: Defining SC3 Program Goals that Address Issues /Areas of         1-15
          Need

Exhibit 1-3: Developing Performance Measures Based on Desired Goals         1-17

Exhibit 2-1: Developing SC3 Activities and Performance Measures to             2-4
          Achieve Program Goals

Exhibit 2-2: SC3 Progress Report                                           2-5

Exhibit 2-3: SC3 Staffing Plan                                              2-6

Exhibit 2-4: Identifying Potential Obstacles and Solutions                       2-8

Exhibit 2-5: SC3 Labor Cost Estimate                                       2-9

Exhibit 2-6: Sample Partnership Agreement                                  2-13

Exhibit 3-1: SC3 Program Components of Interest to Target Audiences           3-3

Exhibit 3-2: Methods of Communication and Publicity for Your Program           3-5
          Message

Exhibit 4-1: Identify Low Cost, Quick Fixes to Chemical Management             4-4
          Situations

Exhibit 4-2: Identify SC3 Priorities for the First Year                            4-7

Exhibit 4-3: SC3 Program Calendar                                          4-9

Exhibit 4-4: Measuring Behavioral Change                                   4-12

Exhibit 4-5: Template for a Letter of  Recognition                             4-14

Exhibit 4-6: Chemical Management  Plan Template                           4-16

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Exhibit 4-7: SC3 Training Topics by Target Audience                          4-19

Exhibit 4-8: Basics of Conducting Formal Training                             4-21

Exhibit 4-9: Post-Inventory Evaluation of your Chemical Management           4-25
           Situation

Exhibit 4-10: Chemical Disposal List                                        4-28

Exhibit 4-12: Vendor Qualifications Checklist                                 4-32

Exhibit 4-13: Sample Price Quote                                           4-33

Exhibit 4-14: Examples of Cost Saving Techniques                            4-34

Exhibit 4-15: Motivations for Supporting a Green Curriculum                    4-39

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            Building Successful Programs to Address Chemical Risks in Schools:
                     A Workbook with Templates, Tips, and Techniques
                                 Introduction
                             Why does EPA care about chemicals in schools?

Outdated, unknown, or unneeded amounts of dangerous or inappropriate chemicals are
often found in K-12 schools across the nation, potentially putting students and staff at
risk.  Because of the nature of some of the chemicals, even small amounts may present a
risk.  Thus, dangerous chemicals represent one of the critical environmental health and
safety issues schools must address.
                                                                            See the EPA Web sites at
                                                                            http://www.epa.gov/schools
                                                                            and http://www.epa.gov/sc3
                                                                              for more information.
The Environmental Protection Agency's (EPA) Schools Chemical Cleanout
Campaign (SC3) promotes chemical management programs that remove outdated,
unknown, or unneeded amounts of dangerous or inappropriate chemicals from K-
12 schools.  SC3 also promotes the creation of policies and practices that prevent
future accumulations of chemicals and encourages responsible management practices of chemicals
used in schools. These programs aim to minimize exposure to students and staff, thus improving the
learning environment and reducing school days lost.
                                    Why did EPA create this Workbook?
                   EPA's SC3 makes available a variety of tools to help you create or improve your
program for responsible chemical management in schools. This Workbook provides advice and
templates developed by successful SC3 programs in various states, localities, and tribes that can be
used to help you design or improve upon your own SC3 program.  The tips, techniques, and templates
in this Workbook can be applied and adapted for SC3 programs being developed and operated at the
school, school district, or state level. We structured this Workbook in a way to help you identify what
organizations and expertise are important to a program and what steps can be taken to get started or
refine a program.  So whether you are an employee of a school, local government, or local business,
this guide will help you.

Please visit www.epa.gov/sc3 for this document and for more tools and information about responsible
chemical management in K-12 schools.

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                                       Introduction:
                     A Workbook with Templates, Tips, and Techniques
                 What are the key components of a school chemical management program?
EPA reviewed many state, tribal, and local SC3 programs and found that the following components and
functions are important for a school chemical management program:
         LtADtRSHIP & RtSOURCtS
CHEMICAL INVENT DRY

                     I  STORAGE ft HANDLING J        CHEMICAL CLEANOUT & DISPOSAL
                                        PURCHASING
                                                            POLLUTION PREVENTION j
                         COMMUNICATION & TRAINING
Please note the components and functions represented here are in no particular order.  While some of
these themes may be related, the connections portrayed are random and do not imply any dependency.
                          Who should you include as members of your SC3 Team?


Creating an SC3 program should include an array of perspectives and expertise. Teaming up with
people with a variety of expertise and an interest in safe schools and communities is important to
successfully design, begin, and maintain a comprehensive, responsible chemical management program.
Such programs can be developed and carried out in stages and still make a positive difference in the
health and safety of a school, students, and staff.

Gaining the support of your superintendent or principal and school board is the logical place to start.
Also, finding someone who is knowledgeable about or interested  in responsible chemical management
is important because they can serve as a "champion" of your SC3 program.  You can also benefit from

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                                        Introduction:
                      A Workbook with Templates, Tips, and Techniques

a diverse team of partners to build and sustain an effective SC3 program.  For example, you may need
expertise not only in responsible chemical management, but also:

       School administration;
       Policy development;
       Contracts management;
       Curriculum development;
       Chemical safety training;
       Understanding regulatory requirements; and
       Risk management.
Most schools do not have the necessary expertise and trained personnel in-house. Therefore,
depending on the unique circumstances and needs of your school, you may want to seek out and
establish partnerships with any of the following entities:
                        SCHOOL DISTHK-,
                        ADMINISTRATORS
                           f, BOARD
COLLEGES a
UNIVERSITIES
                       PARENTS*
                       CAREGIVERS
     INDUSTRY
     PARTNERS
                                   THADE &
                                 PROFESSIONAL
                                ORGANIZATIONS
These potential partners can help your school(s) by cost-effectively assisting with:

       Inventorying chemicals;
       Purchasing of chemicals (e.g., how to purchase fewer and/or less toxic chemicals);
       Budgeting for chemical management;
       Developing a sustainable chemical inventory system (e.g., proper storage and labeling);
       Packaging mismanaged/unnecessary chemicals for removal;
       Removing mismanaged/unnecessary chemicals;
       Proper disposal of unnecessary chemicals;
       Developing and conducting chemical management and safety training;
       Developing and implementing a chemical management program;
       Implementing improved chemical usage strategies (e.g., changes in a school's classroom and
       maintenance practices to minimize the quantity of chemicals used in experiments);
       Developing and implementing greener cleaning practices;

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                                        Introduction:
                      A Workbook with Templates, Tips, and Techniques

       Grant-writing assistance;
       Recruiting other SC3 partners; and
       Developing performance goals and measures to gauge chemical management success.

You probably already have relationships with some of these partners, which should make it easier to
ask for their assistance in creating or improving your SC3 program. If you haven't yet cultivated
relationships with these potential partners, consider contacting them to be part of your effort. Often
potential partners are looking for ways they can help their local communities.
                           What are the steps to build a successful SC3 program?

                 THE STEPS TO A SAFER SCHOOL

        THROUGH RESPONSIBLE CHEMICAL MANAGEMENT
                 Decide What
                 Your Program
                 Will Look Like
STEP1
Evaljate Chemical
  Management
   Practices
  and Identify
 Prog ram Goals
The graphic above provides an outline of the basic steps of an SC3 program that will be discussed in
this Workbook. Whether you are taking the first step towards responsible chemical management or
refining an existing program, this Workbook shows you how to do each of these five steps, with tips,
techniques, and templates from real world practitioners to assist you.  In Exhibit 1 on the next page, we
provide a checklist of activities we recommend for each of the five steps to building an SC3 program.
                                             iv

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                                      Introduction:
                      A Workbook with Templates, Tips, and Techniques
  Exhibit  1:   Checklist for Building an SC3  Program

Step One: Evaluate your chemical management practices and identify SC3
            program goals

   •   Find a manager and identify a champion for your SC3 program.
   •   Identify potential stakeholders, partners, and customers.
   •   Start building your core SC3 Team.
   •   Conduct a visual tour to get first impressions of your school's chemical management situation,
       policies, and practices.
   •   Perform a comprehensive evaluation of your school's chemical management situation, policies,
       and procedures.
   •   Identify issues and agree to SC3 program goals.
   •   Develop performance  measures to track the progress of your SC3 program.

Step Two: Decide what your SC3 program will look like

   •   Define the activities your program will perform.
   •   Create a timeline for starting and completing each activity.
   •   Identify the school/district personnel and potential partners who can perform SC3 activities.
   •   Identify potential roadblocks and ways to address them.
   •   Estimate the resources required to perform each activity.
   •   Identify potential sources of funding for the SC3 program.
   •   Enter into partnerships.
   •   Identify any regulations that may affect your SC3 program.

Step Three: Publicize your  SC3 program

   •   Develop and deliver an effective program message with an informative program name or slogan.
   •   Identify target audiences.
   •   Use existing communication channels to publicize your program.
   •   Consider the most effective time of the year to perform communication and publicity efforts.

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                                        Introduction:
                       A Workbook with Templates, Tips, and Techniques
    Exhibit 1:  Checklist for Building an SC3 Program (Continued)
   	
 Step Four: Put your SC3 program into action
Section 1: Program Management
     •   Begin to put your SC3 program into action.
     •   Establish and modify existing chemical management procedures.
     •   Train appropriate groups on responsible chemical management.
Section 2: Special Chemical Management Projects
     •   Perform an inventory of all chemicals and chemical products.
     •   Secure a chemical cleanout professional.
     •   Implement a green curriculum.
 Step Five: Sustain your SC3 program
        Evaluate and measure your program's progress, methods, and capabilities.
        Keep chemical management policies and procedures up-to-date.
        Conduct periodic training.
        Communicate progress and success to keep enthusiasm and awareness high.
        Maintain relationships with partners.
        Estimate staffing and funding requirements and continue to look for new funding sources for
        ongoing SC3 activities.
                              PL-
                                CHEMICAL CLEANOUT CAMPAIGN
                                        WEB SITE

                                    www.epa.gov/sc3
                                            VI

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      Chapter 1 - Evaluate your Chemical Management
            Practices and Identify SC3 Program Goals
                     Why should you evaluate your chemical management practices?
Conducting an evaluation of your school's chemical management situation, practices, and policies is
important for two reasons.  First, it allows you to identify and address any potential issues regarding
chemicals at your school (e.g., unlabelled, leaking chemical containers). Second, an evaluation will
highlight priority areas that your SC3 program can address. While this chapter focuses on conducting an
initial evaluation, we recommend that you periodically look at your school or school district's chemical
management practices to identify and address problems and consider changes to your SC3 program
priorities.
                         What does it take to get an SC3 program off the ground?
Getting the right people involved is an important first step. You want people who have an interest in school
safety, in general, and possess effective chemical management skills, in particular. Successful SC3
programs tend to have two types of leaders: a program manager and a program champion.  These  leaders
are permanent members of your SC3 Team.  They work to get others involved who have a stake in school
chemical safety, or who can help a school to evaluate, plan,  begin, and maintain an effective SC3 program.
Chapters 1 and 2 of this Workbook primarily address the activities of the program manager,  while Chapter
3 describes the important role of the SC3 program champion in creating and communicating your school's
SC3 program message(s).

This chapter provides a roadmap for creating an SC3 program tailored to the unique situation in your
school. Throughout the remainder of this chapter, we discuss, in detail, the following key activities for
creating your SC3 program:

Activity #                          Description
   1.      Find a manager and identify a champion for your SC3 program;
   2.      Identify potential stakeholders, partners, and customers;
   3.      Start building your core SC3 Team;
   4.      Conduct a visual tour to get first impressions of your school's chemical management situation,
          policies, and practices;
   5.      Perform a comprehensive evaluation of your school's chemical management situation,  policies,
          and procedures;
   6.      Identify issues and agree to SC3 program goals; and
   7.      Develop performance measures to track the progress of your SC3 program.

                                           1-1

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals


The remaining chapters in this workbook provide you with more details about how to:

         Determine how your program will address chemical management issues (Chapter 2);
         Publicize your SC3 program (Chapter 3);
         Put your SC3 program into action (Chapter 4); and
      >  Sustain your SC3 program (Chapter 5)
[ Piece
bv
Piece:
Addressina
Chemical
Issues
in
Separate
and
Manaaeable
Parts


         You may find that there are a number of things you want to address with your SC3 program.
  Don't feel that you need to try and deal with every concern right away. It may be more effective if you
  approach different issues over time, when they might have the best chance of being completed.
ACTIVITY 1 - FIND A MANAGER AND IDENTIFY A CHAMPION FOR YOUR SC3 PROGRAM

WHAT is AN SC3 PROGRAM MANAGER?

A Program Manager is the motivated individual who will lead the overall planning and day-to-day
management of your SC3 program. An SC3 Program Manager is important to getting a program off the
ground and keeping it running smoothly, because this person:

       Recruits and organizes others to help him or her set priorities, develop policies and procedures,
       and mobilize SC3 activities;
       Advises staff and students regarding policies and procedures;
       Takes responsibility for managing and tracking the SC3 program costs and savings; and
       Seeks necessary funding for SC3 projects (e.g., inventory tracking system, storage, training,
       cleanout, and disposal, when necessary).

The best candidate would be someone already involved in chemical management in some capacity.
Because you are concerned about responsible chemical management and are reading this workbook, you
may be the Program Manager.  Examples of people who would be a good fit for the role of SC3 Program
Manager include, but are not limited to:
       School or district facilities manager;
       Lead science teacher;
       Chemical hygiene officer; or
       Risk manager.
Regardless of who becomes the SC3 Program Manager, we believe the roles and responsibilities of those
involved in chemical management should be identified.  It is a good idea to outline the different roles and
responsibilities for your SC3 program to avoid any confusion or overlap. Your SC3 Program Manager will
need to know the way the school or school district gets things done and be confident in taking action.
                                             1-2

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
WHAT is AN SC3 PROGRAM CHAMPION?

An SC3 Program Champion advocates, promotes, and educates others about the positive
benefits of school chemical management programs, as well as the negative consequences of
not addressing school chemical problems.  A Champion can communicate the importance
of the issue to a senior manager at the school or district level who has a direct influence on
setting priorities, allocating budget, making policy, or launching initiatives or programs.
This senior administrator may even be your SC3 Champion. Involving someone who is
not only knowledgeable but also passionate is key to the long-term success of your SC3
program.
                                                                                   someone thatwiiimake
                                                                                    tne cause a personal
                                                                                          one.
       Case Study of a Successful Program Champion
          In 2005, Arlington Public Schools (APS) in Virginia conducted a comprehensive inventory of
   their chemical management system to determine the amounts of outdated, excess, and unknown
   chemicals that were in their facilities.  As a science teacher, Ms. Maria Johnson took the initiative to
   develop and promote materials on responsible chemical management, as well as train staff on
   chemical use, storage, and disposal.  APS used Ms. Johnson's materials as a basis for their citywide
   SC3 program. Arlington removed over 600 Ibs. of chemicals from its secondary schools, and
   continues to use Ms. Johnson's materials to avoid chemical accidents and reduce safety issues. Ms.
   Johnson's efforts and leadership helped earn  her and her school recognition from the EPA and the
   Department of Education.  She continues to champion the SC3 program in APS by seeing that new
   staff is properly trained each school year. Read more about this success story at the following EPA
   Web site:

          httD://www.eDa.qov/eDaoswer/osw/conserve/clusters/schools/success/arlinaton.htm
ACTIVITY 2 - IDENTIFY POTENTIAL STAKEHOLDERS, PARTNERS, AND CUSTOMERS

Successful SC3 programs should involve stakeholders, partners, and customers. The technical expertise for
effective chemical management may not reside in a school or school district, so it's important to involve
partners with the necessary expertise. Finding a person who is knowledgeable and who can provide specific
services or advice is important when building your SC3 program. After reading this Workbook section, try to
come up with a list of potential stakeholders and partners to get involved with your school's program.

STAKEHOLDERS

A stakeholder is a person who is concerned with keeping a school safe from chemicals. Stakeholders
should be aware of and on board with the direction of the SC3 program because they are usually in
positions of influence.  Examples of stakeholders include, but are not limited to:

       Administrators / board members;
       School principals;
       Department heads;
       Science, art, and vocational teachers;
                                              1-3

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals


       Business managers;
       Insurance representatives;
       School legal counsel;
       Facilities and custodial staff; and
       Risk managers.

PARTNERS

Partners are organizations or individuals outside of the school/district that can provide valuable assistance
to an SC3 program. As discussed in the Introduction, partners can offer assistance with a variety of
activities, including1:

       Inventorying chemicals;
       Purchasing of chemicals (e.g., how to purchase fewer and/or less toxic chemicals);
       Budgeting for chemical management;
       Developing a sustainable chemical inventory system (e.g., proper storage and labeling);
       Packaging mismanaged/unnecessary chemicals for removal;
       Removing mismanaged/unnecessary chemicals;
       Proper disposal of unnecessary chemicals;
       Developing and conducting chemical management and safety training;
       Developing and implementing a chemical management program;
       Implementing improved chemical usage strategies (e.g., changes in a school's classroom and
       maintenance practices to minimize the quantity of chemicals used in experiments);
       Developing and implementing greener cleaning practices;
       Grant-writing assistance;
       Recruiting other SC3 partners; and
       Developing performance goals and measures to gauge chemical management success.

EPA has formed partnerships with several organizations under its national SC3 program. These partners
have committed to facilitate responsible chemical management in schools.  Some of these organizations
may have  member companies in your area that could help your school or district. For help in identifying
national partners and their member companies, check the SC3 web site or contact your regional SC3
champion. Contact information for regional SC3 champions can be found on the SC3 web site under
"Where You Live" (httD://www.eDa.qov/eDaoswer/osw/conserve/clusters/schools/live.htm).
1 For a list of potential roles partners can play in your school or district, visit the EPA Partner Web site:
http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/partners.htm

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals


In addition, there may be industries, organizations, and/or individuals in your area who are not national
partners that could offer their expertise as an SC3 program partner to your school. Begin by looking at the
relationships your school already has with members of your community, such as the fire department, a local
college, or a local government agency. Check with other schools or school districts in your area. You may
discover that there are local organizations that have already partnered  with a school or district and would
be willing to help your school.  Such partners may be real assets because they have experience going
through the SC3 partnership process.  Here are some organizations/agencies to consider as you look for
partners for your SC3 program:

        State educational and environmental agencies;
        Trade and professional organizations;
        National companies and local businesses (e.g., chemical suppliers, manufacturers, waste
        handlers, companies with community programs);
        Colleges and universities;
        Fire and police departments;
        Parents;
        School service organizations;  and
        Local schools and/or districts that have an SC3 program.
        Case Study in Successful Partnership Involvement
           In 2005 and 2006, the Northwest Tri-County Intermediate Unit, a school service organization in
   Pennsylvania, began the Safer Schools Initiative to develop chemical inventories, conduct cleanout and
   training, and develop school chemical management policies. The Initiative used existing information from the
   local health department to help determine the extent of the problem in the schools.  A representative from a
   local pollution prevention organization also educated the Intermediate Unit on the problems in the schools.
   The Initiative used the expertise and resources of the Northwest Regional Office of the Pennsylvania
   Department of Environmental Protection to assist with reviewing chemical inventories. This review also helped
   to mitigate costs by identifying substances that may not require hazardous waste disposal.

           The program successfully removed 267 pounds of hazardous material from 16 schools, positively
   affecting 11,469 students.  The program also included information about responsible chemical management
   activities, such as the use of an in-service training  program (teachers educated about chemical safety and
   green chemistry) and the establishment of stronger relationships between schools and  businesses. The
   intermediate unit will continue to provide technical  assistance and training as needed.
CUSTOMERS

Customers are individuals interested in having a safe and healthy school, such as students, teachers, staff,
and parents.

People working in or attending schools are obvious customers. Parents are important customers because
they entrust schools to provide a safe learning environment for their children.  Parents with the necessary
skills and resources can also be key partners to your program.
                                                1-5

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals


ACTIVITY 3 - START BUILDING YOUR CORE SC3 TEAM

To create a chemical management program that is effective and sustainable, the SC3 Program Manager
should get people involved and committed to the effort. In addition to recruiting school/district employees, it
is important to encourage the involvement of key stakeholders and potential partners. An SC3 program
involves a team of individuals that collectively have direct involvement with or knowledge of every aspect of
chemical management at a school, from purchasing chemicals to their ultimate disposal.  Team members
who are most helpful are those with knowledge in one or more of the following areas:

       School management practices, including purchasing;
       Curriculum development;
       Chemical management safety and training;
       Health concerns;
       Legal and regulatory aspects; and
       Risk management.

If your team doesn't have all  of this experience and knowledge, use the team you have to start the program
and add people who can contribute other experiences or knowledge later.  We suggest that the core team
not grow too large or it could become difficult to make decisions and solve  problems.

You may have existing teams already in place in your school/district that have some of the necessary
expertise.  These teams may serve as the basis for building your core team.  Examples of teams that may
already exist at your school/district include:

       Your school health or wellness team;
       Crisis planning team;
       Indoor Air Quality Tools for Schools team; or
    > Other groups that focus on environmental health in school.
ACTIVITY 4 - CONDUCT A VISUAL TOUR TO GET FIRST IMPRESSIONS OF YOUR SCHOOL'S CHEMICAL
             MANAGEMENT SITUATION, POLICIES, AND PRACTICES

One way to quickly determine if your school's chemical management needs improvement is to
take a visual tour of the school, especially those areas where chemicals or products
containing chemicals are stored.  We suggest that at least two people from your team who
are familiar with chemicals conduct the evaluation. As you tour the school, be on the
lookout for sights and smells that may indicate improper chemical management
practices or examples where existing policies and procedures are not being followed.       Be sure to take notes and
Chemicals should be handled or moved as little as possible.  Chemical containers that        pictures during your
are leaking or distorted should not be touched.  Bring a notepad and a camera (if           visual tour so that y°u'
available) with you on the visual tour to record your observations and impressions.  Also,      yo ,ur sc^ T.eam'and
     u       u     u-i     r    j   i    L.  i  i  £cr  it.  •    •  •    L.  i      i       administrators have
in each area where chemicals are found, ask school staff for their opinion about current       enough detai|S upon
conditions and/or previous situations where chemicals may have been improperly            which to set program
stored, handled, or otherwise appropriate for attention.                                   priorities and respond to
                                                                                   a potential chemical
                                                                                  management situation.
                                              1-6

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
A chemical may be appropriate for attention when it is:

       Stored in a container that is in poor condition (e.g., corroded, has crystals growing around the cap);
       Stored in inappropriate containers, such as buckets or reused food containers;
       Expired;
       Unidentified or not clearly labeled with the chemical name, date, and storage and handling
       requirements;
       Stored near incompatible chemicals (alphabetical storage is also inappropriate);
       Stored on deteriorating, unstable, or inappropriate shelving (e.g., flammables stored on wooden
       shelves, corrosives stored on metal shelves);
       Unsecured; or
       Unneeded or in surplus quantities.

The status of a chemical's management can be evaluated relatively quickly and easily. The visual evaluation
doesn't have to include a detailed inventory of all chemicals - a chemical inventory can be developed later
when you put your SC3 program into action (see Chapter 4). However, if you see conditions that indicate an
obvious chemical management problem, let your supervisor know that it should be addressed as soon as
possible.  Activity 5 in this chapter describes a more comprehensive process for fully evaluating your school's
chemical management situation,  policies, and practices so that you can get a better handle on pressing
issues.

We suggest that you brief the school or district administrators about what you observed during your visual
tour.  Try to use this information to get people in authority to support the development of an SC3 program. It
is possible that school management may want the SC3 program to first address some particular issues
identified from the visual tour.  If one of the first orders of business of the SC3 program is to evaluate the
need for a chemical cleanout, please refer to Chapter 4 for guidance regarding how to get qualified personnel
involved.
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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals


ACTIVITY 5  -  PERFORM A COMPREHENSIVE EVALUATION OF YOUR SCHOOL'S CHEMICAL MANAGEMENT
               SITUATION, POLICIES, AND PROCEDURES
                                                                                             ,
The previous activity - conducting a visual tour of the school - is a good start, but to get a
better understanding of your school's chemical management situation, you will have to dig a
little deeper.  In performing a comprehensive evaluation of your school's chemical
management policies and procedures, you should:
                                                                                       The comprehensive
        Collect:                                                                       evaluation of your school's
          o Information about the chemical management situation,  policies,  and             chemical management
            procedures at your school;                                                   situation policies, and
            ,. .   . .      u    •    •    t  iu      u       j j-      i   t  u   •   i           practices should be a team
          o Materials, such as invoices for the purchase and disposal of chemicals;           effort |ed b  the SC3
          o Information about science and art curricula; and                                 Program Manager.
          o Information about chemicals used to keep the school clean, etc.
        Look at your school's SC3 policies and procedures to see how clear, complete, and up-to-date they
        are, as well as how the policies and procedures are being followed;
        Talk to staff involved in any phase of the "chemical management lifecycle" (i.e., anyone involved in
        the purchase, storage, inventory,  use, and disposal of chemicals and products containing
        chemicals); and
        Conduct a more in-depth analysis of the areas  identified as a potential concern during the visual
        tour (Activity 4).  If you noticed something in the visual tour, dig  a little deeper and gather more
        information.  The following paragraphs and Exhibit 1-1 give you some more details on this.
       Case Study of Involving Partners in a School Evaluation   _
       The Illinois Waste Management and Research Center and the Illinois Environmental Protection Agency (IEPA)
provide free facility chemical management assessments (FCMA) to Illinois schools through the Illinois Sustainable
Schools Project. FCMAs consist of a review of chemical inventories, as well as storage, management, and disposal
practices for both laboratory and facility chemical use. These assessments help in the use of an inventory system to
track purchase, quantity, and disposal of chemicals used for facility maintenance and curricula at participating schools.
These assessments also assist with the segregation, inventory, and packaging of chemicals identified for disposal. The
lEPA's Green Schools Program can be found at the following Web site:

                          http://www.epa.state.il.us/p2/green-schools/index.html
                                                1-8

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals


Exhibit 1-1 provides an example of a completed worksheet for evaluating a school's chemical management
situation, policies, and procedures.  Note how the worksheet organizes questions for each phase of the
chemical management lifecycle. The topics covered in the worksheet include all of the SC3 themes
conveyed in the  "molecule graphic" (see the Introduction of this Workbook); the lone exception  is the
"Leadership and Resources" theme which we addressed in Activity 1 earlier in this chapter and later on in
Chapters 4 and 5.

Worksheet 1 -1 in the Additional Tools and Examples section at the end of this chapter can be used to
conduct a comprehensive evaluation of your school's chemical management situation, policies, and
procedures, as well as  answer the questions to the best of your ability. Whenever you answer NO to any of
the questions  on the comprehensive evaluation worksheet, you should elaborate by capturing notes in  the
corresponding 'Description of Conditions' section. Share the completed worksheet with your SC3 Team to
seek agreement on the areas to be addressed in your SC3 program We suggest you pay particular
attention to those program development areas or topics for which you may need stakeholder input or the
involvement of partner(s) with relevant expertise  and capabilities.
Exhibit 1-1: Evaluating Your School's Chemical Management Situation, Policies, and
Procedures (Example)
Question
Answer
(Circle One)
Description of Conditions
Purchasing
Does my school have a purchasing policy to
evaluate chemicals before they come into the
school?
Does one person or a department do chemical
purchasing?
Are chemicals purchased for expected use within
the calendar or fiscal year?
Does my school have a "green" or "microscale"
chemistry curriculum?
Have toxic chemicals been replaced with less toxic
alternatives?
YES /NO
YES /NO
YES /NO
YES /NO
YES /NO
Chemicals are purchased in accordance with budgetary
and curriculum needs.
Chemicals often purchased by individual personnel and
teachers when they need them.
Purchases are made in bulk to get a price discount;
some chemicals purchased may last us four or five
years.
We have a standard chemistry curriculum with no
particular preference for less toxic chemicals. Students
often use toxic chemicals in experiments; they wear
goggles.
1 don't recall an instance where we changed the
chemicals we purchased.
                                              1-9

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        Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
Exhibit 1-1: Evaluating Your School's Chemical Management Situation, Policies, and
Procedures (Example, cont'd)
Question
Answer
(Circle One)
Description of Conditions
Storage
Does the school have a policy or set of procedures
for storing chemicals (e.g., a Chemical Hygiene
Plan)?2
Is there a staff member assigned to manage every
chemical storage area?
Are stored chemicals kept locked?
Are chemicals accessible only to qualified
handlers?
Do all chemicals have up-to-date Material Safety
Data Sheets (MSDS)? 3
Are all MSDSs kept together in a common
location?
Are all chemicals labeled, including name,
purchase/expiration dates, and storage
information? 4
Are chemicals stored according to type and group
(not alphabetically)? 5
YES /NO
YES /NO
YES /NO
YES /NO
YES /NO
YES /NO
YES /NO
YES /NO
No policy but we make sure to tightly close all lids.
Falls to head of chemistry department; no one is
responsible for checking storage areas in the summer.
Chemistry and custodial closets are locked at night but
open during the day; art and ceramic studio is always
open.
Chemistry students allowed into storage during the day;
art supplies available to use by anyone.
Only the newest chemicals have this documentation;
sheets don't always reside where chemicals are stored.
Custodian often throws them away; art teacher has
some sheets in desk; chemistry closet has current
sheets with container on shelf.
Some glass jars in chemistry closet just have
handwritten name; custodian has spray bottles with no
labels.
Liquids in the chemistry lab closet are stored together
alphabetically.
Inventory
Is there a policy or set of procedures for identifying
out-of-date chemicals?
Is there a comprehensive list of chemicals stored
onsite for all departments?
Are incoming chemicals added to a comprehensive
list?
YES /NO
YES /NO
YES /NO
We follow the expiration or "use by" dates on containers
that include this information.
Chemicals are purchased as needed; inventories
completed only to determine next purchase; lists not
kept.
No such list exists.
2See the Occupational Safety and Health Administration's (OSHA) Laboratory Standard containing information on a Chemical
Hygiene Plan (CHP): http://www.osha.gov/pls/oshaweb/owadisp.show document?p table=standards&p  id=10106
3 Figure 1-1 has the first page of a blank sample MSDS from OSHA; the following link:
http://www.osha.gov/dsg/hazcom/msdsformat.html
4 See Figure 1-2 for an illustration of a chemical safety label from the Dana Farber Cancer Institute (DFCI).
5 For a  more definitive reference,  see pages 19-23 of the School Chemistry Laboratory Safety Guide, produced by the U.S.
Consumer Product Safety Commission (CPSC), the Centers for Disease Control and Prevention (CDC), and the National
Institute for Occupational Safety and Health (NIOSH), available in PDF form at: http://www.cdc.gov/niosh/docs/2007-107/
                                                    1-10

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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
Exhibit 1-1: Evaluating Your School's Chemical Management Situation, Policies, and
Procedures (Example, cont'd)
Question
Answer
(Circle One)
Description of Conditions
Use
Does my school have a Chemical Hygiene Plan or
some kind of plan for responding to chemical
emergencies?
Are students and staff adequately trained to handle
the chemicals they interact with?
Do areas where chemicals are used or handled
have up-to-date safety guides and functioning
safety equipment?
YES /NO
YES /NO
YES /NO
Attention is focused on rapid response to violence and
fire emergencies.
Only chemistry teachers and custodians receive
training; students are briefly instructed on chemical
safety in lab classes.
No safety guides present in chemistry labs; students
must share goggles for experiments.
Disposal
Are all hazardous/toxic wastes disposed of
according to federal/state guidelines (e.g., NOT
'down-the-drain')?
Are used or outdated chemicals disposed of within
a reasonable timeframe (e.g., not 'stockpiled' in
storage rooms)?
Does the school retain a waste removal specialist
to handle hazardous/toxic chemicals after use
and/or outdated chemicals?
YES /NO
YES /NO
YES /NO
Custodians collect empty and unwanted containers and
drive to transfer station, when necessary; we don't
know what guidelines apply to us.
Old and unneeded chemicals are stored near rear
loading dock until custodian transports to transfer
station.
We sometimes ask the chemical sales rep to take away
stuff.
                                      1-11

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       Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
                 Figure 1-1: Blank Material Safety Data Sheet (MSDS) (Example)
Material Safety Data Sheet
May be used to comply with OSHA's Hazard
Communication Standard, 29 CFR 1910 1200. Standard
must be consulted for specific requirements.
U.S. Department of Labor
Occupational Safety and Health Administration
(Non-Mandatory Form)
Form Approved
OMB No. 1218-0072
IDENTITY Cas Used on Label and List)
Note: Blank spaces are not permitted. If any item is not
     applicable or no information is available, the space
     must be marked to indicate that.
Section I
Manufacturer's name
Address (Number, Street, City, State and ZIP Code)


Emergency Telephone Number
Telephone Number for Information
Date Prepared
Signature of Preparer (optional)
Section II—Hazardous Ingredients/Identity Information
Hazardous Components (Specific Chemical Identity, Common Name(s))
                                                      OSHA PEL
                                                                   ACGIH TLV
                            Other Limits
                           Recommended
                                                                                               % (optional)
Section III—Physical/Chemical Characteristics
Boiling Point
Vapor Pressure (mm Hg)
Vapor Density (AIR = 1)



Specific Gravity (H20 = 1)
Melting Point
Evaporation Rate (Butyl Acetate = 1)



Solubility in Water
Appearance and Odor
Section IV—Fire and Explosion Hazard Data
Flash Point (Method
Used)
Flammable Limits
LEL
UEL
Extinguishing Media
Special Fire Fighting Procedures
Unusual Fire and Explosion Hazards
(Reproduce locally)
                                    OSHA 174 Sept. 1985
                                                    1-12

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           Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
                                        Figure 1-2:  Chemical Safety Label
                                                    FLAMMABL
                                        xtremely flamable
                                        Ignites at normal
                                        •temperatures
                                      2 Ignites •when moderately
                                        heated
                                      1  Must be preheated to bun
                                      0 Vill not burn
                        HEALTH
                        to en-ter vapor or
                        Liquid
                      3 Extr9mely dangerous
                        use full proctective
                        clothing
                      2 Hazardous - Use
                        breathing
                        apparatus
                      1  Slightly hazardous
                      0 Like ordinary material
                                                            REACTIVITY

                                                      4 May detonate - Vacate
                                                        area if materials are
                                                        exposed to fire
                                                   3 Strong shock or heat may
                                                     detonate - Use monitors
                                                      from behind explosive
                                                        resistant barriers:
                                                          2 Violent chemical
                                                             change possible
                                                             - Use hose
                                                             streams from
                                                             distance
                                                        1 Unstable-if heated
                                                          - Use normal
                                                          precautions
                                                        0 Normally stable
  One helpful practice in
maintaining Material Safety
  Data Sheets is to take a
 picture of each chemical
container and attach it to its
  corresponding MSDS.
More information on chemical labeling can be found at the links listed below:

   http://research.dfci.harvard.edu/ehs/Chemlabels/chemical  labels.htm 6

                                   And

                http://www.cdc.gov/niosh/docs/2007-107/7
             Helpful Link
              The Washington State Department of Ecology's Hazardous Wastes and Toxics Reduction Program offers free
      downloadable hazardous waste labels:

                                      http://www.ecy.wa.gov/programs/hwtr/hw labels
       6 From the Environmental Health and Safety Office at the DFCI.
       7 School Chemistry Laboratory Safety Guide from CPSC, CDC, and NIOSH.
                                                         1-13

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
                  How do I figure out the issues or concerns that my SC3 program needs to
                                                   address?
There are many different forms that an SC3 program can take.  It all depends on the situation at your
school or district.  For example, an SC3 program may place a high priority on improving chemical
purchasing, while another may focus on chemical storage.

The results of your visual tour and the comprehensive evaluation (using Worksheet 1 -1) should help your
SC3 Team identify and characterize areas that need to be addressed or improved.  If your school or school
district already has an SC3 program, the comprehensive evaluation worksheet can still be useful in
determining areas to improve or new issues to address. Remember that you can begin an effective
program by addressing only a few issues at a time.

Your school might not have a formal SC3 program and team, but still has made progress in establishing
safer chemical management policies and procedures. Regardless, by conducting the evaluation activities
outlined in  Activities 4 and 5 of this chapter, your SC3 Team should have enough insights and information
upon which to develop goals that will guide your SC3 program.
ACTIVITY 6 -  IDENTIFY ISSUES AND AGREE To SC3 PROGRAM GOALS

Establishing SC3 program goals is an important step in making your school a safer place. Keep in mind
that assigning specific timeframes to goals will allow you to stay on track with objectives. By setting
concrete deadlines, the SC3 Team can prioritize and plan activities that work for your school.
                 How do I develop goals for my responsible chemical management program?
Setting goals for a program or project may be new to some on the team. The following tips will help guide
the goal-setting activities:

       Look at your self-evaluation and set goals that address its main concerns;
       Consider insights and concerns from stakeholders, customers, and potential partners;
       Set goals that can be measured;
       Set reasonable goals that can be achieved within the desired timeframe; and
    >  Make sure your goals lead to a sustainable, successful SC3 program.
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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
It is important to include stakeholders in setting your SC3 program goals. Because stakeholders have a
vested interest in safe and clean schools, their perspectives can guide the nature and priority of the goals
for your SC3 program. To avoid overlooking anyone's input or support, we suggest that all stakeholders be
invited to share their expectations, needs, and capabilities with your SC3 Team at this stage.

We suggest that the goals of your SC3 program match the issues or areas of concern identified in your
comprehensive evaluation worksheet (Worksheet 1-1).  Use this worksheet to define program goals with
your SC3 Team. Exhibit 1-2 provides an example of goals that match each issue or area of need.  Use
Worksheet 1 -2 in the Additional Tools and Examples section at the end of this chapter to develop your SC3
program goals.  To fill out the "Issue / Area of Need," on the goal-making worksheet,  refer to the completed
Worksheet for Evaluating Your School's Chemical Management Policies and Practices [Worksheet 1-1] and
any input from your SC3 Team, stakeholders, customers, and potential SC3 partners.
 Exhibit 1-2: Defining SC3 Program Goals that Address Issues /Areas of Need (Example)

SC3 Program
Component
Purchasing

Storage


Inventory

Use


Disposal

Issue / Area of Need
(1) My school does not have a
chemical purchasing policy.

(1) Some stored chemicals are
unlabeled.
(2) Storage areas are not secured.

(1) There is no way to know how many
and what type of chemicals are
present in the school.

(1) Our school has no contingency
plan for a chemical emergency.
(2) Chemistry curriculum uses many
chemicals that are known
carcinogens.

(1) Chemicals are routinely poured
down drain and put in trash.

Program Goal
(1) Establish purchasing policy that avoids 'bulk' ordering and
emphasizes less or non-toxic alternative chemicals.
(2) Centralize chemical purchasing at district level.

(1) Establish policy requiring all onsite chemicals be labeled
according to state regulations.
(2) Have copies ofMSDSs for all chemicals stored onsite be
kept near chemicals and in principal's office.
(1) All chemical storage areas shall be locked at all times with
access limited to trained teachers and facilities personnel.

(1) Establish an inventory policy and set of procedures.
(2) Establish chemical inventory database that is updated
when chemicals are purchased, used, or disposed of.

(1) Write an Emergency Response Plan within six months.
(2) Hold yearly training courses for students and staff on
proper chemical use and emergency procedures.
(1) Work with chemistry department to phase out experiments
using carcinogenic chemicals.
(2) Begin using a "green chemistry" curriculum in the next 2
years.

(1) Develop disposal procedures for each chemical type used
in the school.
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   Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
      Tip: Consider Developing a Mission Statement
       To set a long term vision for your school or district's SC3 program, you may consider writing a mission
statement that briefly declares what your SC3 program aims to accomplish. Examples of a simple mission statement
might be: The purpose of SC3 is to reduce chemical exposures and improve chemical management' or, 'SC3 aims to
ensure that all schools in the district are free from hazards associated with potentially harmful chemicals'.
ACTIVITY 7 - DEVELOP PERFORMANCE MEASURES TO TRACK THE PROGRESS OF YOUR SC3 PROGRAM

The last activity in this section is to work on ways to measure progress towards accomplishing your SC3
program goals. This is important because success should be measured. "Performance measures" are
what programs use to gauge progress towards goals. Developing measures of program success can be
difficult, so we provide examples of metrics used by established SC3 programs. The key in developing
performance measures is to tie them directly to goals by asking, "Will this performance measure
demonstrate progress (or lack thereof) towards a specific goal or set of goals?"

The challenge in developing performance measures is to identify meaningful ways to demonstrate program
progress that are straightforward and  reflect your school's chemical management priorities. We suggest
that they be clear and understandable so that people not familiar with the SC3 program can readily
understand the progress being made. It's okay that some performance measures you  develop may be
exclusively for management purposes, while others are for reporting to stakeholders, partners and
customers. Having concrete evidence of program success is also beneficial to
the Program Champion in garnering support when seeking additional resources
and funding. Some typical measures  of progress for a school's chemical
management program include, but are not limited to:

       Amount, by type and weight, of  chemicals removed;
       Number of training sessions completed;
       Number of teachers, facilities personnel, and administrators trained; and
       School populations protected or serviced.

Keep in mind that measurements of changes in  behavior are an important
indicator of program success. Evaluations of how well training exercises
improve a staffs knowledge and expertise in chemical handling is an example of
measuring positive changes in attitudes  towards chemical safety.

All of the worksheets previously discussed in this section should help you when developing your
performance measures. Exhibit 1-3 on the following page is an example of a completed worksheet for
capturing performance measures that tie to specific goals. Worksheet 1-3 in the Additional Tools and
Examples section at the end of this chapter can be used to define your performance measures. It's okay if
your worksheet does not look like the  one in the example, just try to be as detailed as possible.
                                                                             Measure progress by
                                                                              department, when
                                                                          appropriate. Sometimes a little
                                                                           competition can be good for
                                                                           morale and spur progress.

                                                                           eachdepartment to reduce
                                                                          chemical purchasing, storage,
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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
Exhibit 1-3: Developing Performance Measures Based on Desired Goals (Example)
Program
Component

Purchasing



Storage


Inventory

Use


Disposal
Goal

(1) Establish centralized purchasing
policy that avoids buying 'bulk' orders.
(2) Identify alternative chemicals for
each hazardous chemical currently
used.
(3) Use less toxic/hazardous
alternatives.

(1) Enact policy requiring all onsite
chemicals to be labeled according to
state regulations.
(2) All chemical storage areas to be
locked at all times unless accessed by
trained staff.

(1) Establish chemical inventory
database which accounts for all
chemicals, their information, and
incoming and outgoing product.

(1) Hold yearly training courses that
prepare students and staff for day-to-
day chemical safety and emergency
planning.
(2) Work with chemistry department to
phase out experiments requiring
carcinogenic chemicals.

(1) Secure a partner or chemical
cleanout professional to dispose of
'waste' chemicals.
Deadline

2 years
2 Years
1 Year

6 mo.
1 Year

2 Years

1 Year
1Year

1Year
Performance Measure

Number of bulk orders made then vs.
now [every ordering cycle].
Number (and %) of alternative
chemicals substituted for use.
Number and quantity of
toxic/hazardous chemicals on invoice
then vs. now [every ordering cycle].

Number (and %) of passed
"inspections" performed by the SC3
Program Manager.
Number (and %) of passed
"inspections" performed by the SC3
Program Manager.

Ratio of chemicals in physical
inventory vs. not in database.

Number of students and staff
successfully trained each year.
Number (and %) of lesson plans
redesigned to feature less harmful
alternatives.

Number (and %) of unnecessary or
outdated hazardous chemical
containers removed from onsite
storage.
                                      1-17

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
                                                   Summary
The activities for initiating your SC3 program are:

Activity #                           Description

    1.      Find a manager and identify a champion for your SC3 program;
    2.      Identify potential stakeholders, partners, and customers;
    3.      Start building your core SC3 Team;
    4.      Conduct a visual tour to get first impressions of your school's chemical management situation,
           policies, and practices;
    5.      Perform a comprehensive evaluation of your school's chemical management situation, policies,
           and procedures (Worksheet 1-1);
    6.      Identify issues and agree to SC3 program goals (Worksheet 1-2); and
    7.      Develop performance measures to track the progress of your SC3 program (Worksheet 1 -3).

This first chapter walked you through the first stages of preparing to launch an SC3 program at your school
or district.  Chapter 2 will assist you in determining what your SC3 program can look like and what it will do
to help develop and maintain responsible chemical  management practices.
                                       VISIT THE SCHOOLS
                                  CHEMICAL CLEANOUT CAMPAIGN
                                           WEB SITE
                                      www.epa.gov/sc3
                                             1-18

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    Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
                                       Additional Tools and Examples
This section contains some helpful links and blank exhibit worksheets to help you evaluate your school or
district's chemical management situation, develop goals for your SC3 program, and create performance
measures to measure progress. For ideas regarding the kinds of information you might capture on these
worksheets, refer to the exhibits containing examples earlier in this chapter.

  These EPA Web sites provide a variety of links to resources related to healthy chemical management in
  schools:
        SC3 Toolkit
        SC3 Resources
        Healthy Schools' Chemical Management Regulation Resources
        Healthy School Environments Assessment Tool (HealthySEAT)
    >  OSHA Standard for Occupational Exposure to Hazardous Chemicals in Laboratories
  For more information on MSDS:
        OSHA Recommended Format
    >  EPA's  SC3 Links
Worksheet #                               Title
    1-1        Evaluating Your School's Chemical Management Situation, Policies, and Procedures
    1 -2        Defining SC3 Program Goals that Address Issues / Areas of Need
    1-3        Developing Performance Measures Based on Desired Goals
                                            1-19

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      Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
  Worksheet 1-1: Evaluating Your School's Chemical Management Situation, Policies, and
                                          Procedures
               Question
                                            Answer
                                           (Circle One)
                                                                Description of Conditions
                                           Purchasing
Does my school have a purchasing policy or an
approved chemical list?
                                            YES/NO
Does one person or a department do chemical
purchasing?
                                            YES/NO
Are chemicals purchased for expected use
within the calendar or fiscal year?
                                            YES/NO
Does my school have a "green" or "micro-scale"
chemistry curriculum?
                                            YES/NO
Have toxic chemicals been replaced with less
toxic alternatives?
                                            YES/NO
                                            Storage
Does the school have a policy or set of
procedures for storing chemicals (e.g., a
Chemical Hygiene Plan)?
                                            YES/NO
Is there a staff member assigned to manage
every chemical storage area?
                                            YES/NO
                                               1-20

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      Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
  Worksheet 1-1: Evaluating Your School's Chemical Management Situation, Policies, and
                                      Procedures (cont'd)
               Question
 Answer
(Circle One)
                                                                Description of Conditions
                                        Storage (cont'd)
Are stored chemicals kept locked?
YES/NO
Are chemicals accessible only to qualified
handlers?
YES/NO
Do all chemicals have up-to-date Material Safety
Data Sheets?
YES/NO
Are all Material Safety Data Sheets kept
together in a common location?
YES/NO
Are all chemicals labeled, including name,
purchase/expiration dates, and storage
information?
YES/NO
Are chemicals stored according to type and
group (not alphabetically)?
YES/NO
                                               1-21

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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
Worksheet 1-1: Evaluating Your School's Chemical Management Situation, Policies, and
Procedures (cont'd)
Question
Answer
(Circle One)
Description of Conditions
Inventory
Is there a policy or set of procedures for
identifying out-of-date chemicals?
Is there a comprehensive list of chemicals
stored onsite for all departments?
Are incoming chemicals added to a
comprehensive list?
YES /NO
YES /NO
YES /NO




Does my school have a Chemical Hygiene Plan
or some kind of plan for responding to chemical
emergencies?
Are students and staff adequately trained to
handle the chemicals they interact with?
Do areas where chemicals are used or handled
have up-to-date safety guides and functioning
safety equipment?
YES /NO
YES /NO
YES /NO



                                      1-22

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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
Worksheet 1-1: Evaluating Your School's Chemical Management Situation, Policies, and
Procedures (cont'd)
Question
Answer
(Circle One)
Description of Conditions
Disposal
Are all hazardous/toxic wastes disposed of
according to federal/state guidelines (e.g., NOT
'down-the-drain')?
Are used or outdated chemicals disposed of
within a reasonable timeframe (e.g., not
'stockpiled' in storage rooms)?
Does the school retain a waste removal
specialist to handle hazardous/toxic chemicals
after use and/or outdated chemicals?
YES /NO
YES /NO
YES /NO



                                      1-23

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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
 Worksheet 1-2: Defining SC3 Program Goals that Address Issues /Areas of Need
SC3 Program
Component
Purchasing


Storage


Inventory


Use


Disposal

Issue / Area of Need
(1)
(2)

ft)
(2)

(1)
(2)

ft)
(2)

ft)
(2)
Program Goal














                                    1-24

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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
Worksheet 1-3: Developing Performance Measures Based on Desired Goals
Program
Component

Purchasing




Storage



Goal










Deadline










Performance Measure










                                      1-25

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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
Worksheet 1-3: Developing Performance Measures Based on Desired Goals (cont'd)
Program
Component

Inventory




Use



Goal










Deadline










Performance Measure










                                      1-26

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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
Worksheet 1-3: Developing Performance Measures Based on Desired Goals (cont'd)
Program
Component

Disposal



Goal





Deadline





Performance Measure





                                      1-27

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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
                                      1-28

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Chapter 2 - Decide What Your SC3 Program Will  Look Like
                         Why should I define key components of my SC3 program?
As with any new major project, it makes sense to break things down into manageable pieces. In Chapter 1,
we suggested that you define SC3 program goals that match the major elements of responsible chemical
management outlined in the molecule graphic.
         LtADtRSHIP & RLSOURCtS           CHtMICAL INVLNIOKY
                                           I  CHLMICAL CLEANOUT & DISPOSAL  j        [ PURCHASING '
                                                            POLLUTION PREVENTION
i PREVENTION
                         COMMUNICATION & TRAINING

             	
             [    SPILL RESPONSE   ~]
This chapter helps you define the activities and methods you can use to accomplish your SC3 goals. SC3
programs come in all shapes and sizes, but at a minimum, we suggest that you design your program to:

    1.  Conduct periodic chemical inventories;
    2.  Plan and budget for chemical purchases, management and disposal;
    3.  Establish environmentally preferable purchasing practices;
    4.  Encourage school staff to use the smallest amounts of the least hazardous chemicals; and
    5.  Offer chemical management and safety training for school staff.

Ideally, your program will develop policies and procedures to promote responsible chemical management.
In Chapter 4 (Activity 2: Establish and modify existing SC3 Policies and Procedures), we guide you through
the process of developing a "chemical management plan" of policies and procedures geared towards the
needs of your school or district.
                                            2-1

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                    Chapter 2 - Decide What Your SC3 Program Will Look Like


To get started on defining what your SC3 program can look like, you can refer to the Chapter 1 worksheets
that help you to develop SC3 program goals. The next step is to develop a plan of action that can help you
achieve each of those goals. Here is a list of activities for establishing your SC3 program:

Activity #                            Description
    1.            Define the activities your program will perform;
    2.            Create a timeline for starting and completing each activity;
    3.            Identify the school/district personnel and potential partners who can perform SC3 activities;
    4.            Identify potential roadblocks and ways to address them;
    5.            Estimate the resources required to perform each activity;
    6.            Identify potential sources of funding for the SC3 program;
    7.            Enter into partnerships; and
    8.            Identify any regulations that may affect your SC3 program.

Once you have defined the  components of your SC3 program, you should refer to:
        Chapter 3 for crafting an SC3 message and conducting  communication efforts; and
        Chapter 4 for ideas on  how to put your program into action.
                        How can I determine if my SC3 program goals can be achieved?
In Chapter 1, we provided a template that you can use to develop SC3 program goals and assign a timeframe for
accomplishing each goal. It's now time to answer the question "can each SC3 program goal be achieved within
the desired timeframe?" The best way to go about answering this question is to focus on the milestones or goals
that your school wants to achieve in the  upcoming year. To do this, we suggest that your SC3 Team roughly
estimate the needed labor and out-of-pocket costs to reach these annual milestones; we'll give you more details
on this step in Activity 5 later on in this chapter.

Some key points to remember as you begin to set your timeframe for accomplishing your goals are:

        Take care not to overburden any particular team member, school/district employee, or partner with SC3
        responsibilities for the upcoming year.
        Identify ways that potential partners can contribute to achieving the goal by providing funds and in-kind
        services.
        If you can find the necessary personnel to perform SC3 activities and have the budget to cover out-of-
        pocket costs, then you have a realistic plan for achieving milestones for the upcoming year.
        Your SC3 Team may need to adjust timeframes for accomplishing some goals if the necessary staff time
        and budget are not available for the upcoming year.
        Try to recognize current year and out-year budget and personnel constraints early on and  make the
        necessary adjustments to your team, deadlines, and SC3 budget requests.
                                              2-2

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                    Chapter 2 - Decide What Your SC3 Program Will Look Like


ACTIVITY 1 - DEFINE THE ACTIVITIES YOUR PROGRAM WILL PERFORM

In most cases, there is more than one way to achieve a goal.  Your team should evaluate various
approaches for achieving a goal and adopt the best approach for your school.

First, identify some basic approaches for a specific problem or issue. For example, if one of your SC3
goals is to "purchase less toxic chemicals," there are a variety of ways to go about it, such as:

       Determining if a chemical  is really needed to do the job or if there are non-chemical methods to
       accomplish the task;

       Identifying appropriate less-toxic alternatives to chemicals in use;

       Evaluating using smaller quantities of toxic chemicals when alternatives are not readily available;

       Pushing for changes in district-level purchasing;

       Creating an 'accepted use' list for chemicals allowed in your school; or

    >  Some combination of the above.
Second, for each approach, we recommend that you evaluate what expertise is needed and who has this
expertise.  Consider whether you have the necessary expertise "in-house" or if it makes sense to have the
SC3 activity be partially or wholly performed by another organization or vendor. Explore how to go about
finding the skills from other sources, such as enlisting partners that have the necessary skills or hiring a
chemical management specialist (see Chapter 4).

Third, define the activities that could be undertaken to achieve each goal. For each set of activities, we
suggest that you adopt performance measures to track progress towards achieving a goal. Exhibit 2-1
contains an example set of activities designed to achieve a specific goal: "Purchase less toxic chemicals."
This exhibit also contains examples of performance measures that can be used to gauge progress towards
achieving the goal of purchasing less toxic chemicals. Worksheet 2-1 in  the Additional Tools and Examples
section at the end of the chapter can be used to capture the activities and performance measures that your
team agreed to for each SC3  program goal.
                                              2-3

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                    Chapter 2 - Decide What Your SC3 Program Will Look Like
Exhibit 2-1 : Developing SC3 Activities and Performance Measures to Achieve Program Goals
(Example)
Example SC3 Program Goal: Purchase Less Toxic Chemicals
Activity
/. Have a face-to-face meeting with all school/district personnel who purchase
chemicals to map out chemical usage and buying patterns.
ii. Determine which chemicals are toxic and need to be replaced and which are
toxic and, given no available alternatives, must have stringent handling
practices. 1
Hi. Determine if chemicals that pose health and safety risks are really needed to
complete a job, or if replacement with safer alternatives or non-chemical
solutions is an option.
Iv. Research possible non-chemical alternatives before consulting with
chemical vendors, as they may have a bias towards using chemicals.
v. Have chemistry, vocational, and art department heads, and the lead
custodian or risk manager meet with a chemical supplier to discuss alternatives
to hazardous chemicals currently used by the school.
vl. Each department evaluates the list of less-hazardous alternatives that would
reduce potential harmful exposures and lower disposal costs.
vii. If possible, each department creates a table of price comparisons and a
chemical use plan that estimates chemicals (and budget) needed for the
following year. Consider the entire lifecycle when estimating cost.
v'ii'i. Consult with person or department in charge of purchasing alternative
chemicals and reduced quantities of toxic chemicals to purchase.
Performance Measure(s)
a. Number of containers or quantity of
toxic/hazardous chemicals listed on chemical
purchasing invoices [measured every ordering
cycle].
b. Number and quantity of alternative chemicals
purchased [measured every ordering cycle].
c. Number of chemicals changed out for less
hazardous alternatives [measured every
ordering cycle].
ACTIVITY 2 - CREATE A TIMELINE FOR STARTING AND COMPLETING EACH ACTIVITY

We suggest setting realistic deadlines for the completion of SC3 activities so that assigned personnel are
motivated to  stay on track and achieve goals. For ongoing activities, we recommend that you identify
intermediate  milestones that show progress toward goals and keep SC3 Team members enthusiastic and
positive about making a difference.

Exhibit 2-2 provides a worksheet that illustrates an example of how to track and measure progress towards
the goal of purchasing less toxic chemicals. In Exhibit 2-2, we use the same example performance
measures portrayed in Exhibit 2-1. You can use worksheet 2-2 in the Additional Tools and Examples
section at the end of this chapter to track progress over time.  The worksheet enables your program to take
"snapshots" of progress after 1  semester, a year, and two years, but feel free to adjust these timeframes to
fit your team's preferences,  and your school's or district's needs.
1 See the brief description of Green Cleaning on page 2-5 and some helpful links in the Additional Tools and
  Examples section at the end of this chapter.
                                              2-4

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                    Chapter 2 - Decide What Your SC3 Program Will Look Like
Exhibit 2-2: SC3 Progress Report (Example)
Example SC3 Program Goal: Purchase Less Toxic Chemicals
Performance Measure
a. Quantity of toxic/hazardous
chemicals ordered measured
through purchasing invoices
[measured every ordering cycle].
b. Quantity of alternative
chemicals purchased [measured
every ordering cycle].
c. Number of chemicals changed
out for less hazardous
alternatives [measured every
ordering cycle].
Baseline
Year
27oz
3oz
3
After
First Year
20oz
7oz
5
After
Second Year
10oz
1lb
9
Status as of _/_/_
Phasing out toxic usage;
working to phase out bulk
orders ofHVAC chemicals for
the boiler room; have begun
to use alternatives.
Alternative cleaning products
and lab chemicals are
becoming easier to find;
having hard time finding
alternatives to toxic ceramic
glazes.
Difficult to convince some
teachers and facilities
personnel to switch to
alternative chemicals.
There are benefits to keeping a written record of progress in the manner illustrated in Exhibit 2-2:

    >   It is great for briefing management and customers on progress and accomplishments; and

    >   It can help the SC3 Team stay on track.
      Useful Resource: Greening your Cleaning

        One way to have an impact that could reduce the amount of potentially harmful chemicals used in
your school is to evaluate the option of Green Cleaning sanitation practices.  Green cleaning involves
selecting alternative products when appropriate, using those products properly, and taking other steps to
reduce risks, while maintaining a satisfactory level of cleanliness and disinfection.  Check out EPA's Green
Cleaning Web site for additional resources:
                         http://www.epa.gov/epp/pubs/products/cleaner.htm
                                               2-5

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                      Chapter 2 - Decide What Your SC3 Program Will Look Like
  ACTIVITY 3 - IDENTIFY THE SCHOOL / DISTRICT PERSONNEL AND POTENTIAL PARTNERS
               WHO CAN PERFORM SC3 ACTIVITIES

  Exhibit 2-3 continues our purchasing example and illustrates how a worksheet can be
  used to assist you in deciding what personnel should be assigned to perform an SC3
  task.

  In general, you will be evaluating "in-house" (school or district) personnel and "external"
  entities (e.g., partners, parents, vendors). Worksheet 2-3 in the Additional Tools and
  Examples section at the end of this chapter can be used to assign personnel resources
  to specific activities.
 If you have any doubts
  about the technical
 capabilities of school
personnel to perform an
SC3 task, don't hesitate
   to reach out to a
  qualified partner or
      vendor.
Exhibit 2-3: SC3 Staffing Plan (Example)
Example SC3 Program Goal: Purchase Less Toxic Chemicals
Activity
i. Have a face-to-face meeting with all
school/district personnel who purchase
chemicals to map out chemical usage and
buying patterns.
ii. Have chemistry, vocational, and art
department heads, and the lead custodian
meet with a chemical supplier(s) to discuss
alternatives to hazardous chemicals currently
used by the school.
ill. Each department evaluates the list of
less-hazardous alternatives that would
reduce potential harmful exposures and
lower disposal costs.
iv. If possible, each department creates a
table of price comparisons and a chemical
use plan that estimates chemicals (and
budget) needed for the following year.2
v. Consult with person or department in
charge of purchasing about alternative
chemicals and reduced quantities of toxic
chemicals to purchase.
What do we need to
accomplish?
A list of chemicals we
currently buy, how they
are used, and purpose
they serve.
A list of alternative
chemicals that we can
substitute for more
hazardous chemicals
currently in use.
Department head
decision to adopt the
recommended list of
alternative chemicals.
Revised curriculum plan
that details types and
quantities of alternative
chemicals to be
purchased.
A presentation or memo
about preferred
alternative chemicals
and more hazardous
chemicals to be
avoided.
Who can do this?
In-house
Heads of all chemical-
using departments in
school
Chemistry, custodian,
and art department
heads
Any staff familiar with
school's chemicals
(teachers and/or
custodians)
Staff familiar with
chemicals, budgeting,
and curriculum planning
Staff member
possessing good
presentation skills and,
ideally, previous
experience with budget
planning
External
Chemical supplier
representative(s)
Chemical supplier
representative(s)
Chemical expert
(if nobody is available
internally to do this)
Partner familiar with
chemicals and ideally,
curriculum planning
Partner familiar with
presentation computer
programs
2 To help staff forecast use and demonstrate reductions, visit the Office of the Federal Environmental
  Executive's Green Cleaning Pollution Prevention Calculator: http://www.ofee.gov/ianitor/index.asp
                                                 2-6

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                   Chapter 2 - Decide What Your SC3 Program Will Look Like


ACTIVITY 4 - IDENTIFY POTENTIAL ROADBLOCKS AND WAYS TO ADDRESS THEM

The best plans are those that anticipate potholes and roadblocks. Your SC3 Team should anticipate how a
plan might be sidetracked in any way and be ready to take appropriate action to avoid problems that may
arise (e.g., submit recommended changes in policy well in advance and get the people authorized to make
these changes behind them).  Sometimes a  problem cannot be avoided, so you will need to be effective in
making the necessary adjustments.

In Exhibit 2-4, we provide an example of a tool your team can use to anticipate potential obstacles and plan
ways to overcome them. The  exhibit focuses on the purchasing goal we have been discussing throughout
this chapter. Worksheet 2-4 in the Additional Tools and Examples section at the end of this chapter can be
used to identify and plan for potential roadblocks so that your SC3 program will maintain momentum and
continue towards its goals.
      Tip: Be Aware of Potential Delays

       Delays in getting approvals on budget requests and changes in policy are likely to be one of the
biggest obstacles you face.  Learn when such requests need to be made so you are prepared and can see
how the timing affects your schedule-allow enough time and get started early!
                                             2-7

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                          Chapter 2 - Decide What Your SC3 Program Will Look Like
                  Exhibit 2-4: Identifying Potential Obstacles and Solutions (Example)

                         Example SC3 Program Goal: Purchase Less Toxic Chemicals
               Activity
                         Potential Obstacles
  Ways to Avoid or Correct the Problem
i. Have a face-to-face meeting with all
school/district personnel who purchase
chemicals to map out chemical usage and
buying patterns.
                     Hard to coordinate schedules for
                     an in-person meeting.
                     Inadequate information regarding
                     usage or purchasing
                     arrangements.	
Align meeting times to associate with weekly
staff meetings or mandatory teacher workshops
to ease scheduling conflicts; Develop a
semester 'outline' of chemicals used.
ii. Have chemistry, vocational, and art
department heads, and the lead custodian
meet with a chemical supplier(s) to discuss
alternatives to hazardous chemicals
currently used by the school.	
                     Current supplier is back-ordered
                     on some of the alternative
                     chemicals we would like to
                     purchase.
Investigate and seek information from other
suppliers.
ill. Each department evaluates the list of
less-hazardous alternatives that could
reduce potential harmful exposures and
lower disposal costs.
                     Some department heads are
                     unfamiliar with alternative
                     chemical substitutes, and are not
                     willing to adopt them.
Get chemical sales reps to answer questions
and address concerns. Tap an experienced
partner to weigh in on the recommended list of
alternative chemicals.
iv. If possible, each department creates a
table of price comparisons and a chemical
use plan that estimates chemicals (and
budget) needed for the following year.
                     Alternative chemicals may be
                     safer, but some are substantially
                     more expensive.
Work with staff in each department to alter
curriculum and usage patterns to lower costs.
Enlist the SC3 Program Champion to back
budget requests.
v. Consult with person or department in
charge of purchasing about alternative
chemicals and reduced quantities of toxic
chemicals to purchase.	
                     Purchasing authority may
                     overlook alternative options.
Follow up any memo with a phone call or in-
person meeting with purchasing personnel to
convey importance.
      ACTIVITY 5 - ESTIMATE THE RESOURCES REQUIRED TO PERFORM EACH ACTIVITY

      In some cases, there are no additional labor costs when school and district personnel are doing SC3
               program business - school chemical management can be made part of their job.  However, your
                school may have overtime policies that come into play for some personnel performing SC3
                 activities, so your SC3 Team may need to set aside some budget for in-house support.  For
                 example, SC3 activities performed when school is not in session (e.g., holiday breaks,
                summer, after hours) may involve a separate expense.
Consider when and
 how partners can
help the SC3 Team
   with funding
  contributions or
  voluntary labor.
In Exhibit 2-5, we provide an example of an estimate of in-house labor costs to perform an
activity related to the goal of purchasing less toxic chemicals. Worksheet 2-5 in the Additional
Tools and Examples section at the end of this chapter can be used to estimate the labor costs for
each activity; you can use the worksheet to estimate partner and vendor costs, too, if applicable.
                                                      2-8

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                          Chapter 2 - Decide What Your SC3 Program Will Look Like
Exhibit 2-5: SC3 Labor Cost Estimate (Example)
Example SC3 Program Goal: Purchase Less Toxic Chemicals
Activity: Have a face-to-face meeting with all school/district personnel who purchase chemicals to map out chemical
usage and buying patterns
Job Title
Dept. Head
Custodian
Teacher

Hours
4
2
2

Rate
$25/hour
$13/hour
$20/hour

Other
Supplies ($45)
NA
NA
TOTAL:
Total
$145
$26
$40
$211.00
      If you need outside expertise for an SC3 activity, first consider involving your partners and
      estimate the number of hours of in-kind service they can offer, or, in those instances where
      you need to hire a vendor (e.g., a chemical inventory specialist), you will need to budget for
      the out-of-pocket expense.  You can probably use school requisition forms and
      procedures to gain the resources that you need.  Other times, when the activity might
      not be covered by a normal requisition, you may need to create and publish a Request
      for Proposal to obtain the services of a qualified vendor (see Chapter 4 for an example
      of a request for proposal to retain a cleanout specialist).

      In adding up the budget requirements for all SC3 activities for the upcoming year, your
      team may come to the conclusion that you won't have all that you need for a
      comprehensive program. Remember, you can build your program a piece at a time,
      choosing to begin some SC3 activities later on. Whatever you do, it is important for the
      SC3 Program Champion to support your team's budget requests.
 Completed worksheets
  outlining the specific
 support your program
 requires can be used to
 show partners where
  they can assist your
  program and what
resources you would like
   them to commit.
      ACTIVITY 6 - IDENTIFY POTENTIAL SOURCES OF FUNDING FOR THE SC3 PROGRAM

                 Obtaining funds is necessary for any program.  The success of almost every activity you
                  undertake will depend in some part on securing funding resources. The SC3 Team should
                  explore several approaches for obtaining funds rather than solely depending on one funding
                  source. Having multiple funding sources will more likely give you a stable financial base that
                      will help you expand and sustain your chemical management program.
It's possible your program
 can rely on one "golden
   goose," but most
programs will need to tap
 multiple funding sources
   to remain viable.
                                                     2-9

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                     Chapter 2 - Decide What Your SC3 Program Will Look Like


  Your SC3 Team should become knowledgeable and savvy regarding how the budget process works in your
  school or district. You can use the expertise on your team to help you navigate the budget process so that
  the necessary resources can be obtained to support your program.  We provide a description of a variety of
  funding sources that your SC3 Team may want to consider:

  STATE AND LOCAL AGENCIES: State and local departments that address the environment, education,
  labor, health and safety, and agriculture may have funding or can provide in-kind services for SC3
  programs. Another possible option is to try to use funding that you have received from
  other sources to obtain state matching funds for your SC3 program. Be sure to also
  check out the Grants and Funding page of EPA's Pollution Prevention (P2) Web site
  (http://www.epa.gov/p2/pubs/qrants/index.htm) for more information regarding
  matching funds from state programs.
                                                                         The Fort Worth Independent School
  SCHOOL AND SCHOOL DISTRICTS: Some SC3 programs require that           District (FWISD) in Texas reported that
  schools contribute to the costs of chemical removal, training, or other          EPA fundin9was a "catalyst" for getting
  activities. A school's financial contribution into its own program validates      their school board to contribute $55,000 to
  ..      .,  .     .           ...   .    .  .             . \/      u  i        their program.  See the Additional Tools
  the need for long-term responsible chemical management. Your school        and Examp,es section for this and other
  may  not yet budget for responsible chemical management. You can          state, tribe, and regional scs successes.
  speak to someone familiar with your school's budget to find out if SC3
  would fit into the existing budget or if it could be added later. Consider expanding existing programs, such
  as your coordinated school health program (CSHP)3; Indoor Air Quality/Tools for Schools; multi-hazards
  planning team; HealthySEAT or EMS; or Integrated Pest Management program (IPM). Also,  you can speak
  with anyone on your SC3 Team who has experience working with your school district about exploring
  potential sources of technical assistance and funding.

  LOCAL BUSINESSES, INDUSTRIES, FOUNDATIONS, AND GROUPS: Local organizations can also help you
  achieve your SC3 goals.  Look for corporate sponsorship or charitable donations of services and funds.
  You can also look for competitive grant programs. You can ask the members of your SC3 Team to help find
  existing connections to these organizations. You may also research your locality to find any likely local
  sources for program funding and support. Local sources of funds and resources are often available from
  businesses with ties to the community either directly or through their charitable foundations.  Consider
  contacting local industries that have the chemical experience and technical expertise to  potentially offer in-
  kind services to your program.  You can speak with people involved in other groups around the school and
  within your community for potential contacts and resources specific to your area.

  FEDERAL AGENCIES: There may be funds available from federal agencies in the form of grants (see
  www.grants.gov). Funds  may be available from EPA through grants offered by the Office of Solid Waste
  and Emergency Response, the Office of Children's Health Protection and Environmental Education, the
  Office of Air and Radiation, the Office of Pollution Prevention and Toxics, and the EPA regions.  Other
  federal agencies and programs with relationships to schools, such as the Department of Education,
  Centers for Disease Control, and Community Action for a Renewed Environment (CARE: see
  http://epa.gov/care/) should also be explored.
3 This is a Centers for Disease Control & Prevention program and each state has a coordinator. You can find
  out more information about this program at: http://www.cdc.gov/HealthyYouth/CSHP/


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                            Chapter 2 - Decide What Your SC3 Program Will Look Like
        ACTIVITY 7 - ENTER INTO PARTNERSHIPS

        Partners are an excellent source of technical expertise and in-kind support for your
        SC3 program. This section offers guidance on how the SC3 Team might go
        about establishing and maintaining partnerships to support your SC3 program.
                                                                         Target a range of partners to
                                                                        ensure that you have more than
                                                                           one source for advice and
                                                                        assistance throughout the life of
                                                                             your SC3 program.
                                   How do I recruit partner organizations to the SC3 Team?
        Children are our most important resource. Many organizations within your community have people working
        to keep children safe. These organizations may wish to partner with your school to achieve responsible
        chemical management, so you may want to gauge their interest and get them involved.  Consider the
        following approach:

               Research the organization (e.g., talk to knowledgeable people in the community, contact the
               Chamber of Commerce, or even conduct an Internet search);
               Identify the person who can make or influence decisions;
               Arrange for a face-to-face meeting, if possible, or set up a conference call;
               Engage the decision-makers in your school or district, if possible;
               Be prepared (see list below); and
               Follow up your initial contact.

                   Another approach would be to pull together a number of potential partners for a school-
                    sponsored meeting and follow up with the steps listed above.  Even if an organization is not
                     interested in partnering now, they may want to in the future.  Contact them again at a later
                          date to reassess their interest.
Cultivating an appropriate mix
  of partners who ideally are
dedicated to offering long-term
   technical expertise and
 financial resources will help
   maintain a robust SC3
        program.
               When the SC3 Team first meets with a potential partner, remember to employ effective
               meeting practices (see Chapter 4, Activity 1: Begin to Put your SC3 Program into
               Action,  page 4-5). At your meeting, you will want to cover the following topics:
                      Purpose:  State generally what will be covered in the meeting and what you
               hope to achieve by the end of the meeting.  Ask meeting participants if there are other
   topics they would like to cover and their goals for the meeting.
>  Current Situation:  Describe the current chemical management situation you are addressing. It
   may not be necessary to go into detail; however,  you should be prepared to answer specific
   questions about your chemical management situation (e.g., estimated quantity of chemicals,
   general condition of containers, etc.)
   Responsible Chemical Management Program: Provide potential partners with an overview of
   your plan to address the situation. Give a summary of the goals of the plan, the content, and the
   strategy and milestones you have laid out.
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                    Chapter 2 - Decide What Your SC3 Program Will Look Like


    >  Partner Assets: Explain how the potential partner is uniquely suited to be part of the solution.
        Provide details about the plan and where you see them being most able to contribute.  Ask for
        input and be open to ideas about their expertise and ways they would like to participate.
    >  Partnership Benefits:  Explain the benefits of partnering beyond protecting students and staff. Be
        prepared to offer partners meaningful incentives, such as public recognition, a certificate or plaque,
        or a school award (see below).
    >  Next steps:  Summarize any agreements that were reached; outline outstanding questions and
        how they will be addressed; clarify next steps; and arrange for a future meeting.
     Usefi

       Loc,
      Useful Resource: Local Emergency Planning Committees
       Local Emergency Planning Committees (LEPCs) are groups that allow for emergency management organizations
to communicate about chemical hazards in the community and cooperate to provide information regarding chemical risks to
the public. Given their experience and connection to local industries, you should try to contact your local LEPC. For a
database of LEPCs nationwide, visit: http://Yosemite.epa.gov/oswer/lepcdb.nsf/SearchForm70penForm
 Developing incentives for partners to come on board can really help get a partnership started. Partners
 may have a number of motivations for joining up with a school's SC3 program.  Some of the benefits of
 becoming involved in a successful partnership may include:

        Protecting the health and safety of children and school personnel;
        Protecting the environment;
        Preventing fires and spills;
        Demonstrating community leadership;
        Improving the local schools;
        Gaining recognition locally from your school or district through community media outlets;
        Gaining national recognition from EPA through the national SC3 program (the SC3 Web site, press
        events, and/or a recognition award); and
    >  Earning credit toward EPA's Performance Track (see http://www.epa.gov/perftrac).
    Tip: Be Prepared with Information when Reaching out to Potential Partners
       Being up front about any and all issues can provide a potential partner with a clearer picture of your
school's chemical management situation. To better manage a potential partner's expectations, consider
bringing the following relevant documents to your first meeting:

               Completed status worksheets summarizing school chemical information;
               Photos of chemical situations that need to be addressed;
               Contact information; and
               'Partner Appendix: Why Become Involved in School Chemical Management' (included in the
               Additional Tools and Examples section at the end of this chapter).

Providing these items could  help answer many initial questions a potential partner may have about your
program and can make your first meeting as productive as possible.
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                       Chapter 2 - Decide What Your SC3 Program Will Look Like
                             How can everyone get the most out of an SC3 partnership?
   Once a partner has agreed to enter into a relationship with your school or district, knowing the
   types of activities your SC3 program will be conducting should give your SC3 Team and
   partners a better idea of where assistance may be helpful.  Because your initial meeting with a
   partner likely gave them a basic understanding of your chemical management situation
   and the plan to address it, you should use subsequent meeting(s) with a partner to do
   some of the following:

          Gain an expert opinion on your chemical management situation;
          Brainstorm approaches to addressing issues specific to your school; or
       >  Agree on the roles and responsibilities of both the school  and the partner.
                                           Understand that some
                                            partners may only be
                                            available to help on a
                                            single project, while
                                          others could commit to a
                                           long-term association.
   A good way to clearly define the components and expectations, including roles, responsibilities, and
   limitations, of the partnership is to develop a partnership agreement, a team charter, or a letter of intent.
   This document should outline the elements of the relationship, including but not limited to:

          The specific tasks that a partner can perform or assist with;
          The proposed schedule for agreed upon activities; and
          The ways your school or district can recognize a partner's efforts.

   In Exhibit 2-6, we provide an example of an SC3 Partnership Agreement to give you an idea of what is
   included. Consider using this and other partnership agreements (links provided in the Additional Tools  and
   Examples section at the end of this chapter) to outline a version for your school or district if your SC3 Team
   and partner(s) decides that doing so will benefit your partnership.
                           Exhibit 2-6: Sample Partnership Agreement
       Partnership Agreement Between
(Partner Name) and
(School/District Name)
Through this agreement, [Partner's Name], hereafter referred to as "SC3 Partner," joins in partnership with [School/District
Name], to help create healthier school environments for students and personnel. SC3 Partner intends to support the
goals of the Schools Chemical Cleanout Campaign (SC3) program, which are to: remove accumulations of unnecessary
chemicals from schools; facilitate implementation of responsible chemical management practices; and raise awareness of
the potential risks to students and school personnel created by mismanaged chemicals. The SC3 Partner intends to
promote responsible chemical management in [School/District Name]. [School/District Name] intends to cooperate with
other parties to this agreement to support these same goals.
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                        Chapter 2 - Decide What Your SC3 Program Will Look Like
                             Exhibit 2-6: Sample Partnership Agreement
Partner Role
SC3 Partner intends to provide, without charge to [School/District Name], resources or services in the following areas at
[insert name of school(s) or school district(s)]:
    Q   Inventory chemicals
    Q   Develop a sustainable chemical inventory system
    Q   Package mismanaged/unnecessary  chemicals for removal
    Q   Remove mismanaged/unnecessary chemicals
    Q   Proper disposal of chemical waste
    Q   Develop chemical management training
    Q   Conduct chemical management training
    Q   Assist with the development of a chemical management program
    Q   Assist with the implementation of a chemical management program
    Q   Recruit other SC3 Partners
    Q   Develop performance goals and measures to gauge chemical management success
    Q   Administer SC3 Partner Program to Trade Association/Organization member companies and other interested
         parties
    Q   Other (describe)	

         (Use additional pages  if necessary)

The SC3 Partner agrees to provide services to [School/District Name] in the amount of [# of hours] each [duration of time
(e.g., semester, year, etc.) to addressing the aforementioned resources and services.

School / District Role
[School/District Name] will provide the SC3 Partner with the following recognition opportunities:
    Q      Presence at publicity opportunities (e.g.,  local media events, PTA meetings, etc.)
    Q      Prominent display of SC3 Partner name and logo in communication and outreach materials to stakeholders
    Q      Recognition as  program partner in all press releases, with opportunities for SC3 Partner quotes

Limitations
This Partnership Agreement describes the actions [Partner Name] agrees to undertake as a SC3 Partner.  It does not
impose any legally-binding obligations on [School/District Name], nor is [School/District Name] imposing, through this
Agreement, any legally-binding obligations on  the SC3 Partner or on any other entity.

This Partnership Agreement does not create any right  or benefit, substantive or procedural, enforceable by law or equity
against [School/District Name], their officers or employees, or any other person.

Effective Date, Modification, and Termination
This agreement becomes effective upon the date of the last signature.  This agreement will be in  effect for [# of years]
from the date of the last signature. It may be modified or amended only through written agreement of all signatories. Any
signatory may terminate this agreement by providing 30 days written notice to the other parties.
Signature and Date, SC3 Partner Representative
Signature and Date, School's Legal Counsel / Principal / School Board Director
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                    Chapter 2 - Decide What Your SC3 Program Will Look Like


Agreeing early on what is involved in the partnership will help manage expectations and interactions in the
future.  As you develop the terms of your partnership, consider the factors that will keep your relationship
successfully going forward:

        Revisit the partnership agreement on a schedule that works for you both. As your
        partnership moves along,  revisit your commitments and adjust them, if necessary, to
        meet both your needs and those of your partner.
        Keep open communication.  Staying in contact with your partner is very important as
        the program progresses. Agree on how often you should meet or have phone calls. It is
        especially important to communicate with partners well in advance concerning upcoming
        events with which they should  be involved.
        Discuss national partnership opportunities.  Your partner may want to gain additional
        recognition for their role in keeping schools safe.  Be sure to inform them of the
        opportunity to become a national partner with EPA.

In addition to the items mentioned above, refer to Chapter 5, Activity 5: Maintain Relationships with
Partners (page 5-7) for additional guidance on how to maintain a healthy relationship with partners as your
program develops.
ACTIVITY 8 - IDENTIFY ANY REGULATIONS THAT MAY AFFECT YOUR SC3 PROGRAM

In planning your SC3 program, it is important for you to remember that you need to
comply with the applicable federal, state, and local rules and regulations regarding
chemical management and safety. Any number of government authorities could
potentially impact the design, performance, sustainability, and ultimate success of
your SC3 program. These regulations are designed to keep people and the             cultivate the involvement of
environment safe.  To comply, you will want to investigate pertinent legal issues prior     partners who understand
to taking any action.                                                              applicable regulations related
                                                                                   to school chemical
There are a variety of ways in which laws and regulations may play a role in how
your SC3 program operates.  For example:                                          iegai and technical advice.

       School Safety Regulations. It is likely that there may be limitations on the types of activities that
       can be performed during school hours.  If you are planning a cleanout during school hours, make
       sure that you notify school management, get the necessary permits, or simply reschedule to a date
       and time that is compliant with applicable laws and regulations.
       Chemical Disposal Restrictions. There are regulations governing the proper disposal of
       chemical wastes.  The Resource Conservation and Recovery Act (RCRA) regulates hazardous
       waste generators. A "generator" is any person, or site, whose processes and actions create
       hazardous waste. Refer to the EPA Hazardous Waste Generator link in the Additional Tools and
       Examples section at the end of this chapter for more information in determining whether your
       school generates hazardous waste, and if so, your generator status. Additionally, MSDSs are
       good sources of information on proper disposal of specific types of chemicals.  Finally, check with
       your local Publicly Owned Treatment Works (POTWs); they may be able to help you determine the
       appropriate methods of disposal for chemicals.
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                    Chapter 2 - Decide What Your SC3 Program Will Look Like


       OSHA. The Occupational Safety & Health Administration requires that laboratories (that are
       subject to OSHA regulation) potentially exposing workers to hazardous materials have a written
       Chemical Hygiene Plan. Refer to the OSHA links in the Additional Tools and Examples section at
       the end of this chapter for more information on chemical safety and compliance.
       Labor Laws.  Some laws put limits on the amount of overtime that school personnel can work.

Partners with legal and chemical management experience can be extremely useful in reviewing your
planned SC3 activities and advising you of any potential shortfalls or issues you need to be aware of (e.g.,
state and local agencies). You may want to conduct some background research into local, state, and
federal laws pertaining to chemical management. We provide some links for you to begin your research:

       EPA listing of state environmental agencies related to Solid & Hazardous Waste:
       http://www.epa.gov/epaoswer/osw/stateweb.htm
       State Environmental Agencies:
       http://www.epa.gov/epahome/state.htm
       EPA Regional office sites can  be found at the  web sites with this format.  Simply change the
       number for each region (1—10):
       http://www.epa.gov/region1/
      Keys to Sustained Success: Use Best Practices
         Two useful compliance guides to review from EPA's Region 2 provide best management practices
  applicable to schools' environmental concerns:

  A primary environmental compliance guide for K-12 schools:
  http://www.epa.gov/region02/children/k12/k12pdf.htm

  An environmental compliance guide for art programs at K-12 schools, colleges and art studios:
  http://www.epa.gov/region02/children/k12/artpdf.htm
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                    Chapter 2 - Decide What Your SC3 Program Will Look Like
                                                    Summary
The activities for developing an SC3 program to achieve your chemical management goals are:

Activity #                            Description

    1.            Define the activities your program will perform (Worksheet 2-1);
    2.            Create a timeline for starting and completing each activity (Worksheet 2-2);
    3.            Identify the school/district personnel and potential partners who can perform SC3 activities
                  (Worksheet 2-3);
    4.            Identify potential roadblocks and ways to address them (Worksheet 2-4);
    5.            Estimate the resources required to perform each activity (Worksheet 2-5);
    6.            Identify potential sources of funding for the SC3 program;
    7.            Enter into partnerships; and
    8.            Identify any regulations that may affect your SC3 program.

This chapter helps you to identify the activities and support needed to achieve your SC3 program goals.
Chapter 3 will assist you in developing and delivering your program message to secure participation,
enhance awareness, and change behaviors.
VISIT THE SCHOOLS
    LEANOUT
    WEB SITE
                                 CHEMICAL CLEANOUT CAMPAIGN
                                     www.epa.gov/sc3
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                    Chapter 2 - Decide What Your SC3 Program Will Look Like
                                         Additional Tools and Examples
This section of the chapter contains helpful links to conduct further research and blank exhibit worksheets
to help you get started with developing and defining the various components of your SC3 program. For
ideas regarding the kind of information you might capture on these worksheets, you can refer to the exhibits
containing examples earlier in this chapter.
    These Web sites have useful information on potentially hazardous chemicals:
        OSHA Fact Sheet dealing with hazardous chemicals in laboratories
        OSHA Standard for Occupational Exposure to Hazardous Chemicals in Laboratories
        Informational booklet from OSHA (gives an overview of Chemical Hazard Communication)
        EPA definition of hazardous waste generators and how to determine your hazardous waste generator
        status
        Summary of State, Tribal, and Local SC3 programs
     These sites provide information on Green Cleaning:
        Green Seal
        Green Cleaning Network
     >  Healthy Schools Campaign Green Clean Schools
Worksheets                                Title
    2-1            SC3 Activities and Performance Measures to Reach Program Goals
    2-2            SC3 Progress Report
    2-3            SC3 Staffing Plan
    2-4            Identifying Potential Obstacles and Solutions
    2-5            SC3 Labor Cost Estimate
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                     Chapter 2 - Decide What Your SC3 Program Will Look Like
       Worksheet 2-1:  SC3 Activities and Performance Measures to Reach Program Goals
Goal:
                     Activities
IV.
v.
VI.
                                                     a.
                                                     b.
Performance Measure(s)
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Chapter 2 - Decide What Your SC3 Program Will Look Like
Worksheet 2-2: SC3 Progress Report
Goal:
Performance Measure
a.
b.
c.
d.
e.
Baseline
Year





After
First Year





After
Second
Year





Status as of _/_/_





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Chapter 2 - Decide What Your SC3 Program Will Look Like
Worksheet 2-3: SC3 Staffing Plan
Goal:
Activity
i.
ii.
iii.
iv.
V.
vi.
What do we need to
accomplish?






Who can help?
In-house






External






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                      Chapter 2 - Decide What Your SC3 Program Will Look Like
                 Worksheet 2-4: Identifying Potential Obstacles and Solutions
Goal:
          Activity
IV.
v.
Potential Obstacles
Ways to Avoid or Correct the Problem
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Chapter 2 - Decide What Your SC3 Program Will Look Like
Worksheet 2-5: SC3 Labor Cost Estimate
Goal:
Activity:










Rate




Other




Total




                        2-23

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Chapter 2 - Decide What Your SC3 Program Will Look Like
                        2-24

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               Chapter 3-Publicize your SC3 Program
                            Why is it important to publicize my SC3 program?
SC3 programs need support - financial and moral - and active participants to be successful. By publicizing
your program and actively reaching out to potential partners and stakeholders, you can create interest and
momentum for your SC3 program. This chapter describes some of the activities you can undertake to
create a message and attract attention to your program.

The activities for creating and spreading your SC3 program message are:

Activity #                           Description
    1.        Develop and deliver an effective program message with an informative program name or slogan;
    2.        Identify target audiences;
    3.        Use existing communication channels to publicize your program; and
    4.        Consider the most effective time of the year to perform communication and publicity efforts.
ACTIVITY 1 - DEVELOP AND DELIVER AN EFFECTIVE PROGRAM MESSAGE WITH AN INFORMATIVE
            PROGRAM NAME OR SLOGAN

Creating a program message is important to publicizing your SC3 program and gaining the necessary
support for long-term success.
                                Why should I create a program message?
Communication and publicity are critical to the success of the SC3 program. Your efforts to reach out to
and communicate with various stakeholders and partners play a key role in:

       Securing participation in your SC3 program (See Chapter 4 regarding putting your program into action);
       Enhancing  awareness of chemical safety issues; and
       Changing behaviors so that effective chemical management can be sustained over time (See
       Chapter 5 regarding program sustainability).

Your communication and publicity efforts begin with developing an effective message to promote your SC3
program.  Your program message should be eye-catching and distinctive.
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                                     Chapter 3 - Publicize your SC3 Program
                                           How do I develop an effective message?
       Schools often have a variety of programs, initiatives, and campaigns vying for the
       attention and involvement of people, so it is important to develop a message that is
       distinctive and well timed. Develop a clear, simple, and compelling message about the
       importance of responsible chemical management in creating a safe environment for
       students and school staff. In crafting your  message, you may want to
       consider:
               The target audience you are trying to reach;
               The central theme of your message and how it may relate to the "big
               picture" and overall priorities of your school or district;
               Supporting statements;
               Existing communication channels to spread the message in your
               school or district; and
               The best time to begin publicizing your message.
                                                        A catchy program name or slogan can
                                                             help your program make a
                                                           memorable splash and maintain
                                                        interest. Examples of program names
                                                               and slogans include:

                                                        >   "Rehab the Lab;"
                                                        >   "Clean Sweeps Program;"
                                                        >   "Healthy Schools;"
                                                        >   "Safer Schools Initiative;"
                                                        >   "No Recess for Chemicals;" and
                                                        >   "Clean Out Your Chemicals"
You should 'brag' about any
   chemical management
successes you may have had
  so far.  Touting how your
school may have quickly and
  effectively responded to
  leaking containers can be
helpful in gaining support and
   resources for your SC3
        program.
You should address some specific situations that will soon be tackled under your SC3
program, as well as activities that will prevent problems in the future by instituting
responsible chemical management policies and practices.

Initially, we suggest that your emphasis be on publicizing your program name or
slogan and articulating achievable, worthy goals (See Chapter 1 regarding
development of program goals). If your stakeholders and partners believe that the
program is a worthy effort and that goals are achievable, they will be more inclined to
participate.
                              Tip: Essentials of a Winning Message
                               An effective message should have a central concept with no
                               more than 3 points, and should be:
                                     Relevant to the audience receiving it;
                                     Credible;
                                     Concise and memorable;
                                     Clear and non-technical; and
                                  >  Focused and compelling.
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                           Chapter 3 - Publicize your SC3 Program
ACTIVITY 2 - IDENTIFY TARGET AUDIENCES

To ensure your message is as successful as possible, you and your team will want to consider the various
ways you might deliver it to specific audiences.  Tailoring your central message to each target audience
increases your chances of gaining support for your program.
                       Who are the target audiences of the SC3 program message?
As you develop your program message, think about which program components should be emphasized
when promoting your SC3 program to each stakeholder and partner.  Exhibit 3-1 provides an example of
how SC3 program components may map to these target audiences. Worksheet 3-1 in the Additional Tools
and Examples section at the end of this chapter can be used to evaluate messages and topics of interest to
your stakeholders and partners.
Exhibit 3-1 : SC3 Program Components of Interest to Target Audiences (Example)
Target Audience
Administrators
Potential Industry
Partners
Teachers & Staff
Students
Parents
Local Business
SC3 Program Components
Purchasing
X
X



X
Storage
X
X
X
X
X

Inventory
X
X
X



Use
X
X
X
X
X

Disposal
X
X
X
X
X
X
Example "Hot" Topics
Liability and budget
Public relations opportunity
Classroom safety, curriculum,
and professional responsibility
Feeling safe
Their children's health
Good neighbor
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                             Chapter 3 - Publicize your SC3 Program
 ACTIVITY 3 - USE EXISTING COMMUNICATION CHANNELS TO PUBLICIZE YOUR PROGRAM
 To publicize your program, we recommend that you use existing
 approaches and products that your school or district has found to be most
 effective.  For example, no need to reinvent the wheel when a school
 already has a widely read newsletter or heavily attended meetings (e.g.,
 PTA).

 A successful strategy may be to tap into the current communication
 channels to reach as many stakeholders,  potential partners, and customers
 as possible.  Attempting to create new communication channels and
 publicity events can be time consuming, expensive, and may, in the end, not
 be all that effective. For example, given the demands on people's time,
 scheduling a separate (additional) meeting involving folks who already
 attend another school function may lead to lower than desired attendance.
"Piggybacking" on existing events
  and forums ensures a captive
  audience and saves time and
 money. It also eases scheduling
  difficulties and allows school
 personnel to participate without
interfering with  their personal time
       and resources.
 You should also consider whether to take advantage of other initiatives, meetings, or programs that
 complement or are consistent with SC3 program efforts to get your message out. Exhibit 3-2 provides
 examples of various communication and publicity methods that may reach your target audiences.
 Worksheet 3-2 in the Additional Tools and Resources section can be used to look at the different
 communication methods that may be available to you and your SC3 Team.
       Leveraging an Existing Communication Network
       Iowa has a statewide TV network that every school can access. A partner organization, the Metro
Waste Authority, used this medium to reach out to teachers to train them on responsible chemical
management. This is an excellent example of using an existing resource to cost-effectively reach many
teachers. Metro Waste Authority's Rehab the Lab program is described here:

                             http://www.mwatoday.com/sch_reh.html
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Chapter 3 - Publicize your SC3 Program
Exhibit 3-2: Methods of Communication and Publicity for your Program Message (Example)
Intended Results
Target Audience
Pros
Cons
Resources
Needed
Continuing Education/Teacher and Facilities Personnel Training
Create awareness; Change
behaviors regarding
chemical use in classrooms
and facilities.
Teachers
Uses an existing forum to
reach a captive audience.
Getting participation.
Trainer; incentives
and materials.
Article in Parent Newsletter
Generate participation in
SC3 and prompt
parent/student discussions
on chemical safety.
Parents
Uses an established
product for conveying
information to parents.
No face-to-face
interaction; SC3
message could get
"lost".
Design and writing
time.
Presentations forPTA and Teacher/Staff Meetings
Spread awareness; Identify
potential participants.
Parents, Teachers
Program information
brought directly to their
attention; Can answer
questions immediately.
Need to have plan.
Prep time and
materials.
Newspaper Articles and PSAs
Spread awareness; Identify
potential participants; Gain
media attention to attract
supporters.
General Public, Local
Community, Partners
Wide-reaching exposure;
article write-up would be
inexpensive.
Need to develop
PSA or set up
interview.
Newspaper
personnel; writing
time.
Brochure and Pamphlet Campaign
Spread awareness;
Encourage feedback and
participation.
Administrators,
Teachers, Local
Community
Able to present variety of
program information.
No personal
interaction; easily
disregarded.
Printing equipment;
labor; planning;
distribution and
design time.
Publicized Program Launch and Press Conferences
Generate enthusiasm and
support among community;
Gain media attention to
attract supporters.
General Public, Local
Community, Partners
Exposure to potential
partners; Message is
widespread.
Requires a lot of
coordination and
commitment.
Equipment; labor.
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                             Chapter 3 - Publicize your SC3 Program
                        How do I get people involved and committed to the program?
Publicizing your program is important, but you will need to reach out to those people
and organizations that your team believes are critical to long-term program success.

For example, face-to-face discussions, calls and group meetings allow for that all-
important personal contact to recruit a partner for their resources and expertise.  If
your SC3 program is organized at the school district level, it may be appropriate to
reach out to  individual schools and nearby communities to garner support. At the
school level, local meetings and other forums are great venues to discuss responsible
school chemical management.
  You should spread your
message beyond your school
  and into the community.
 Keeping everyone informed
   can  help in attracting
   additional support and
 possible resources to build
  and sustain the program.
The main message here is that while all forms of communication should be utilized,
personalized, live contact is more likely to generate excitement and secure the
commitment of individuals and organizations than an email or a letter. Your SC3 program's target
audiences are much more likely to offer their support or participation  if they are asked directly.  People
need to know about your program and how they can make a difference.

In addition to gaining a commitment from those who can help get your SC3 program up and running, you
should be reaching out to customers and stakeholders to push for long-term changes  in the attitudes and
behaviors of all those involved in the school chemical management lifecycle (e.g., science, art, vocational,
and facilities personnel, as well as administrators). Even for staff in your school or district that have little to
no involvement with chemicals on a regular basis, you still want their support as you work to promote
responsible chemical management. You can gain this support for your SC3 program  by communicating the
fact that everyone who works at your school or district benefits from working in a safe  and healthy facility.
By securing support within your school or district from as many individuals as possible, you will increase
your chances of establishing and maintaining your SC3 program.

You can keep personnel and partners committed by publicly recognizing their contributions and giving them
credit for program accomplishments.
                                               3-6

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                            Chapter 3 - Publicize your SC3 Program
ACTIVITY 4 - CONSIDER THE MOST EFFECTIVE TIME OF YEAR TO PERFORM COMMUNICATION AND
             PUBLICITY EFFORTS

Determining when to launch a new program is an important consideration. Factors relating to staff and
partner availability or funding accessibility at certain points in the year may make your efforts more likely to
succeed.
                              When is a good time to launch an SC3 program?
It has been said, "timing is everything."  Most schools have a lot of activities and programs throughout the
year vying for attention and involvement. Look for opportune times to conduct certain SC3 activities or
perform communication and publicity efforts.  For instance:

       A chemical inventory or cleanout might be safer if it is carried out during summer months when
       fewer students, teachers, and staff are present.
       Stakeholders may be more receptive to a public rollout of your SC3 program near the beginning of
       the school year when students are settled and 'back-to-school' is still on the public's mind.

You should work with your SC3 Team to gain insights into when is a good time to launch the SC3 program,
keeping in mind other projects that may compete for attention, involvement, and funding.  Pick a time to
launch  your SC3 program that will optimize participation, funding, and results.
             The National Cancer Institute offers Guidance on Communication
              The National Cancer Institute has put together a book on "Making Health
       Communication Programs Work."  In Stage 3 of this book, they describe how to conduct a
       health communication program. There is a significant amount of helpful information
       provided that could be applied to setting up and launching an SC3 program and preparing
       to communicate that message to the public and partners.  Visit their Web site for more
       information at:
                            http://www.cancer.gov/pinkbook/paqe7
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                            Chapter 3 - Publicize your SC3 Program
                                                  Summary
The activities for creating and communicating your SC3 program message are:

Activity #                           Description
    1.        Develop and deliver an effective program message with an informative program name or slogan;
    2.        Identify target audiences (Worksheet 3-1);
    3.        Use existing communication channels to publicize your program (Worksheet 3-2); and
    4.        Consider the most effective time of the year to perform communication and publicity efforts.

This third chapter helps you to create and communicate your SC3 program message to obtain participation,
enhance awareness, and change  behaviors.  Chapter 4 offers guidance regarding how to take action with
your SC3 program and perform certain chemical management projects.
                                     VISIT THE SCHOOLS
                                CHEMICAL CLEANOUT CAMPAIGN
                                         WEB SITE

                                    www.epa.gov/sc3
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                            Chapter 3 - Publicize your SC3 Program
                                        Additional Tools and Examples
This section contains some helpful links and blank exhibit worksheets to help you craft your program
message, and evaluate communication and publicity methods and activities that can best reach your target
audiences. For ideas regarding the kinds of information you might capture on these worksheets, refer to the
exhibits containing examples earlier in this chapter.
    We have included links that offer additional help in developing the various aspects of your

    communication and publicity methods:

               General guidelines for media messages from The Points of Light Foundation

               Stage 3 of NCI's Making Health Communication Programs l/l/bric

       EPA's Pay As You Throw Program:

               http://www.epa.qov/pavt/top5.htm

           >   http://www.epa.gov/payt/pdf/other.pdf
Worksheets                               Title

    3-1            SC3 Program Components of I nterest to Target Audiences
    3-2            Methods of Communication and Publicity for your Program Message
                                              3-9

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Chapter 3 - Publicize your SC3 Program
Worksheet 3-1 : SC3 Program Components of Interest to Target Audiences
Target Audience
Administrators
Potential Industry
Partners
Teachers & Staff
Students
Parents
Community
Local Business
Purchasing







Storage







Inventory







Use







Disposal







"Hot Topic"







                3-10

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Chapter 3 - Publicize your SC3 Program
Worksheet 3-2: Methods of Communication and Publicity for your Program Message
Intended Results
Target Audience
Pros
Cons
Resources
Needed
Method:





Method:





Method:





Method:





Method:





                3-11

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Chapter 3 - Publicize your SC3 Program
                3-12

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         Chapter 4 - Put Your SC3 Program Into Action


OVERVIEW

The purpose of this chapter is to guide you through the process of putting your SC3 program plan into
action.  This chapter builds upon the work you did in completing the program planning worksheets provided
in Chapter 2 of this Workbook.  For those of you who did not complete the Chapter 2 worksheets, but
developed an SC3 program plan on your own, that's ok!  Before you put your SC3 program plan into
action, you may want to refer to Chapter 2 to see whether you have covered all the bases (e.g., assigning
and scheduling tasks, getting program partners on board).

Regardless of how you developed  your SC3 program plan, you will find Chapter 4 to be helpful in launching
components of your program or undertaking a special chemical management project (see Sections I and II
of this chapter, respectively). At a  minimum, your SC3 Team should be planning to:

           Remove inappropriate, outdated, unidentified, and unneeded chemicals (if appropriate);
           Prevent future chemical mismanagement in schools through training, curriculum and policy
           change, and finding long-term management solutions; and
           Raise awareness of chemical issues in schools and promote sustainable solutions.

Ideally,  your SC3 Team has a plan that addresses all of the major elements of responsible chemical
management.  These chemical management themes are commonly found in successful SC3 programs, so
we encourage you to consider them if you have not already done so.
        LEADERSHP & RESOURCES            CHEMICAL INVENTORY
                      STORAGE & HANDLING |       (^CHEMICAL CLEANOUT & DISPOSAL j       | PURCHASING
                                                          POLLUTION PREVENTION
Please note the components and functions represented here are in no particular order.  While some of
these themes maybe related, the connections portrayed are random and do not imply any dependency.
                                            4-1

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                         Chapter 4 - Put Your SC3 Program Into Action
                                 How do I put my SC3 program into action?
OK. You've talked to a lot of people; checked your school for any situations that need to be addressed
immediately; created a plan of action with milestones; have thought about how the SC3 Team will measure
performance; identified a champion that is working to communicate your message loud and clear; and built
a team that is ready to go. So what's next? Now it's time to put all of that preparation into action.

As you go through this chapter, you  will find a list of three (3) activities to establish a SC3 program.  We
also describe three (3) "Special Chemical Management Projects" that your program may undertake  at some
point.  Here is a list of activities and  projects that we will be covering:
Activity #                           Description

Program Management
    1.      Begin to put your SC3 program into action;
    2.      Establish and modify existing chemical management procedures; and
    3.      Train appropriate groups on responsible chemical management.

Project #
Spec/a/ Chemical Management Projects
    1.      Perform an inventory of all chemicals and  chemical products;
    2.      Secure a chemical cleanout professional; and
    3.      Implement a green curriculum.
                                             4-2

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                         Chapter 4 - Put Your SC3 Program Into Action


SECTION 1: PROGRAM MANAGEMENT

ACTIVITY 1 -BEGIN TO PUT YOUR SC3 PROGRAM INTO ACTION

PULL TOGETHER SC3 PROGRAM PLANNING MATERIALS

In Chapters 1 and 2, we identified a variety of materials to collect or prepare when developing your SC3
program. Your team will want to refer to this information regularly, so it makes sense to have the following
items in one place:

        List of goals and performance measures;
        Completed worksheets from Chapters 1 - 3 (e.g., Worksheet 1-1: Evaluating Your School's
        Chemical Management Situation, Policies, and Procedures);
        Existing procedures;
        Partnership agreements; and
        Chemical management plan (see Activity 2 in the Program Management section).

It is a good idea to compile all these materials (and other documents you think are important) into a living
document.' The document can be kept in an electronic or physical file folder.  Establishing a single location
for these materials can help the school to:

        Retain "institutional knowledge" of chemical  management conditions,  plans, and practices;
        Find information pertaining to chemical safety in your school or district; and
        Inform management, administrators, and district staff of SC3 Team projects that have been
        initiated, completed, or planned for future implementation.
          Tip: Treat your SC3 Plan as a 'Living Document'

              When creating a central place to store SC3 materials, it is a good idea to arrange
       them in categories to find things quickly.  One simple and effective way to do this is to create
       basic tabs or headers to organize related documents. Below we provide examples of some
       straightforward labels to consider using:
              Who's involved and contact information;
              Project plan and milestones;
              Inventories;
              Progress reports and annual summary of activities;
              Chemical management procedures (e.g., storage guidelines, inventory methods,
              etc.);
              Workbook worksheets;
              Partner materials (e.g., contact numbers, partnership agreements, etc.);
              SC3 Team meeting notes;
              Communication and publicity materials;
              Training materials; and
           >  Future project ideas.
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                         Chapter 4 - Put Your SC3 Program Into Action
DO WHAT IS MOST IMPORTANT FOR YOUR SCHOOL RIGHT NOW

Your SC3 Team has set priorities for a responsible chemical management program at your school. Now
you need to integrate the priorities of your program with those of your school.  We suggest you start by
taking actions that quickly achieve worthwhile results for your program and the school.
                               Where can we have the greatest impact now?
One way to energize your team is to identify things you can do right now to reduce risks quickly and at a
low cost. Revisit the issues identified during your visual tour and comprehensive evaluation (See Chapter
1, Activities 4 and 5) and discuss ideas to readily correct or improve your school's chemical management
situation. Exhibit 4-1 provides examples of solutions that can be implemented quickly and inexpensively.
Worksheet 4-1 in the Additional Tools and Examples section at the end of this chapter can be used to help
your team come up with some quick and easy solutions to reduce risks.
      Exhibit 4-1: Identify Low Cost, Quick Fixes to Chemical Management Situations
      Issue/Area of Need
            Solution
       What is Needed
 i.   Chemicals are stored in
    unlocked areas.
Purchase locks and distribute keys
to appropriate teachers and staff.
3 locks with keys: $45
    Chemical usage and storage
    areas are not clearly marked.
Purchase signs to post around
chemical usage and storage areas
to alert to the presence of
chemicals.
8 signs1: $24
Screws: $5
    Chemical handling
    procedures and safety
    instructions are faded,
    illegible, and missing from
    some chemical usage and
    storage areas.
Reprint/reorder documents relating
to chemical safety and ensure they
are present where chemicals are
used or stored and in a central
location.
Reprinting handling procedures:
Insignificant cost.
Request new instructions for
chemical handling from
manufacturer: Insignificant cost
1 Temporary signs can be downloaded and printed for free at the following Web site:
  http://www.compliancesigns.com/freesigns/
                                             4-4

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                         Chapter 4 - Put Your SC3 Program Into Action
To figure out where your SC3 Team can make some of these low-cost quick fixes, you will want to hold a
team meeting to discuss possible alternatives and assign tasks. Your SC3 Team will have many meetings
as your program moves forward, so we offer some suggestions to make your SC3 team meetings as
efficient, productive, and interesting as possible:

           Prepare and distribute an agenda before the meeting. Include the purpose of the meeting,
           a list of topics to address, and the amount of time that will be devoted to each topic's
           discussion.  Allow some flexibility to add or remove discussion topics.
           Let people know what to expect. Let your SC3  Team know in advance what you will talk
           about, what you hope to get out of the meeting, and what they could do to be best prepared.
           Be efficient with everyone's time. Members of your SC3 Team have other responsibilities,
           so you need to stick to the timing suggested in the agenda, including starting and ending on
           time.  If a topic requires more discussion, table it  for the next meeting. Move on to new topics
           when discussions begin to lose focus or become  repetitive.
           Identify action items and  next steps. Make sure your action items are clear and have
           realistic deadlines. Set the date and time for your next SC3 Team meeting so members can
           check their availability, suggest items for the agenda, and come prepared.
           Get feedback on how things went.  Be sure to talk with your SC3  Team afterwards to get an
           idea of what helped, what didn't, and see what can be changed for the next meeting.
              Tip: Making Consensus Decisions
                Remember, making a consensus decision does not require unanimous
           agreement.  Rather, a consensus decision occurs when everyone in a group can agree
           to live with the decision that is ultimately made. On major issues regarding priorities
           and approaches, it is important to get team members to weigh in.  Everything does not
           need to be put to a vote, but on important topics, the majority should agree and others
           should respect and support the team's decision. Below are a few suggestions for
           facilitating a consensus among SC3 Team members:

                  Encourage and consider input from every person;

                  Discuss disagreements and explore alternatives and potential compromises;

                  and

              >  Keep a record of important discussions to refer to in the future.
                                             4-5

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                          Chapter 4 - Put Your SC3 Program Into Action
                                  How do we set priorities for the first year?
After taking care of some low-cost quick fixes, your SC3 Team will want to prioritize what you want to do in
your SC3 program's first year. Remember, prioritizing tasks isn't necessarily a ranking of what is more
important (it wouldn't be part of your program if it wasn't important!), but a way to determine what to
concentrate on at this time.  Setting priorities for the first year will help everyone  involved focus on
specific tasks with near-term deadlines so they can begin their projects confidently.
Schools and/or districts are going to have different chemical management priorities.
Determining what to make a priority in your first year can depend on a number of factors,
SUCh as:                                                                               Allow enough time and
                                                                                      resources to carry out
       Urgency of the issue;                                                             each activityin y°ur
       Impact/benefit of the activity;
       Ability to make significant progress within the first year;
       Budget availability;
       Stakeholder support of the issue; and
       Competing school priorities.

In Exhibit 4-2, we provide an example of weighing the various factors that can affect how you determine
your SC3 program's priorities in the upcoming year.  Use worksheet 4-2 in the Additional Tools and
Examples section at the end of this chapter to help your team prioritize tasks. Review the goals and
activities you developed in Chapters 1 and 2 (you should have them organized in a central place) and the
worksheets used to help develop  specific tasks, including:

           Worksheet 2-3: SC3  Staffing Plan;
           Worksheet 2-4: Identifying Potential Obstacles and Solutions; and
           Worksheet 2-5: SC3  Labor Cost Estimate.
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                          Chapter 4 - Put Your SC3 Program Into Action
Exhibit 4-2: Identify SC3 Priorities for the First Year
Activity
/. Have a face-to-face meeting
with all school/district personnel
who purchase chemicals to map
out chemical usage and buying
patterns.
11. Have chemistry, vocational,
and art department heads, and
the lead custodian speak with a
chemical supplier(s) to discuss
alternatives to hazardous
chemicals currently used by the
school.
Hi. Each department evaluates
the list of less-hazardous
alternatives that would reduce
potential harmful exposures and
lower disposal costs.
iv. If possible, each department
creates a table of price
comparisons and a chemical use
plan that estimates chemical
quantities (and budget) needed
for the following year.2
v. Consult with person or
department in charge of
purchasing about alternative
chemicals and reduced
quantities of toxic chemicals to
purchase.
Resources Needed
A list of chemicals we
currently buy;, how
they are used, and the
purpose they serve.
A list of alternative
chemicals that we can
substitute for more
hazardous chemicals
currently in use.
Department head
decision to adopt the
recommended list of
alternative chemicals.
Revised curriculum
plan that details types
and quantities of
alternative chemicals
to be purchased.
A presentation or
memo about preferred
alternative chemicals
and more hazardous
chemicals to be
avoided.
Priority
High
Medium
High
Medium
Low
Makes Progress Toward which
Goals
Purchase less toxic chemicals;
establish a Green Chemistry
curriculum; minimize disposed
chemical waste.
Purchase less toxic chemicals;
establish a Green Chemistry
curriculum.
Purchase less toxic chemicals;
establish a Green Chemistry
curriculum.
Purchase less toxic chemicals;
minimize disposed chemical
waste.
Purchase less toxic chemicals;
minimize disposed chemical
waste.
2 To help staff forecast use and demonstrate reductions, visit the Office of the Federal Environmental
  Executive's Green Cleaning Pollution Prevention Calculator: http://www.ofee.gov/ianitor/index.asp
                                               4-7

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                         Chapter 4 - Put Your SC3 Program Into Action
In Exhibit 4-2, we focused on a single goal to illustrate how to prioritize activities to achieve a goal. Your
team may want to complete Worksheet 4-2 for each goal you plan to address in the first year of the
program. Remember, some activities make progress toward multiple goals, so you don't have to achieve
one goal before moving on to the next. You may find it easier to gain support or keep participants focused
by sticking to one goal, but activities with the greatest priority under any goal should be tackled first.
Be aware that your priorities may change as your program progresses through  its first year. Your team
should be prepared to reprioritize tasks and adjust to any significant changes.
MANAGE AND COORDINATE INITIAL SC3 ACTIVITIES

After determining what your SC3 program will do in its first year, it is important that everyone involved
knows what their roles will be. You should continue to actively manage tasks and address issues as they
arise to keep things running smoothly.
                                   How do we get team members started?
When beginning a task or activity, team members should be comfortable with their responsibilities and
know what they are going to do. Everyone helping with a task should be comfortable with the following:

           Knowing what is expected of them;
           Having a plan of action;
           Being aware of deadlines; and
           Having what they need to do their job (e.g., contact numbers for partners, instructional
           materials, etc.).

As you begin getting team members working on the priorities your program will address in its first year, your
team should consider keeping its agenda organized by scheduling activities and milestones on a calendar.
Try to make this calendar easy to update and access by the SC3 Team (e.g., one that is electronic and/or
Web-based) so everyone can be aware of what is happening. As members of your school's community,
your SC3 Team should have a good idea of when schedules get crowded, when people are available, and
when coordinated efforts are the most effective. Getting everyone together to plan out when to do things
and writing them down can help keep your SC3 program on track.
                                              4-8

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                          Chapter 4 - Put Your SC3 Program Into Action


You may even consider incorporating your school's calendar into your SC3 calendar to get an idea of when
other events may take up the school's attention, allowing your SC3 Team to craft a schedule that avoids
competing for the school's limited time and resources.  Maintaining a calendar will also help keep track of:

           Related events that may be linked with SC3 activities;
           Availability of partners;
           Training schedules;
           Team members' workload levels;
           Availability of budget;
           Upcoming deadlines; and
           Achieved milestones.

In Exhibit 4-3, we provide an example of an SC3 program calendar being used to keep track of significant
dates.  Write down initial ideas and schedules with your SC3 Team to develop a final, centralized version
(remember, if possible, try to make the calendar electronic and online so it can be easily updated and
viewed by the team).
Exhibit 4-3: SC3 Program Calendar
Color Code: 1 SC3 Event 1 School Event 1 Important Deadline
October
Sunday
1
8
15
22
29
Monday
2
9 -Draft of
purchasing
budget for
year due
16
23
30
Tuesday
3
10
17
24
31 - Holiday
party
Wednesday
4
1 1 - Teacher
workshop
18
25 - IT Partner:
setup chemical
tracking
program
Thursday
5 - SC3 Team
Meeting;
4 PM; Library
12
19-SC37eam
Meeting;
4 PM; Library
26
Friday
6
13
20
27
Saturday
7
14
21
28
Reminders for Next Month:
Conducting Inventory (11/15-16)
Training for Purchasing Staff (1 1/23 or 1 1/25)
Status Update to Teacher Workshop (1 1/28)
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                          Chapter 4 - Put Your SC3 Program Into Action
               Keep Referring to the Calendar
                  Have you ever worked on a project where no one met the deadlines or achieved
              milestones according to the schedule? Chances are that the project manager did not follow
              the timeline set forth at the beginning of the project. The team should focus on the SC3
              calendar at each meeting. Make adjustments if necessary, but keep the whole team
              focused on the 'living calendar.'
                            How do we keep our SC3 program running smoothly?
Making sure team members have all the necessary support to fulfill their responsibilities is key to making
your SC3 program's first year, and subsequent years, a success. Most likely, the best person suited to
keep things running smoothly is the SC3 Program Manager (which may be you!). As a
coordinating member of your team, they can be responsible for the following:
       Working closely with those performing tasks;
       Providing support and troubleshooting;
       Ensuring budget is available;
       Coordinating with multiple stakeholders, especially partners; and
       Working to meet deadlines while remaining flexible.
 Be aware of overburdened
team members and partners,
and re-task or relax deadlines,
     when necessary.
In addition to staying on top of separate tasks, we believe it important for the SC3
Program Manager to periodically bring the team together to discuss progress and next steps. Holding SC3
team meetings can help share the collective energy and keep everyone up to speed on the big picture.
Your SC3 Team should establish regular meetings after putting your program into action to review its
implementation and evaluate some of the following topics:

        Progress against the SC3 project schedule;
        Troublesome issues;
        New developments (if applicable);
        Schedule changes (if necessary);
        Next steps/new action items; and
        Recognition ideas.
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                         Chapter 4 - Put Your SC3 Program Into Action


TRACK PROGRESS AND TELL YOUR STORY

As your SC3 program kicks off, you'll want to keep track of what is getting accomplished. Other people'
begin to notice your team's efforts, and you will want to keep them informed of how your program is
progressing.
                                How do we track progress in the first year?
Tracking progress in the first year of your SC3 program involves making note of efforts undertaken and
results achieved.  Recognize any low cost quick fixes that your SC3 Team may have completed and the
benefits to the school. As your SC3 Team carries out activities during the first year, we suggest you
document the resulting benefits or improvements, especially when a task is completed.

Consider tracking outputs and  outcomes. For example, recording the number of outdated, leaking,  or
corroded chemical containers removed in a cleanout would  be an output, while counting the number of
students who were made safer because your school or district removed those chemicals would be an
outcome. Also keep in mind the  performance measures you may have developed in Chapter 1 in
Worksheet 1-3: Developing Performance Measures Based on Desired Goals to show progress made
toward your goals. Recording  information to support these measures will  help set a baseline for evaluating
improvements to chemical management in the future.

The SC3 program should strive to achieve lasting change in chemical management behaviors in your
school or district.  Having people who understand and support responsible chemical management is key to
sustaining it. Recording behavior changes is an excellent way to track the progress made by your SC3
program.  Exhibit 4-4 provides an example of a worksheet to track behavior changes within an SC3
program.  Worksheet 4-4 in the Additional Tools and Examples section at the end of this chapter can be
used to indicate behavior changes within your own school or district.
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                          Chapter 4 - Put Your SC3 Program Into Action
Exhibit 4-4: Measuring Behavioral Change
Original Behavior
(before program)
Chemical storage area
locks were not properly
secured.
Students did not always
wear personal protective
equipment (PPE) when
conducting experiments in
class.
Used and unwanted
chemicals were disposed
of down the drain.
Behavior After 3 Months of
Implementation
Chemical storage areas are
locked 60% of the time when
checked randomly.
Students wear PPE 40% of
the time when lab walk-
throughs are conducted.
25% of chemicals are
improperly disposed when lab
walk-throughs are conducted.
Desired Behavior
Chemical storage areas
are always locked when
no one is present.
Labs involving
chemicals have 100%
PPE use.
Chemicals are disposed
of according to the
appropriate laws and
regulations.
Benefit/Improvement
There is a reduced risk
of chemicals being
stolen or misused.
Students are safer from
accidental chemical
exposure.
School is in accordance
with the law and
contributing to a
healthier environment.
An excellent way to see behavior changes as a direct result of your SC3 program is to observe how people
behave before and after formal training or informal instruction. Your SC3 Team may want to think of what
behaviors to measure and make a point of addressing them in formal training, staff meetings, and
classroom settings. Consider your desired  behaviors when developing your training plan and curriculum
(see Activity 3 of this chapter).
                            When should we tell everyone what we are doing?
First impressions are important. Once your team has made some of the low-cost quick
fixes and begun to tackle first year priorities, you should let stakeholders and customers
know about the progress made to date and what you plan to do next.

Another important message you will want to  promote is how your partners have
helped your SC3 program. Acknowledging partner participation in your school or
district's chemical management efforts is a great way to raise awareness of what
your program is doing and strengthen the relationship with your partners.  Consider
some creative ways that your SC3 Team can recognize a partner for their dedication
to improving safety in your school or district.
Refer to Activity 3 in Chapter 3
    for utilizing existing
 communication channels to
communicate recent progress
   and upcoming efforts.
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                        Chapter 4 - Put Your SC3 Program Into Action
                What are some good ways my SC3 Team can recognize partners for their
                  contributions to responsible chemical management at our school?

              > Presenting an award at a public ceremony or school board meeting;
              > Contacting local media to inform them of a partner's efforts;
              > Publicizing their assistance in a school newspaper or Web site; and
              > Informing U.S. EPA of partner's successful cooperation.
In the textbox below, we provide an example of a brief press release to publicly recognize both a partner's
assistance, as well as successful chemical management efforts. Another way to show partners you are
appreciative of their assistance to your school or district is by presenting them with a letter of recognition.
Exhibit 4-5 provides a template for a letter of recognition that your school or district can adapt.  Consider
adding language and content to this template to develop your own letter showing your school's gratitude for
a partner's assistance.
                                 Sample Press Release:
                     LOCAL BUSINESS HELPS KEEP SCHOOL SAFE
         [Name of Partner Company] Helps [Name of Your School] Remove Unwanted
                                        Chemicals

        [Your school] is honoring its local partner, the [Partner Company], at a ceremony
        today for its continued commitment to making the school a safe environment for
        students and staff.  [Principal's name], the principal, presented a  plaque to the
        company for assisting the school's "Schools Chemical Cleanout Campaign"  team
        remove unneeded and outdated chemicals over the past week. The school
        recently began addressing its chemical management practices and called on
        [Partner Company] to volunteer their handling and removal services. [Partner
        Company] is also playing a significant role in helping [your school] develop
        training courses for teachers and staff, as well as working with the school to find
        safer chemicals to include  in their curriculum and maintenance program.  Both
        [your school] and [Partner Company] are confident that these  efforts will not only
        help save the school vital funds, but also help prevent future cleanouts and
        accidents.  Many schools across the country have recently taken  action to rid
        their facilities of unwanted  and potentially harmful chemicals that  may build up in
        chemistry labs  and custodial closets and are implementing chemical
        management plans to prevent future accumulations.
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                       Chapter 4 - Put Your SC3 Program Into Action
                    Exhibit 4-5:  Template for a Letter of Recognition
School Name and Address (use school letterhead if possible)

Date

Partner Contact
Partner Name and Address


Dear (Partner Contact),

       On behalf of (School Name), we would like to recognize the vital assistance (Partner
Name) provided in helping to keep our school safe by assisting our school's SC3 team with
(Partner Assisted Activity).

       The SC3 team is truly grateful that you were so generous with your time and resources in
assisting our efforts.  You should know that, because of your help, (Positive Benefit/Outcome of
Partner Assisted Activity). Your contribution to our school's responsible chemical management
program and concern for the well being of our community is greatly appreciated and key to our
continued success.

       We hope you are as pleased with the success of your efforts as we are, and we hope that
we can collaborate on similar projects in the near future.


Sincerely,

Name of Principal/School Board Member/Appropriate Department Head
                                           4-14

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                         Chapter 4 - Put Your SC3 Program Into Action


ACTIVITY 2 - ESTABLISH AND MODIFY EXISTING CHEMICAL MANAGEMENT PROCEDURES


ESTABLISH PROCEDURES AND INTEGRATE THEM INTO A CHEMICAL MANAGEMENT PLAN

Having clear, proven procedures in place is key to creating a lasting foundation for responsible chemical
management.  As you begin to put your SC3 program into action, your SC3 Team should revisit the existing
set of chemical management procedures and determine if any changes need to be made. Copies of
current procedures may be at the school, the district offices, and/or at the state level. The SC3 Team may
want to update existing chemical management procedures to make sure they:

         Take a comprehensive look at  the entire school  environment;
         Are clear and easily understood by the lay public; and
         Are up to date with laws and best practices.

Start by taking a look at the materials you pulled together in the beginning of this chapter. Consider the
support you will need to eventually implement any changes your SC3 Team decides to make to the
procedures. Ask yourself the following question: Is there a formal process my team needs to follow to make
these changes happen and from whom does the team need to gain approval? Actively involve senior
management with the responsibility for approving changes in procedures.

The chemical management procedures maintained by the SC3 Team form the foundation of your school's
chemical management plan.  A school chemical management plan defines how chemicals and products
containing chemicals are dealt with from  before they enter a school to the time they are used up or
disposed. The plan functions as a tool to  reduce risks, prevent future cleanouts, and create a healthier
school environment by providing an approved set of practices for managing chemicals that can be referred
to by students, staff and visitors. This document may include guidelines on:

       Hazard communication and response;
       Environmentally preferable purchasing;
       Curriculum;
       Chemical inventories;
       Safe usage guidelines;
       Chemical hygiene in areas where chemicals are used;              Visit the Resources Pa9e at
       Chemical labeling;                                           ^S?^ fl8' ^ f°U
       _,   .  .  .          ,                                        will find helpful material to
       Chemical storage;  and                                       assist with the deveiopment of
       Disposal.                                                   a chemical management plan.
                                             4-15

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                         Chapter 4 - Put Your SC3 Program Into Action

In Exhibit 4-6 we provide an example of common elements that may be found in a school's chemical
management plan. Your SC3 Team can use this template to organize your school's own procedures into a
comprehensive document outlining the proper guidelines for dealing with chemicals.  Notice that the
categories for procedures are similar to the tabs or headers you may have created when centrally
organizing all your SC3 materials in Activity 1 of this Chapter.
                    Exhibit 4-6: Chemical Management Plan Template
            General Rules and Procedures
               o   Responsibilities of students, staff, and administration
            Purchasing Guidelines
               o   List of qualified staff
               o   Inventory/tracking protocols
            Storage Procedures
               o   Storage guidelines
               o   Chemical storage access
               o   MSDS requirements
               o   Labeling protocols
            Chemical Usage Procedures
               o   Personal Protective Equipment (PPE) requirements
               o   Safety equipment requirements
               o   Waste reduction techniques
            Curriculum
               o   Acceptable experiments/procedures
            Training Program Information
               o   Topic-specific materials
            Disposal of Chemical Waste
               o   Regulatory requirements
            Emergency Spill and Accident Response
               o   Emergency procedures
               o   Reporting requirements
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                         Chapter 4 - Put Your SC3 Program Into Action


As your team sets out to develop or modify a chemical management plan, you should involve partners and
look at plans created and used by other schools and districts.  To give you an idea of what a chemical
management plan might look like, consult the following links for guidance and real world examples:

         Guidelines for Developing a Chemical Management Plan:
         o   http://www.cdphe.state.co.us/cp/lnstitutions/schools/ChemslnSchools/ChemMqmt.html:
         Laboratory Chemical Management Program for Vermont Schools (pg. 55):
         o   http://www.mercvt.org/PDF/finalreport.pdf: and
         Los Angeles Unified School District Office of Environmental Health and Safety School Laboratory
         Chemical Hygiene and Safety Plan:
         o   http://www.lausd-oehs.org/docs/CSC/Chemical%20Hygiene%20Plan.pdf.


ACTIVITY 3 -TRAIN APPROPRIATE GROUPS ON RESPONSIBLE CHEMICAL MANAGEMENT

IDENTIFY WHAT YOUR CHEMICAL MANAGEMENT TRAINING WILL LOOK LIKE

It will be important to train people on safe chemical management practices. This can be done in formal
settings (e.g., a set-aside time with an instructor and training materials) or informally (e.g., a five-minute
portion of a weekly staff meeting).  Some training  can be done informally as part of daily activities (i.e.
those involving the use of chemicals), while other training will require dedicated time.
                                         Who needs to be trained?
Anyone involved in an aspect of school chemical management should be considered a candidate for
training that your SC3 program will be undertaking.

As you think about the content of your training, consider who your audience will be.   Keep in mind that
different audiences need to know different things. A good approach to take is to develop a
core training module that outlines the basic ideas of practicing responsible chemical
management (e.g., dos and don'ts of storage, disposal, etc.).  Other modules may focus on
more specific subjects (e.g., conducting a chemical inventory, etc.).
Some typical audiences may be:                                                    Consider partners who may
                                                                                  be familiar with regularly
       p   ,                                                                     conducting training sessions
       Purchasers;                                                              (e g^ fire department, etc.).
       Teachers;
       Custodial staff;
       Administrators; and
    >  Students.
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                         Chapter 4 - Put Your SC3 Program Into Action
                              What topics should I include in my SC3 training?
We suggest that the content of your training sessions should focus on what attendees can do to make
schools safer and protect the environment. At a minimum, the training should cover the procedures that
the school has adopted. Whenever the SC3 Team changes a procedure or practice, make note of who
needs to know and choose the most efficient means for informing them. Ask partners and community
members with chemical management experience to help design your training.  You should also research
training methods used successfully by other schools and organizations to adapt and develop your own
method. To save you time,  we provide a list of links to materials you can tailor to your school's situation
and procedures. Feel free to use these or seek out other training materials:

       OSHA's Model Training  Program for Hazard Communication
           o  http://www.osha.qov/dsq/hazcom/MTP101703.html:
       British Council's Training of Trainers Manual
           o  http://www.britishcouncil.org/pakistan-traininq-of-trainers-manual.pdf:  and
       See if any local, regional, or state agencies (http://www.epa.gov/epaoswer/osw/stateweb.htm)  have
       any helpful guidance material on developing effective training.
Exhibit 4-7 provides examples of what you may want to cover with each audience.  Use Worksheet 4-7 in
the Additional Tools and Examples section at the end of this chapter to help you develop a plan of what
each audience should know.
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Chapter 4 - Put Your SC3 Program Into Action
Exhibit 4-7: SC3 Training Topics by Target Audience
Training
Topics
Purchasing
Storage
Inventory
Usage
Disposal
Emergencies
Target Audience
Teachers
What chemicals
should not be
purchased; potential
less hazardous
alternative
chemicals.
How to understand
an MSDS; proper
storage and labeling
protocol; tracking
what and how much
of each chemical is
in storage; spotting
leaking/corroded
containers.
How to conduct an
inventory (either
comprehensive or
chemicals they are
responsible for).
Proper chemical
handling; promoting
safe techniques and
PPE use; minimizing
waste and
preventing spills
during use.
What can and can
not be dumped down
the drain; how to
handle used
chemicals; where
and how to store
used chemicals for
off site removal.
Emergency
procedures outlined
in Chemical
Management Plan.
Custodians
What chemicals
should not be
purchased; potential
less hazardous
alternative
chemicals.
How to understand
an MSDS; proper
storage and labeling
protocol; tracking
what and how much
of each chemical is
in storage; spotting
leaking/corroded
containers.
How to conduct an
inventory (either
comprehensive or
chemicals they are
responsible for).
Proper chemical
handling; minimizing
waste and
preventing spills
during use.
What can and can
not be dumped down
the drain; how to
handle used
chemicals; where
and how to store
used chemicals for
offsite removal.
Emergency
procedures outlined
in Chemical
Management Plan.
Administrators
Complete
understanding of the
school's purchasing
policy.
How to understand
an MSDS; proper
storage and labeling
protocol.
Complete
understanding of the
steps involved in
conducting an
inventory and
tracking chemicals.

Complete
understanding of the
school's disposal
policy.
Emergency
procedures outlined in
Chemical
Management Plan.
Purchasers
Complete
understanding of
the school's
purchasing policy.
General knowledge
of storage and
labeling protocol.
Understanding of
how chemical
inventories may
influence
purchasing
patterns.

Knowing which
purchased
chemicals have the
highest disposal
costs.
Knowing which
purchased
chemicals present
potential hazard.
Students

How to
understand an
MSDS; spotting
leaking/corroded
containers.

Handling
chemicals; using
safety
equipment;
minimizing waste
and preventing
spills during
experiments.
What can and
can not be
dumped down
the drain.
What to do in case
of spill/accident.
Target audiences should be aware of and understand the federal state, and local regulations that may impact a school's
chemical management program.
4-19


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                          Chapter 4 - Put Your SC3 Program Into Action
After you have trained everyone on the basics of responsible chemical management, we recommend that
you conduct 'refresher' training periodically (see Activity 3 of Chapter 5). Also, consider how and when you
will need to train new teachers and staff on responsible chemical management.
                                        Who will perform the training?
We all get more from teachers who really know their stuff. Good chemical management trainers can come
from your SC3 Team, the staff at your school or district, or a partner or member of your local community.
Look to individuals with a specialized interest or knowledge of chemical management topics, especially if
they helped design some of your training material; a familiarity with the subject, your school, or school
procedures can make their participation even more valuable.
             What to Look for in a Chemical Management Trainer
                Trainers who are dynamic speakers and can speak from experience are more effective
           'and memorable. As you consider who will lead training sessions, consider looking for those
            who have:
                   Expertise on the subject;
                   Practical, real world experience;
                   Effective communication skills; and
                >  An understanding of the school's chemical management situation.
                                     How can I best plan training events?
After considering who will be trained and what the content of their training will be, your
SC3 Team will need to decide where and when the training will be held.  Try to take
advantage of existing venues or forums (e.g., classroom settings, weekly staff meetings,
teacher workshops, etc.) to reach your audience and avoid imposing new time
commitments.  If you are unable to use an established forum or event to conduct
training, work to find a time that is the most convenient for your audience to attend.
                                               4-20
   Consider other types of
 training events (e.g., CPR,
 emergency planning, etc.)
 already in place, not only for
 effective training techniques,
but also as potential forums to
    include SC3 training.

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                         Chapter 4 - Put Your SC3 Program Into Action


Exhibit 4-8 gives some helpful tips on how to conduct a formal training session.


                     Exhibit 4-8: Basics of Conducting Formal Training


  >   Have a Message. You should know what you want people to learn from each training session.
      Have specific objectives that you want the audience to know when they leave training.
  >   Keep it Interesting. Anyone can stand in front of a group and read from a manual; the point of
      holding a training session is to bring the material to life and make it memorable. Try to incorporate
      ways to make your training material more easily absorbed (e.g., show a video, have group
      interaction, conduct hands-on exercises, etc.).
  >   Be Efficient. People have other responsibilities to keep and drawn out sessions may cause them to
      lose interest.
  >   Follow up Training.  Because you will ideally conduct training at least once a year, you should
      continue to evaluate how effective each session is. Getting feedback from attendees, observing
      behavior changes, and having brief quizzes to measure how well material was absorbed are great
      ways to measure results and assess the effectiveness of training to identify areas for  improvement.
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                          Chapter 4 - Put Your SC3 Program Into Action


  SECTION 2: SPECIAL CHEMICAL MANAGEMENT PROJECTS

  This section presents three detailed projects that are common among successful chemical management
  programs. At the very least, we highly recommend that you develop a chemical inventory.

  PROJECT 1 - PERFORM AN INVENTORY OF ALL CHEMICALS AND CHEMICAL PRODUCTS 3
                               Why should I conduct a chemical inventory?
  Completing a chemical inventory not only provides your school or school district with a better understanding
  of your chemical management situation, but also serves as a tool for future chemical management. A well-
  organized inventory provides information on chemical type, quantity, purchase date, and location. Having
  detailed and recorded knowledge of the chemicals present at your school or in your school district is
  important to making responsible purchasing decisions,  considering safe storage arrangements, evaluating
  use, and accurately estimating removal and disposal costs.
       Tip: What is included in the inventory?
         At a minimum, we suggest that a chemical inventory include the following information for each
         chemical or product:
                Chemical or product name;
                Place(s) where material is being stored (room, name, building);
                Program(s) using the material and whether it is currently being used;
                Date of purchase (if unknown, write "prior to" and the inventory date); and
                Amount of material currently in school (by location).
3 This material (and the Tip: What is included in the Inventory?) comes from the Florida School Chemical
  Cleanout Manual and is being used with permission from the Florida Department of Environmental
  Protection, Division of Waste Management, Bureau of Solid and Hazardous Waste:
  http://www.dep.state.fl.us/waste/quick topics/publications/shw/hazardous/SC/SCC Manual.pdf.
                                              4-22

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                          Chapter 4 - Put Your SC3 Program Into Action
                           What is involved in performing a chemical inventory?
Establishing an accurate inventory is important to maintaining a safe and healthy learning environment.
Prior to completing an inventory, you should gather relevant pieces of information to determine where to
find all the chemicals in your school or district and the overall scale of your chemical management program.
You should have the following pieces of information ready before you begin your inventory:

           Number and type (e.g., high school, vocational) of schools;
           Location of schools and proximity to each other;
           Locations of chemicals (within school facilities);
           A completed Worksheet 1-1 (Evaluating Your School's Chemical Management Situation,
           Policies, and Procedures) for each facility to briefly outline their chemical management
           situation, policies, and procedures;
           School staff responsible for those locations;
           Hours and dates schools can be accessed to inventory chemicals; and
           Previous chemical incidents.

As you conduct your inventory, remember to note any chemical that appears to be appropriate for attention.
A chemical may be appropriate for attention when it is:

           Stored in a container that is in poor condition (e.g., corroded,  has crystals growing around the
           cap);
           Stored in inappropriate containers, such as buckets or reused food containers;
           Expired;
           Unidentified or not clearly labeled with the chemical name, date, and storage and handling
           requirements;
           Stored near incompatible chemicals (alphabetical storage is also inappropriate);
           Stored on deteriorating, unstable, or inappropriate shelving (e.g., flammables stored on
           wooden shelves, corrosives stored on metal shelves); or
           Unsecured.

We also suggest that you note whether particular chemicals appeared to be unneeded or in surplus
quantities.

Remember, conducting a chemical inventory may pose  risks to the individuals taking the inventory;
therefore, we recommend that only those who have technical knowledge about the chemicals be involved.
Students should not participate in inventories! In some cases an inventory may take many hours to
complete—it is important not to underestimate the amount of time required to complete the inventory.
Administrators may not be aware of the time commitment and the importance of an accurate  inventory;
therefore, it is important to inform them.

If you are new to the school and/or a recent inventory has not been conducted, you should be especially
cautious. Serious injury can result from touching or moving chemicals that have become shock sensitive or
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                          Chapter 4 - Put Your SC3 Program Into Action


pressurized. If any chemical container is unmarked, bulging, leaking, rusted, cracked, has a degraded top,
contains a liquid above a solid, or crystals in a liquid, we recommend that it not be moved unless you are
sure that it is safe to do so.  If you feel that conducting an inventory might not be safe with current in-house
staff, we encourage you to seek professional help from a qualified partner or outside source.
    Here is a list of things to note when completing an inventory:

    1.  Allow ample time to conduct the inventory.

    2.  Know where all chemicals used in the school are located and that you have access to those
       locations. Some of the places you may find chemicals are science classes and laboratories, art
       classes / studios, maintenance sheds, cleaning closets, and office supply areas.

    3.  Have a plan to deal with potential explosives if they are found and verify that everyone listed in the
       plan is familiar with their role. We suggest that you contact your county's sheriffs office for
       information about access to the services of a "bomb squad," if needed. Also, we suggest that you
       notify your local sheriff and fire departments that you will be doing an inventory, especially if this is
       the first inventory in several years.

    4.  Work in pairs, never alone. It is best if one team does the entire inventory.

    5.  Areas in which you are working should have adequate lighting and ventilation.

    6.  Wear appropriate Personal Protective Equipment (PPE). This should include gloves, chemical
       splash goggles, a lab apron, and closed-toed shoes.

    7.  Have quick access to a phone and a recently tested eyewash and safety shower.

    8.  Have a written response plan nearby in case of a spill or accident and verify that all participants
       have read it in advance.

One person should act as the recorder and the other person should read the names of the chemicals. The
reader should confirm that the names of the chemicals have been recorded accurately.  While completing
an inventory, you may identify outdated, unknown, or unnecessary chemicals in need of disposal. Project 2
discusses what is involved in conducting a chemical cleanout to rid your school of these potentially harmful
chemicals.
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                         Chapter 4 - Put Your SC3 Program Into Action
                       What steps do I take after completing a chemical inventory?
After completing your comprehensive inventory, we recommend that you meet with your team to discuss
potential next steps for your SC3 program to take. In Exhibit 4-9, we provide an example of a checklist that
can be completed after conducting an inventory to further evaluate your school or district's chemical
management situation. The SC3 Team can use Worksheet 4-9 in the Additional Tools and Examples
section at the end of this Chapter to help evaluate your chemical management situation after conducting an
inventory.
Exhibit 4-9: Post-Inventory Evaluation of your Chemical Management Situation (Example)
Question
How many chemical containers are:
1) Unlabeled?
2) In poor condition?
3) Expired?
4) No longer used or essential?
5) Unsecured?
How much of the following chemical
do I use every year?
Chemical A
Chemical B
Chemical C
Given the amounts above, how many
years worth of chemical do I currently
have?
Status
1) 22
2) 15
3) 10
4) 30
5) 145
Chemical A: 1 gallon
Chemical B: 50 ounces
Chemical C: 100 ounces
Chemical A: 3 years
Chemical B: 200 years
Chemical C: 27 years
Action Taken
Properly dispose of any
mismanaged chemicals in
compliance with applicable
regulations.
See next step.
Keep only 1 year supply;
Dispose of remaining chemicals.
After conducting an inventory and discussing your findings with your team, you may decide that the
chemicals you have stored in your school or district facilities are not being mismanaged. This is great
news! If your SC3 program determines that chemical mismanagement does not need to be addressed, it
will allow you to focus on other areas of your program. However, if you do decide that the level of
chemicals being managed may present a health and/or safety risk to students and staff, you should
consider conducting a chemical cleanout (see Project 2: Secure a Chemical Cleanout Professional).
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                           Chapter 4 - Put Your SC3 Program Into Action
  PROJECT 2 - SECURE A CHEMICAL CLEANOUT PROFESSIONAL
                                  Why should I  conduct a chemical cleanout?
  If your chemical inventory identified chemicals in your school and your SC3
  Team determines that they present a health and/or safety concern, you
  should consider performing a chemical cleanout.  A chemical cleanout
  addresses immediate threats, as well as unneeded chemicals and, together
  with other responsible chemical management practices, helps to prevent
  accidents before they happen. Conducting a chemical cleanout that
  includes proper disposal is an important step to creating a safer school that
  protects the health and safety of students and staff. A chemical cleanout
  may be necessary in science laboratories, art and vocational classes,
  facility maintenance areas, janitorial closets, and even the nurse's office.4
  This section of the workbook provides information to help you with your
  chemical cleanout and disposal.
   Here are some outdated and
improperly stored chemicals in need
of removal and disposal. (From The
Local Hazardous Waste Program in
   King County's Rehab the Lab
  program, in King County, WA)
                                  How do I get started on a chemical cleanout?
  There are four sub-activities for effectively managing the chemical cleanout and disposal process:

         A.  Evaluate your chemical inventory and create a list of chemicals to dispose (a disposal list);
         B.  Identify a qualified professional(s) to assist in the cleanout and disposal process;
         C.  Prepare for chemical cleanout and disposal; and
         D.  Take additional steps to reduce the need for future chemical cleanouts.
4 Please see http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/manaqe.htm for additional details
  on areas in your school where chemical hazards may be found.
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                          Chapter 4 - Put Your SC3 Program Into Action


SUB-ACTIVITY A - EVALUATE YOUR CHEMICAL INVENTORY AND CREATE A LIST OF CHEMICALS TO
DISPOSE (A DISPOSAL LIST)

Your first activity in the cleanout process is to review your initial inventory (See Project 1:
Perform an Inventory of All Chemicals and Chemical Products) and develop a disposal list of
chemicals that should be removed. This list can be created using information from your initial
chemical inventory and should be as detailed and as comprehensive as possible.  You
        .,..,...       .         ,.e  ,    r   •   11     jii      i/o        If you are not qualified to
can use this information in securing a qualified professional to conduct a cleanout (See     do an initia| evaluation of
Tip: What do I include in the disposal list?). Completing this disposal list will help you to:     your chemicals, ask a
        ........             .    ..        .      ..      ..  .    .                technical expert from
        Identify chemical management problems or cleanout issues that need                 your partner team
        immediate attention or action (e.g., situations that might pose health and safety
        concerns to students and staff, such  as potential explosions or fires);

        Rank and prioritize schools and areas of the school(s) needing cleanout;

        Estimate the types and quantities of chemicals for removal  in the cleanout;

        Identify chemicals needing special handling (e.g., radioactive or explosive, shock sensitive,
        unknown); and

        Identify activities that need the expertise of a qualified professional (e.g., removing and disposing
        of chemicals).
You can include this disposal list in your Request for Proposal (See What is A Request for Proposal? in
Sub-Activity B) to give bidders a better indication of what you have on hand and help them estimate the
amount of help that you need. After you secure a qualified partner or hire a chemical management
contractor, they can  use your disposal list as they assess the extent of the problem at your school. Often,
they find additional chemicals that may need to be removed from your school, so don't be surprised if that
happens.
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                          Chapter 4 - Put Your SC3 Program Into Action
      Tip: What do I include in the disposal list?
       A disposal list typically contains information on the following (you may not be able to find all of this
information, so provide as much as you can):
             Types of chemicals including chemical name and/or hazard classification;
             Chemical Abstract Service (CAS) registry number;
             Chemical concentration;
             Chemical expiration date;
             Type and condition of storage container (e.g., glass bottle, broken seal);
             Amount of each chemical (e.g., liters, milliliters);
             Location of chemicals in school and/or location within classroom or storage area; and
             Chemicals requiring specialized handling or disposal techniques (e.g., radioactive, explosive,
               shock sensitive, unknown).
       The information included in Exhibit 4-10 is provided as an example disposal list. Worksheet 4-10 in
the Additional Tools and Examples section at the end  of the chapter can be used to gather information on
chemicals you may consider disposing.
Exhibit 4-10: Chemical Disposal List (Example)
Chemical Name
1-Propanol
Acetone
Aluminon
Aluminum
Aluminum
Aluminum Sulfate
CAS Number
71-23-8
67-64-1
569-58-4
7429-90-5
7429-90-5
10043-01-3
Concen-
tration
100%


100%
100%
100%
Exp.
Date

none
none
none
none
none
Amt. & Size of
Container for
Disposal
2x500 ml
2x4 L
25 grams
2oz
2x500 ml
1x5lb
Type of
Container
poly
poly;
metal
glass
plastic
cup
glass jar
glass
Amount
(est.)
750
4.5
20
5
850
3.25
Storage Location
Flammable Cabinet,
Room 202
Flammable Cabinet,
Room 202
Chemical Storage
Shelves,
Room 110
Flammable Cabinet,
Room 202
Chemical Storage
Shelves,
Room 110
Flammable Cabinet,
Room 202
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                            Chapter 4 - Put Your SC3 Program Into Action


  SUB-ACTIVITY B - IDENTIFY A QUALIFIED PROFESSIONAL(S) TO ASSIST IN THE CLEANOUT AND
  DISPOSAL PROCESS

  It is important to have a qualified and experienced professional to handle the chemical cleanout process,
  including packing, removing, transporting, and disposing of the chemicals.  You may have this expertise in
  your school district; however, it is likely you may need to call on partners or outside professionals. In the
  Introduction to this Workbook, we identified a variety of potential partners who may contribute to the
  success of your SC3 program. For example, organizations, such as chemical  manufacturers and
  engineering firms, fire and police, and colleges and  universities  are good sources for advice or labor in the
  performance of chemical cleanouts and disposal. These potential partners  can help to:

           Identify additional chemicals to add to your disposal list;
           Identify chemicals that can be safely disposed of without a chemical cleanout professional5;
           Prepare chemicals for disposal;
           Develop requests for proposal for cleanout service providers;
           Coordinate your cleanout and disposal with other community hazardous waste events, if
           possible, to reduce the cost of disposal; or
           Dispose of unwanted chemicals.

  For each partner that may assist with chemical cleanout and disposal,  it is important to  define roles and
  responsibilities.

  Remember that only qualified personnel should be involved with chemical handling, packing, removal, and
  transport to bring about a safe and successful cleanout. Disposal of chemicals and chemical waste must
  be done in compliance with local and state regulations, as well as with the federal Resource Conservation
  and Recovery Act.  A qualified professional will be aware of the proper cleanout and disposal techniques
  and applicable regulatory requirements.  In addition, using qualified personnel will help  to minimize
  chemical exposure to students and staff, environmental damage, and the likelihood of accidents and their
  associated costs. One way to evaluate and competitively select a qualified  hazardous waste disposal
  contractor is to issue a request for proposal (RFP).
                     / don't know much about cleanout and disposal professionals. How do I find one?

                   Check your state environmental agency Web site for company listings and
                   information. While most agencies cannot recommend a specific company, they may
                   be able to provide you with contact information for a number of service providers.

                   Check with your school's business manager(s) for companies that may have
                   provided similar services in the past.

                   Perhaps a college or university or an  industry partner in your area can perform the
                   cleanout and disposal or has a contract you can tap into.
5 If you are unable to involve a qualified professional to do this, it may be safer to wait until you have secured
  a contractor who can safely determine which chemicals, if any, can be disposed of without a contractor's
  professional removal.
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                          Chapter 4 - Put Your SC3 Program Into Action
                                       What is a Request for Proposal?
A Request for Proposal (RFP) is an invitation for service providers to bid on a contract to provide a service
or product to a customer.  In an RFP, you spell out the services and qualifications you seek in a
professional and describe your needs in sufficient detail so that vendors can bid a realistic, competitive
price. In response to an RFP, qualified professionals submit a proposal describing how they plan to meet
your requirements.  For a sample RFP, see Exhibit 4-11 in the Additional Tools and Examples section at
the end of this chapter.

We have provided examples of common components of an RFP for chemical cleanout and disposal
services. Every situation is unique, so tailor your RFP to your specific needs and your state and local
requirements! You should consult with your school or district's legal counsel to be sure you have included
all legal requirements for a contract.

Exhibit 4-11 in the Additional Tools and Examples section at the end of this chapter is an actual RFP that
was used by a regional education unit to solicit bidders to  assist with school chemical cleanout and
disposal. In developing an RFP, it is important to define "evaluation selection criteria" that reflect your
particular program needs so that bidders can write responsive proposals.
     Tip: Common Components of an RFP
           Statement of work or "SOW" (i.e., the services you want a vendor to provide);
                o  Chemical inventory services (see Project 1 in this chapter for more information)
                o  Packing
                o  Transport
                o  Treatment and Disposal
                o  Reconciliation of items removed/disposed or provide waste manifests
           Evaluation selection criteria;
           Period of performance (i.e., the timeframe over which you require the SOW services to be
           performed);
           Specifications of what you consider to be a qualified service provider (e.g., can the contractor
           provide a sufficient, competent, and trained staff to receive, handle, weigh, package, store,
           and transport chemicals?);
           Insurance requirements;
           Items to include in cost estimate (Refer to the Question titled "How do I estimate cleanout and
           disposal costs?" in this chapter for tips on what is typically included in a cost estimate); and
           Your organization's standard legal or regulatory language.
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                          Chapter 4 - Put Your SC3 Program Into Action
                                          How do I advertise an RFP?
There are a variety of ways to communicate the opportunity for qualified vendors to bid on your RFP.
Typically, organizations advertise on their Web sites, in trade publications, on e-mail distribution lists, or in
local newspapers. Your organization may have a
special process for RFPs. You should ask your
manager or supervisor for specific guidance on
how and where to advertise RFPs. Consider
other venues that may appeal to chemical
cleanout service providers, such as trade
                                                  Advertising your RFP in a local newspaper is
                                                  easy.  With a simple transmittal letter, you are
                                                  on your way! For example:
publications. Also consider asking partners to
help with advertising and distributing your RFP.
                  ^
        Keep timing in mind when issuing
        an RFP. Consider timeframes for
        budgeting, advertising, collecting
        vendor responses,  and your SC3
              program's goals.
Hometown Newspaper
Attention: Legal Advertising

To Whom It May Concern:
Please run the enclosed "Request for Proposals" in
your paper on January 6, 9, and 17, 2009.  Billing for
these ads along with a tear sheet should be forwarded
to my attention at the address above.

Please confirm that you have received this request, by
contacting me at (123) 456-7890 or
myemail@myorganization.com. Thank you in advance
for your prompt action and cooperation in executing
this request.
                                   How do I select a qualified professional?
You may have multiple entities that respond to your RFP. So, how do you compare them and find the one
that is right for you? You want the vendor to be both qualified and propose an approach that meets your
needs. Also check to see if the RFP includes minimum vendor qualifications. Exhibit 4-12 provides a
sample checklist to document prospective vendor qualifications. In addition to ensuring that a vendor is
qualified, you can evaluate a vendor by how well it tailors an approach to meet your needs.  In reading a
vendor's proposal, "score" them by the quality and completeness of their approach to performing all of the
services in your SOW. For example, a vendor that proposes an approach guaranteeing that all work will be
done after school and on weekends may be a better choice because of minimal  potential disruptions to
school operations.  Also remember that while your evaluation and selection of the most qualified vendor is
an ideal approach, your school or district may have a selection  policy (e.g., lowest qualifying bid) that
affects your decision.
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                          Chapter 4 - Put Your SC3 Program Into Action

                        Exhibit 4-12: Vendor Qualifications Checklist

Vendor Name:	
Ensure that your vendor meets all applicable Federal, State and Local requirements before selecting.

The Vendor:

1.   Can pack the chemicals?

2.   Can transport the chemicals?

3.   Can treat and dispose of the chemicals?

4.   Can reconcile the chemicals?

5.   Has appropriate bonds, licenses, and insurance?

6.   Has chemical technicians that have proper training and certifications?

7.   Has truck drivers that have proper training and certifications?

8.   Can provide acceptable  USDOT compliance history?

9.   Can provide acceptable  USEPA compliance history?

10. Can provide acceptable  OSHA compliance history?

11. Can provide acceptable TSDF compliance history?

12. Has all the appropriate permits for transportation?

13. Has all the appropriate permits for storage?

14. Has all the appropriate permits for treatment and disposal?
               Tip: Other questions to help compare potential cleanout professionals

                  What are the qualifications and experience of your staff?
                  Will you be using subcontractors for any of your services?
                  Can your company provide copies of necessary permits?
                  Have you had any citations or violations in the past 5 years?
                  Can you provide references?
                  What is your plan for responding to the SOW (i.e., what is their process or
                  approach to performing the required services and achieving objectives
                  outlined in the RFP)?
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                          Chapter 4 - Put Your SC3 Program Into Action
                               How do I estimate cleanout and disposal costs?
Your RFP should request potential qualified vendors to include a price quote or cost estimate.
Thus, you should provide sufficient details in the RFP to enable potential bidders to have a
basis for their price quotation (e.g., identify the number of schools to be cleaned out, the
types and quantities of chemicals evaluated in the inventory, etc.).  The collection of bidders
will "define the market price," but be  mindful of price quotes at the low and high ends of the
spectrum - attempt to understand the underlying assumptions. Exhibit 4-13 is an example      Typical cleanout and
of a price quote that a qualified professional may send in response to your RFP; it contains    disposal costs range from
some typical costs associated with chemical cleanout and disposal.
                              Exhibit 4-13: Sample Price Quote
 Re:  Disposal of My High School's Waste

 Our company is pleased to submit a detailed quotation for the management, transportation and disposal of
 the hazardous materials located at My High School.

 Given our understanding of the scope of work per the chemical inventory that was provided us, we present
 the following Price Estimation to complete this project.

 This estimate specifies the following services to be carried out and the requirements to be met:

        Materials will be classified  and marked with a label giving the chemical name or composition, or
        the MSDS must be available.  The cost for marking each container is $XX.OO

        Materials will be segregated by compatibility, hazard class and disposal requirements.  The cost
        for segregation of materials is $XX.OO.

        Lab packing materials into drums and/or DOT approved over packing containers.  The cost of lab
        packing each drum is $XX.OO.  Lab packs will be labeled to meet state and federal regulations.

        Completion  of appropriate documentation,  manifests, and shipping documents.  The cost for
        preparing these documents is $XX.OO.

        Lab packs will be transported to  our facility for storage/transfer/processing for final disposal.  The
        cost for these services is $XX.OO.

        Materials that are  not included in this price quote include:  radioactive materials, shock sensitive
        compounds, biological  wastes,  explosives,  and pressurized cylinders  and/or gases  unless
        otherwise stated in the attached Price Estimation.

        This proposal is valid for 45 days from the issue date.
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                         Chapter 4 - Put Your SC3 Program Into Action
                                   Are there ways to lower disposal costs?
You may want to consider ways to potentially minimize the costs associated with the disposal of the
chemicals removed from your school. State and local organizations use a variety of approaches that result
in cost-effective solutions.  Please keep in mind that not all of these examples may be applicable to your
situation. You should explore the  legal or regulatory impacts of any technique before getting started!
Exhibit 4-14 provides examples of some real world cost saving techniques that you can consider for your
SC3 program.
Exhibit 4-14: Examples of Cost Saving Techniques
Technique
Leveraging a household
hazardous waste (HHW)
collection event for chemical
disposal.

Use a knowledgeable partner to
help identify substance(s) that
can be safely disposed of without
a hazardous waste contractor.

Work with a partner organization
to take advantage of an existing
disposal contract.

Incorporate performance-based
contracting in your RFP.

Negotiate disposal rates by
combining multiple cleanouts.
Type of Cost
Savings
Transportation and
labor.

Packing, labor,
transportation, and
disposal.

Disposal (lower rates)

Disposal, chemical
purchasing, future
chemical
management.

Lower disposal rates
and reduce cost for
lab packing, labor,
and transportation.
Real World Example
The Tennessee Department of Environment and
Conservation used an existing contract to do HHW
collection and facilitate simultaneous cleanouts of school
labs.

The Northwest Tri-County Intermediate Unit in Pennsylvania
leveraged the State environmental agency to review
inventories and denote items that could be safely disposed.

In Iowa, in the early stages of their chemical management
efforts, the Metropolitan Waste Authority partnered with EPA
Region 7 to use existing chemical management services.

A pilot program in Lansing, Michigan incorporated
performance-based contracting clauses to encourage
cleanout professionals to find ways to minimize costs, while
providing other chemical and resource lifecycle services.

Qualified school personnel in the Fort Worth, Texas'
Independent School District collected smaller amounts of
waste from all district schools prior to one large consolidated
disposal to save on transportation costs and negotiate a
lower disposal rate per drum of hazardous waste.
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                            Chapter 4 - Put Your SC3 Program Into Action
Exhibit 4-14: Examples of Cost Saving Techniques (cont'd)
Identify agency assistance for
removal of radioactive wastes.

Research your chemical
management regulations to
identify potential ways to lower
costs.
No-cost removal of
radioactive
chemicals.

Reduced packing and
transportation costs.
The Illinois Emergency Management Agency has launched
a program to help schools safely dispose of radioactive
materials. IEMA officials collect the materials and send
them to a radioactive waste disposal facility. The Illinois
program is one of several around the country; other states
include Connecticut, Colorado and Vermont.6

Rochester City School District, New York environmental
personnel talked to regulators about the amounts and types
of chemicals that could be legally and safely transported by
the school district to a proper disposal facility.
  SUB-ACTIVITY C - PREPARE FOR CHEMICAL CLEANOUT AND DISPOSAL

  After you identify a qualified cleanout professional or other qualified partner and enter into an appropriate
  agreement or contract, the chemical removal and disposal process can begin.  Communication and
  coordination with the person performing the cleanout and disposal is important. You should obtain a copy
  of their recommended plan of action for the cleanout and disposal project and ensure you understand and
  agree with the steps and details. Such upfront discussion will minimize performance risks and bolster
  chances that the project will be completed safely, with minimal disruption, and within budget.

  For instance, you may want to ask the following questions so that you know what to
  expect when the cleanout occurs:


             When during the school day/week will the cleanout occur?
             Is there anything our school can do to help  you prepare for
             the cleanout (e.g., mark chemicals slated for removal)?
             What safety precautions should we take?
             What areas of the school will you need access to?
             What school staff needs to be present during the cleanout?
             What should I expect on the day of the cleanout (i.e., what
             are the steps of the cleanout process)?
Due to financial or other constraints, you may
  not be able to remove all of the identified
  chemicals at one time from one or more
    schools. Any amount of potentially
 dangerous chemicals that can be removed
  from a school helps to prevent accidents
         before they happen.
  While you may not personally be involved in cleanout activities, we suggest that someone knowledgeable
  about the conditions and locations of chemicals in your school be available to answer questions and
  facilitate communication to help guarantee cleanout success.
6 Learn more about the Illinois Emergency Management Agency's Orphan Source Recovery Program-High
  School Initiative: http://www.state.il.us/iema/publications/pdf/Radiation  In Schools.pdf
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                         Chapter 4 - Put Your SC3 Program Into Action


SUB-ACTIVITY D - TAKE ADDITIONAL STEPS TO REDUCE THE NEED FOR FUTURE CHEMICAL CLEANOUTS

Congratulations on completing the chemical cleanout of your school.  We recommend that you take the
appropriate steps to ensure that you don't have to undertake another cleanout again.  It will be important to
develop and adhere to responsible chemical management practices to minimize the chance of having to
conduct future cleanouts.  Chapter 5 of this Workbook provides some helpful guidance in this regard:

       You should keep your policies and procedures current by periodically evaluating your SC3 program
       (Activity 2: Establish and modify existing chemical management procedures); and
       See the Textbox "Key to Sustained Success: Maintaining Chemical Inventories" on page 5-1.
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                         Chapter 4 - Put Your SC3 Program Into Action

PROJECT 3 - IMPLEMENT A GREEN CURRICULUM

PUTTING TOGETHER A GREEN CURRICULUM
                                       What is a "green curriculum"?
A "green curriculum" involves the use of more environmentally friendly, less hazardous chemicals in the
smallest possible quantities.  The purpose of a green curriculum is to reduce waste, minimize treatment
after use, and conserve energy and resources.  A green curriculum can be used in almost any discipline
that involves chemicals, such as:

       Chemistry;
       Biology;
       Physics;
       Art;
       Photography;  and
       Vocational courses (e.g., woodworking  class, auto/machine shop, etc.).

'Greening' a course curriculum can result in:

       Fewer chemicals consumed throughout the school year;
       Less waste being produced;
       Fewer students exposed to chemicals;
       Lower risk of spills or accidents; and
    >  Lower costs associated with chemical purchases, storage, and disposal.
     Learn More about the Green Curriculum Concept

      The concept of a green curriculum borrows from the practices of "green" (or 'sustainable') and
   "microscale" (or 'small-scale') chemistry.  The following links provide some helpful background information
   on how these concepts promote a greener curriculum:

          http://www.epa.gov/opptintr/greenchemistry/index.html
          http://www.uoreqon.edu/~hutchlab/qreenchem/whyqreen.html
      >  http://www.microscale.org/about.asp
          http://www.epa.qov/epaoswer/osw/conserve/clusters/schools/resources.htmfflabs

   For more information on developing green curricula for specific classes, see Web site links provided on
   page 4-24.
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                          Chapter 4 - Put Your SC3 Program Into Action


In addition to educational settings, the principles of green curricula can also be applied to reducing
chemicals used in the operational aspects of your school (i.e., janitorial/sanitation).  As discussed in
Chapter 2 of this Workbook, "green cleaning" involves selecting environmentally friendly products when
appropriate, using those products properly, and taking other steps to reduce risks, while maintaining an
appropriate level of cleanliness and disinfection. Visit EPA's Green Cleaning resource page
(http:/ifwww.epa.gov/epaoswer/osw/conserve/clusters/schools/resources.htm#clean) and refer to the
Additional Tools and Examples section at the end of Chapter 5 for additional resources.
    -
                               How can I start a green curriculum in my school?
As with any change your SC3 Team makes to improve chemical management in a school, a green
curriculum needs to be embraced and implemented by those who are affected. In this case, we believe
that the teachers and department chairs where green curriculum is being proposed should be engaged and
supportive of the effort. Your team will need to gauge the level of interest among people who could help
make it happen.  Identify a teacher - preferably a department head - who knows the current curriculum and
would like to take on the task of assessing:

       What changes could be made to existing curricula to use smaller quantities  and less hazardous
       chemicals; and
    > The costs (or cost savings!) of any changes to existing curricula.
       Success Stories: Going Small in Rhode Island
        After attending a teaching workshop, Mrs. Kathleen Beebe, a teacher and a Chemical
     Hygiene Officer in Rhode Island, found that 'greening' her school's chemistry classes did not
     require major changes to the curriculum itself.  Instead, her approach was to modify current
     experiments to use smaller quantities of chemicals. In addition to  saving money and requiring
     less time to prepare chemicals for instructional labs, Mrs. Beebe's school realized a number of
     other benefits to adopting a green curriculum, including:

          Students work in smaller groups and receive more hands-on experience;
          Errors are minimized since experiments are easy to run multiple times;
          Minimal set-up time allows students the opportunity to set up experiments themselves and
          increases time for discussion and interaction among students about what they are
          learning; and
          Experiments are safer for students to conduct since fewer chemicals  are involved and
          disposal concerns are minimized.
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                         Chapter 4 - Put Your SC3 Program Into Action
In Exhibit 4-15, we describe some common motivations that a school may have to adopt a green
curriculum.  Have your SC3 Team refer to these motivations when discussing green curricula with teachers
and administrators.
                Exhibit 4-15: Motivations for Supporting a Green Curriculum
    Stakeholder
        Motivation
       What to Mention to Them
 Department Heads
   and Teachers
Time savings; potential to
improve learning, risk
reduction
Smaller amounts of chemicals used means
less to store, track, and clean up;
Smaller chemical amounts may mean more
students can participate (groups of 2 instead
of 4);
More experiments can be redone if mistakes
should occur given their scaled down
approach; and
Small amounts (droppers) of chemicals used
in class may not pose as great a threat to
health and safety as large amounts (bottles).
  Administrators
 and School Board
     Members
Risk reduction; cost savings.
Storing, using, and disposing of smaller
amounts of less hazardous chemicals can
significantly reduce risks to students and
school staff;
Having to purchase and dispose of less
chemicals saves money; and
Using and disposing of less hazardous
chemicals and waste may help lower
insurance and disposal costs.
Some teachers who have adopted a green curriculum found that a good place to start is the microscale
approach of using smaller quantities of chemicals in current classroom assignments. Work with
department heads and teachers on how to make the microscale approach work for them.
Other changes to a curriculum along the lines of substituting new 'green' chemicals and
introducing new labs or assignments may require permission and/or approvals beyond
the department,  so we suggest that the appropriate administrators  be involved in the
decision-making process. You may find that your school revisits and revises curricula
each year.  Discuss opportunities for incorporating elements of a green curriculum with
the appropriate people whenever a school revisits a particular course of study.
                                                           Look to partners who
                                                           may have experience
                                                             with developing
                                                            curricula, such as
                                                            colleges and your
                                                           state's Department of
                                                               Education.
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Chapter 4 - Put Your SC3 Program Into Action
       How should we design our green curriculum?
Because they are most familiar with the content and structure of the courses and the educational
standards, teachers and department chairs are in the best position to determine how a curriculum can be
made "greener."  Members of the SC3 Team who work in a department where chemicals are being used
are ideal candidates to champion the development of a green curriculum.

There are numerous ways to green the curriculum. Depending on the chemicals and processes involved,
you may wish to start with one approach or a combination of approaches and build as your green
curriculum matures. Choose approaches that are best suited for a certain course or department, which
may include:

        Reducing the quantity of chemicals used. Adapting lesson plans to use smaller amounts of
        chemicals is a great way to reduce the amount of chemicals needed in storage, the quantity of
        waste produced in the classroom, and the level of chemical exposure students experience.  See
        the text box entitled "An Effective Solution" below for additional information on  using fewer
        chemicals in your school's curricula.

        Using safer chemicals and practices. Consider substituting your current
        chemicals with alternatives that are less hazardous and/or toxic.  Researching
        alternative experiments,  processes, and activities for courses and operational
        activities that incorporate the techniques mentioned above is also a key part
        of both a greener curriculum and practicing more responsible chemical
        management. Some helpful resources to identify less hazardous, alternative
        chemicals (and processes) to adopt are listed below:

               Massachusetts Institute of Technology's (MIT) Green Chemical
               Alternatives Purchasing Wizard
                  •  http://web.mit.edu/environment/academic/purchasing.html
               Illinois EPA and  WMRC's Greening Schools
                  •  http://www.greeningschools.org/
        Eliminating the use of specified chemicals.  Consider phasing out or stopping
        immediately the use of chemicals that pose a risk to the health and safety of the
        school. Some examples to check out are included below:

               King County, Washington's Rehab the Lab
                   •   http://www.govlink.org/hazwaste/publications/highrisktable.pdf
               American Chemical Society
                   •   http://membership.acs.Org/c/ccs/pubs/NotlnSecondarySchools.pdf
                                                         Check out Illinois EPA's
                                                         listing of alternatives for
                                                       devices containing mercury:
                                                       http://www.epa.state.il.us/p2
                                                         /green-schools/mercurv-
                                                          free-alternatives-for-
                                                             schools.pdf.
                                                              Use MSDSs to
                                                              compare less
                                                           hazardous alternative
                                                           chemicals for potential
                                                              substitution in a
                                                               curriculum.
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                          Chapter 4 - Put Your SC3 Program Into Action
Remember to keep administrators involved in the process, as appropriate. Administrators can assist with
budget questions, purchasing procedures, and getting your green curriculum approved, if necessary.  To
give you an idea of what others are doing to 'green' school curricula, we provide a variety of Web links
below organized by classroom subject.
        An Effective Solution: Use Smaller Quantities of Chemicals
            Adopting a microscale approach at first may be less expensive and easier to implement
        than redesigning a curriculum by eliminating experiments using dangerous chemicals or
        modifying experiments by substituting alternative green chemicals. However, some
        microscale practices may require new, specific equipment and thus, additional upfront costs.
        Teachers in each department should collaborate to identify where to make changes in order to
        reduce risks, save costs, and maintain or enhance the educational experience.
                Green Curriculum Resources for Different Types of Classes
       Chemistry:
            http://www.qovlink.org/hazwaste/schoolvouth/rehab/labs.htm
            http://www.state.tn.us/environment/sc3/greenchemistry.shtml
            http://academic.scranton.edu/facultv/CANNM1/drevfusmodules.html
            http://fusion.stolaf.edu/gca/
            http://greenchem.uoregon.edu/gems.html
            http://www.deg.utah.gov/Schools/pollution  prevention.htm
            http://www.epa.gov/greenchemistrv/pubs/educat.html
       Biology:
            http://www.greeningschools.org/resources/view_cat_teacher.cfm?id=2
            http://www.govlink.org/hazwaste/publications/rehabbio.pdf
            http://www.chem.harvard.edu/resources/green labs/index.php

       Art:
            http://www.greeningschools.org/resources/view_cat_teacher.cfm?id=1
            http://www.environmentaldefence.ca/toxicnation/artist/index.htm
            http://www.c2e2.org/arts_workshop_05/princeton_pdf.pdf
            http://www.uic.edu/sph/glakes/harts1/HARTS library/substitutes.tx
            http://www.watoxics.org/safer-products/choosing-safer-products-art-and-craft-supplies
        >  http://www.deg.utah.gov/Schools/appendix1 resources contacts.htm
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                         Chapter 4 - Put Your SC3 Program Into Action
ROLL OUT YOUR GREEN CURRICULUM
                          How do we incorporate green curricula into our classes?
Curriculum changes can start small and evolve over time. A teacher may decide to introduce a few
experiments or activities gradually in their class(es) as they have the time and resources. Depending on the
changes made to the curriculum, it may be necessary to modify chemical purchasing practices, and/or
purchase new equipment.

One way to introduce a curriculum is by conducting a "pilot" to refine the techniques in one class before
implementing the green curriculum in other classes. For example, a large school with multiple chemistry
classes may want to roll out the new curriculum in a single class instead of changing practices in all classes
at the same time. In a small school with only one class targeted for a green curriculum, a pilot may consist of
going forward with a subset of the planned lab changes instead of implementing the full curriculum for the
class term.  Piloting a green curriculum can help your department to:

       Adjust the quantities of chemicals being used;                                        /!/ *r
       Test new equipment and chemicals; and                                            \\*
       Get feedback from students.                                                     \\*  '
As a new curriculum is implemented, remember to keep track of changes to show the
benefits associated with 'greening' your teaching methods.  For example, try to track the
following:

       The amount of chemicals used each class term;
       The number of harmful or hazardous chemicals no longer used/purchased;
       The amount of waste generated; and
    >  The costs or cost savings for each class term.
Once you determine when
a new curriculum will begin,
  give a heads-up to the
school's purchasing agent.
  You don't want to buy
 chemicals that you'll be
     phasing out!
Using different chemicals and chemical quantities may require a shift in purchasing procedures.  By
working with your SC3 Team, teachers, administrators, and purchasers, you can align chemical purchasing
with green curriculum changes.  Remember to factor in disposal costs when considering the purchase price
of chemicals.  The cost of disposal for unneeded chemicals is likely to be greater than the savings from
buying in bulk.
           Tip: Look to Teachers Who Have Adopted a Green Curriculum
            There is a lot to be learned from those who have already tried something new.  The
          SC3 Team may be able to help by identifying teachers at other schools who are willing to
          share lesson plans and lessons learned in rolling out green curricula in their classrooms.
          You could also post an inauirv at an online discussion forum for teachers.
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                         Chapter 4 - Put Your SC3 Program Into Action
                                                  Summary
As you went through this chapter, you worked through a list of six (6) activities and projects to help you
successfully put your SC3 program into action. Here, in summary, is the list of them:

Activity #                           Description

Program Management
    1.              Begin to put your SC3 program into action;
    2.              Establish and modify existing chemical management procedures; and
    3.             Train appropriate groups on responsible chemical management.

Project #

Spec/a/ Chemical Management Projects
    1.              Perform an  inventory of all chemicals and chemical products;
    2.              Secure a chemical cleanout professional; and
    3.              Implement a green curriculum.

This fourth chapter helped you to carry out your SC3 program and undertake some vital chemical
management projects.  The next section (Chapter 5) will assist you in continuing to evaluate and sustain
your SC3 program.

Note: We plan to add more activities and projects to this Chapter in the future. If you have questions about
this chapter that you would like to discuss, refer to the SC3 Web site's "Where you Live" page for the
appropriate contact for your state that can help you. The SC3 Web site is an excellent source of additional
information, as are the resources listed at the end of this document.
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                         Chapter 4 - Put Your SC3 Program Into Action
                                       Additional Tools and Examples
This section of the chapter contains helpful links to conduct further research, a sample RFP, and exhibits
and worksheets to help you work toward getting your SC3 program in place:
 Click on the "Resources" section of EPA's Schools Chemical Cleanout Campaign Web site and then go
 to "Developing a Chemical Management Program" for additional help on:
        Regulatory Requirements:
          o http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/resources. htm#reqs
        Chemical/Disposal Inventories:
          o http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/resources.htmffinventory
Worksheet #
    4-1
    4-2
    4-4
    4-7
    4-9
    4-10
Identify Low Cost, Quick Fixes to Chemical Management Situations
Identify SC3 Priorities for the First Year
Measuring Behavioral Change
SC3 Training Topics by Targets Audience
Post-Inventory Evaluation of your Chemical Management Situation
Chemical Disposal List
Exhibits
    4-11
    4-12
    4-13
    4-14
                  Title
Sample RFP
Vendor Qualifications
Sample Price Quote
Examples of Cost Saving Techniques
                                             4-44

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                   Chapter 4 - Put Your SC3 Program Into Action
Worksheet 4-1: Identify Low Cost, Quick Fixes to Chemical Management Situations
  Issue/Area of Need
Solution
What is Needed
                                    4-45

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              Chapter 4 - Put Your SC3 Program Into Action
       Worksheet 4-2: Identify SC3 Priorities for the First Year
Activity
Resources Needed
Priority
Makes Progress Toward which
           Goals
                                4-46

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                      Chapter 4 - Put Your SC3 Program Into Action
                    Worksheet 4-4: Measuring Behavioral Change
Original Behavior
(before program)
Behavior After 3 Months of
     Implementation
Desired Behavior
Benefit/Improvement
                                        4-47

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Chapter 4 - Put Your SC3 Program Into Action
Worksheet 4-7: SC3 Training Topics by Target Audience
Training
Topics





Target Audience
Teachers





Custodians





Administrators





Purchasers





Students





                   4-48

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                          Chapter 4 - Put Your SC3 Program Into Action
      Worksheet 4-9: Post-Inventory Evaluation of your Chemical Management Situation
            Question
        Status
Action Taken
How many chemical containers are:
    1)  Unlabeled?
    2)  In poor condition?
    3)  Expired?
    4)  No longer used or essential?
    5)  Unsecured?
1)
2)
3)
4)
5)
How much of the following chemical
do I use every year?


Given the amounts above, how many
years worth of chemical do I currently
have?

                                             4-49

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Chapter 4 - Put Your SC3 Program Into Action
Worksheet 4-10: Chemical Disposal List
Chemical
Name






CAS
Number






Concentration






Exp.
Date






Amt. & Size of
Container for
Disposal






Type of
Container






Amount
(est.)






Storage Location






                   4-50

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                         Chapter 4 - Put Your SC3 Program Into Action
                                Exhibit 4-11: Sample RFP                         A|| RFRs shou|d go
                                                                                    through your legal
                                                                                    department and be
                                  ABC Regional Education Unit                        tailored to meet your
                                          123 Main St.                                specific requirements.
                                      Anywhere, PA 16412

           Hazardous Chemicals Collection and  Disposal 2005-2006

                                    BID SPECIFICATIONS

1.      Scope of Services
       The Contractor shall provide all of the following services where required for all generating sites:

              *   Identification - The Contractor must be able to identify and dispose of all known and
                  unknown hazardous waste chemicals.  If an unknown chemical is not identified, it
                  shall be considered as "hazardous" for the purposes of transportation and disposal.

              *  Packing - The Contractor must sort and package all waste chemicals according to
                  USDOT, USEPA, OSHA and PADEP regulations.

              *  Transportation - The Contractor will provide all proper transportation, labeling,
                  manifests, and  documentation according to all state, USDOT and USEPA
                  regulations.

              *  Treatment and Disposal - The Contractor shall  provide or arrange with a
                  subcontractor, as approved by the Intermediate Unit, for the proper treatment and
                  disposal of all hazardous waste chemicals.  The first options would  be to recycle,
                  refine, or recover the waste for reuse so that new raw materials are not required and
                  so that waste pollutants never reach the land, the water, or the atmosphere, and
                  resources are conserved. The second option would be to treat the waste to reduce
                  its toxicity and its potential for harming the environment. The third option is disposal
                  by landfill or incineration with proper disposal of the residual ash. No wastes should
                  be directly landfilled except those without specific available treatment technology.
                  The Contractor shall also  submit a chain of custody form for each hazardous
                  chemical, including a Certificate of Destruction, Disposal, or Recycling. The
                  Contractor shall be required to provide compliance histories for the  disposal facilities
                  as well.  The chain of custody form shall be substantially in the form attached to this
                  bid specification.

              *  Reconciliation - The Contractor must provide a  manifest sheet for each hazardous
                  waste removed from each site within 60 days of removal (PCB and  Dioxin wastes
                  may require additional time).  The Contractor shall also provide accurate invoicing
                  that is generator site specific.  Invoicing shall include:
                  o   All materials used at each site.
                  o   All applicable labor and transportation fees.
                  o   Transportation and disposal fees.

              *   Compliance with Laws - The Contractor, in the  performance of the obligations of
                  this bid specification and award, agrees to comply with all applicable federal and
                  Pennsylvania regulations, specifically including regulations of the Pennsylvania
                  Department of Transportation  and the Pennsylvania Department of Environmental
                  Protection.
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                         Chapter 4 - Put Your SC3 Program Into Action


       The Contractor will only pickup the chemicals that are listed on the enclosed school inventory
lists. No additional add-ins are to be collected and disposed of.  If chemicals are picked up and disposed
of that are not on the lists the cost for those chemicals will be the responsibility of the Contractor.

       The Contractor will schedule all of the pickups at the participating schools in the most efficient
manner possible, so that extra transportation costs are not incurred from backtracking. Pickups shall be
scheduled with the principal that  is provided on the school inventory lists.

2.     Vendor Qualifications

       Bids are designed to achieve the best price for a common commodity.  However, due to the short
and long term liability of the hazardous waste generator, vendor qualifications become a prerequisite.
Any RFP for lab pack services shall  include several qualifying  requirements.  Failure to comply with any of
the required qualifications for any time during the contract shall result in termination of the contract.

       Insurance

              A qualified vendor must submit proof of the following insurance:

                      *  Contractor's Pollution  Insurance -Contractor shall have coverage of at
                         least $2,000,000 that provides coverage for the services contemplated in the
                         bid specifications.

                      *  General Liability Policy - Contractor shall have coverage of at least
                         $1,000,000 occurance/$2,000,000 aggregate. Contractor shall have XCU.

                      *  Contractor's Liability - Contractor shall have coverage of at least
                         $2,000,000.

                      *  Automobile Policy - Contractor  shall have coverage of at least $1,000,000.
                         MCS90 enclosed.

                      *  Professional Errors and Omissions Liability - Covers errors the
                         contractors may make - applicable to unknown identifications; Contractor
                         shall have coverage of at least $1,000,000.

                      *  Workmen's Compensation Insurance - Covers all workers; Contractor
                         must have coverage of at least $500,000 (federal minimum).

                      *  Transporter Pollution Liability - Covers cost of spill cleanup during all
                         modes of transportation; Contractor must have coverage of at least
                         $5,000,000 (DOT requirement).

                      *  Pollution Legal Liability Insurance - Covers immediate environmental
                         damage to the disposal site; Disposal Facility must have coverage of at least
                         $2,000,000.

                      *  Environmental Impairment Liability - Covers long term environmental
                         damage to the disposal site; Disposal Facility must have coverage of at least
                         $5,000,000.

                      *  Indemnification - Contactor shall provide indemnification to the
                         Intermediate Unit and assume full responsibility and liability for all chemicals,
                         including but not limited to spills, transportation, treatment and disposal,
                         whether handled by the Contractor or its subcontractor. The ABC Regional
                         Education Unit shall be named as additional insured for all policies.
                                              4-52

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                  Chapter 4 - Put Your SC3 Program Into Action


Training

       A qualified vendor shall have the following training:

               *  Chemical Technicians - All on site employees
                  must have 40 Hour Health and Safety Training
                  complying with 29 CFR 1910.120(e)(3)(i). This
                  is an OSHA standard for lab pack work.              Your organization may already
                                                                  have an RFP template you can use
               *  Truck Drivers - All drivers must have the          to get started! This will ensure you
                  appropriate training required in 29 CFR 177 and         jnc|ude references to all
                  383.  These are DOT standards for Hazardous      appropriate legal and/or regulatory
                  Material Transporters.                                      clauses.

Compliance History

       All bidding vendors  must submit a detailed history of all citations for the last 5 years,
including:

               *  USDOT Compliance History - A track record of highway safety;

               *  USEPA Compliance History - A record of environmental safety;

               *  OSHA Compliance History - A record of employee safety; and

               *  TSDF Compliance History - A record of inspections by state agencies and
                  corrective action taken.

       Reference to citations for the purposes of this provision shall include information
       concerning all notices of violation, civil penalties and assessments, criminal actions, and
       similar detailed history.

Permits

       All bids must include all applicable permits for transportation, storage, and treatment for
all disposal facilities including the final landfills.


Subcontractors

       All subcontractors used must be listed and fulfill all  vendor qualification requirements.
                                       4-53

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                        Chapter 4 - Put Your SC3 Program Into Action
          Hazardous Chemicals Collection and Disposal 2005-2006
                                     Price Breakout
Colby Lake

Colby Valley

Copeland Central

Carlisle

East Middletown (2)

Ellston County Vo-tech School

Ft. Langley

General Marston

Ginley

Hay Creek

Mapleville

McDouglas

Merriweather

North Cumberland

Northeast Gains Academy (2)

Newton

Sage City

Upland Marshall

Van Buren


TOTAL PRICE:
                                        i.
                                        i.
                                        i.
                                        i.
                                        i.
See Exhibit 4-3 for more details on
  cleanout costs you may want
qualified professionals to estimate.
i.
i.
i.
i.
i.
i.
i.
i.
i.
i.
i.
                                        i.

                                        L
                                          4-54

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                         Chapter 4 - Put Your SC3 Program Into Action
                             CHAIN OF CUSTODY/MANIFEST FOR
                              HAZARDOUS CHEMICAL DISPOSAL
Generator School District Name and Building Address:
Description of the Hazardous Chemicals (Use additional pages as necessary):
Name of Chemical



No. of
Containers



Type of
Container



Total
Quantity



Description



Generator School District Certification:  I hereby declare that the contents of this consignment
are fully and accurately described on the above by proper shipping name and are classified, packed,
marked, and labeled, and are in  all respects in proper conditions for transport by highway, rail or
water according to applicable international and national government regulations.	
Printed/Typed Name
Signature
Date
Transporter Acknowledgment of Receipt:  I hereby declare that all of the materials identified
hereinabove, except such discrepancies as noted hereinafter, have been received by me for proper
disposal in accordance with applicable international and national government regulations. I  certify to the
generator that the contents of this consignment will be transported to a permitted or licensed facility for
disposal, destruction, or recycling as permitted by applicable law and regulations.	
Printed/Typed Name
Signature
Date
Discrepancy Indications Space (if none, write "None"):
Subcontracted Transporter Acknowledgment of Receipt: I hereby declare that all of the materials
identified hereinabove, except such discrepancies as noted hereinafter, have been received by me, from
the contracting party identified hereinafter, for proper disposal in accordance with applicable international
and national government regulations. I certify to the generator and transporter that the contents of this
consignment will be transported to a permitted or licensed facility for disposal, destruction, or recycling as
permitted by applicable law and regulations. (Use additional pages, if necessary).	
Contracting Party Name and Address (Please identify the individual agent or employee of the Contracting
Party):
Printed/Typed Name
Signature
Date
Discrepancy Indications Space (if none, write "None"):
Disposal/Recycling Facility Acknowledgment of Receipt: I hereby declare that all of the materials
identified hereinabove, except such discrepancies as noted hereinafter, have been received by me for
proper disposal and/or recycling in accordance with applicable international and national government
regulations.  I certify to the generator that the contents of this consignment will be disposed, destroyed,
recycled as permitted by applicable law and regulations, in accordance with this facility's permit or
license.
                                                           or
Printed/Typed Name
Signature
Date
Discrepancy Indications Space (if none, write "None"):
                                             4-55

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Chapter 4 - Put Your SC3 Program Into Action
      COMPLIANCE REPORT FORM
Compliance Background. (Note: Copies of specific documents, if applicable, must be made available to the Intermediate
Unit upon its request.) List all documented conduct of violations or enforcement actions identified by the USDOT, USEPA,
OSHA, PADOT, PADEP, pursuant to applicable law and regulations, terms and conditions of an operating permit or plan
approval or order by Contractor or any related party, using the following format grouped by source and location in reverse
chronological order. Attach additional sheets as necessary. See the definition of "documented conduct" for further
clarification.
Date








Location








Plan
Approval/
Operating
Permit#








Nature of
Documented
Conduct








Type of
Enforcement
Action








Status: Litigation
Existing/Continuing or
Corrected/Date








Dollar
Amount
Penalty
$
$
$
$
$
$
$
$
List all incidents of deviations of the USDOT, USEPA, OSHA, PADOT, PADEP regulations, terms and conditions of an
operating permit or plan approval or order by Contractor or any related party, using the following format grouped by
source and location in reverse chronological order. This list must include items both currently known and unknown to the
Department. Attach additional sheets as necessary. See the definition of "deviations" for further clarification.
Date









Location









Plan Approval/
Operating Permit#









Nature of Deviation









Incident Status:
Litigation
Existing/Continuing Or
Corrected/Date









CONTINUING OBLIGATION. Contractor is under a continuing obligation to update this form using the Compliance
Review Form if any additional deviations occur between the date of submission and the Intermediate Unit's action on the
Contractor's bid.
                 4-56

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                         Chapter 4 - Put Your SC3 Program Into Action
Definitions:
"Related Parties" shall be the applicant and any general partner, parent, or subsidiary of the applicant or
permittee for a plan approval or operating  permit including a general plan approval and general operating
permit.

"Documented conduct' shall mean any activity that occurred at a source owned or operated in
Pennsylvania by the Contractor, permittee or a related party within 5 years prior to the date of submission
of the compliance review form identified as a violation of the environmental laws, the regulations, a plan
approval, permit or order issued by USDOT, USEPA, OSHA, PADOT, or PADEP. The term includes, but
is not limited to, activities which are described in or the subject of the following: All Notices of Violation
issued by the PADEP, USEPA, or OSHA or any other authorized enforcement or regulatory agency in
Pennsylvania against the Contractor, permittee  or related parties;  All administrative orders, civil penalties,
permit suspensions or revocations, and civil penalty actions issued by the PADEP, USEPA, or OSHA or
any other authorized enforcement or regulatory  agency in Pennsylvania against the Contractor, permittee
or related parties; All consent decrees, consent  orders and  adjudications, consent order and agreements,
consent assessments, letter agreements, stipulations or other settlements between the PADEP, USEPA,
OSHA, or any other authorized enforcement or regulatory agency in Pennsylvania against Contractor,
permittee or related parties; All Pennsylvania court proceedings, including proceedings before the
Environmental Hearing Board, involving Contractor or related parties; All summary, misdemeanor, or
felony convictions, or pleas of guilty or pleas of no contest that have been entered in Pennsylvania
against Contractor or related parties pursuant to any environmental laws or regulations; and Any
suspension, revocation or denial of reissuance of any operating permit issued to the Contractor or related
parties pursuant to the environmental laws or regulations.

"Deviations"  shall mean all activities that occurred at a source owned or operated in Pennsylvania by the
Contractor, permittee or related party within the  5 years prior to the date  of submission of the compliance
review form that has not been formally documented by the PADEP, USEPA, OSHA or another authorized
enforcement or regulatory agency in Pennsylvania which otherwise did not conform to the application law
or regulations promulgated thereunder, plan approvals, permits or orders of the PADEP, USEPA, or
OSHA. The identification of a deviation on a compliance review form does not constitute a waiver of a
defense to liability under the law for the activity disclosed. The term includes, but is not limited to, the
following: All unauthorized, accidental releases or emergency releases of hazardous chemicals into the
environment; All malfunctions of equipment, the maintenance of which, is necessary to prevent such
releases; All other deviations of the environmental laws, regulations, terms or conditions of operating
permits or plan approvals and orders of any state or federal enforcement agency by the Contractor or any
related party,  whether or not these deviations have been documented.


I,	, being duly  sworn  according to the law depose and
state, under penalty of law as provided in 18 Pa. C.S. §4944, that I am the representative of the
Contractor, identified above, authorized to make this affidavit. I further state that the information provided
with this form, after reasonable inquiry, is true and complete to the best of my belief and that there are
reasonable procedures in place to insure that documented conduct and deviations are identified and
made part of the compliance review information contained in the Compliance Review Form.
                                             4-57

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                          Chapter 4 - Put Your SC3 Program Into Action
                                Exhibit 4-12: Vendor Qualifications
                                             Checklist
Vendor Name:	
Ensure that your vendor meets all applicable Federal, State and Local requirements before selecting.
The Vendor:
    1)  Can pack the chemicals?
    2)  Can transport the chemicals?
    3)  Can treat and dispose of the chemicals?
    4)  Can reconcile the chemicals?
    5)  Carries all of the proper insurance?
    6)  Has chemical technicians that have proper training and certifications?
    7)  Has truck drivers that have proper training and certifications?
    8)  Can provide acceptable USDOT compliance history?
    9)  Can provide acceptable USEPA compliance history?
    10) Can provide acceptable OSHA compliance history?
    11) Can provide acceptable TSDF compliance history?
    12) Has all the appropriate permits for transportation?
    13) Has all the appropriate permits for storage?
    14) Has all the appropriate permits for treatment and disposal?
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                         Chapter 4 - Put Your SC3 Program Into Action
                              Exhibit 4-13: Sample Price Quote
Re: Disposal of My High School's Waste

Our company is pleased to submit a detailed quotation for the management, transportation and disposal of
the hazardous materials located at My High School.

Given our understanding of the scope of work per the chemical inventory that was provided us, we present
the following Price Estimation to complete this project.

This estimate specifies the following services to be carried out and the requirements to be met:

       Materials will be classified and marked with a label giving the chemical name or composition, or
       the MSDS must be available. The cost for marking each container is $XX.OO

       Materials will be segregated by compatibility,  hazard  class and disposal requirements.  The cost
       for segregation of materials is $XX.OO.

       Lab packing materials into drums and/or DOT approved over packing containers.  The cost of lab
       packing each drum is $XX.OO.  Lab packs will be labeled to meet state and federal regulations.

       Completion  of appropriate  documentation, manifests, and shipping documents.  The cost for
       preparing these documents is $XX.OO.

       Lab packs will be  transported to our facility for storage/transfer/processing for final disposal. The
       cost for these services is $XX.OO.

       Materials that are not included in this price quote include:  radioactive  materials, shock sensitive
       compounds,  biological wastes,  explosives,  and  pressurized cylinders  and/or gases  unless
       otherwise stated in the attached Price Estimation.

       This proposal is valid for 45 days from the issue date.
                                              4-59

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                           Chapter 4 - Put Your SC3 Program Into Action
Exhibit 4-14: Examples of Cost Saving Techniques
Technique
Leveraging a household
hazardous waste (HHW)
collection event for chemical
disposal.

Use a knowledgeable partner to
help identify substance(s) that
can be safely disposed of without
a hazardous waste contractor.

Work with a partner organization
to take advantage of an existing
disposal contract.

Incorporate performance-based
contracting in your RFP.

Negotiate disposal rates by
combining multiple cleanouts.

Identify agency assistance for
removal of radioactive wastes.

Research your chemical
management regulations to
identify potential ways to lower
costs.
Type of Cost
Savings
Transportation and
labor.

Packing, labor,
transportation, and
disposal.

Disposal (lower rates)

Disposal, chemical
purchasing, future
chemical
management.

Lower disposal rates
and reduce cost for
lab packing, labor,
and transportation.

No-cost removal of
radioactive
chemicals.

Reduced packing and
transportation costs.
Real World Example
The Tennessee Department of Environment and
Conservation used an existing contract to do HHW
collection and facilitate simultaneous cleanouts of school
labs.

The Northwest Tri-County Intermediate Unit in Pennsylvania
leveraged the State environmental agency to review
inventories and denote items that could be safely disposed.

In Iowa, in the early stages of their chemical management
efforts, the Metropolitan Waste Authority partnered with EPA
Region 7 to use existing chemical management services.

A pilot program in Lansing, Michigan incorporated
performance-based contracting clauses to encourage
cleanout professionals to find ways to minimize costs, while
providing other chemical and resource lifecycle services.

Qualified school personnel in the Fort Worth, Texas'
Independent School District collected smaller amounts of
waste from all district schools prior to one large consolidated
disposal to save on transportation costs and negotiate a
lower disposal rate per drum of hazardous waste.

The Illinois Emergency Management Agency has launched
a program to help schools safely dispose of radioactive
materials. IEMA officials collect the materials and send
them to a radioactive waste disposal facility. The Illinois
program is one of several around the country; other states
include Connecticut, Colorado and Vermont.7

Rochester City School District, New York environmental
personnel talked to regulators about the amounts and types
of chemicals that could be legally and safely transported by
the school district to a proper disposal facility.
7 Learn more about the Illinois Emergency Management Agency's Orphan Source Recovery Program-High
  School Initiative: http://www.state.il.us/iema/publications/pdf/Radiation In  Schools.pdf
                                               4-60

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                Chapter 5 - Sustain Your SC3 Program
                                   What can I do to sustain my program?
Congratulations! Your SC3 program is off the ground and you are doing good things. Now the
challenge is to sustain that success. An important part of maintaining a safe learning environment is to
continue to follow responsible chemical management policies and procedures, and periodically
evaluate program progress and make adjustments, as necessary. This chapter focuses on ways to
keep your program current and ensure that those involved in chemical management continue to do the
right things. The activities to  sustain your SC3 program are:

    Activity #                            Description

       1.              Evaluate and measure your program's progress, methods, and capabilities;
       2.              Keep chemical management policies and procedures up-to-date;
       3.              Conduct periodic training;
       4.              Communicate progress and success to keep enthusiasm and awareness  high;
       5.              Maintain relationships with partners; and
       6.              Estimate staffing and funding requirements and continue to look for new
                      funding sources for ongoing SC3 activities.
       Key to Sustained Success: Maintaining Chemical Inventories

       No school wants to find itself in a situation requiring a significant chemical cleanout.  A key to
    preventing a potentially dangerous chemical situation in your school is to keep tabs on the chemicals
    your school buys, stores, uses, and disposes. One way to do this is to keep your school's chemical
    inventory system up-to-date with information regarding:

              Location;

              Quantity;

              Condition; and

              Age of every chemical at your school.

    You should periodically check that all components of your inventory are up-to-date and that the people
    managing it are functioning efficiently and effectively.  In addition to preventing a potential costly
    cleanout, a comprehensive chemical inventory can help your school make more cost-effective and
    healthy purchasing decisions, as well as indicate if school policies are being followed.  Finally, you
    should check to see that the school is continuing to evaluate the need for the chemicals and alternate
    ways of doing business.
                                             5-1

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                             Chapter 5 - Sustain Your SC3 Program


ACTIVITY 1 - EVALUATE AND MEASURE YOUR PROGRAM'S PROGRESS, METHODS, AND CAPABILITIES

After initially putting your program into place, you should be prepared to evaluate the goals, strategies,
and activities you originally developed for your program to determine if they need to be revised or
expanded.  You should evaluate all aspects of your SC3 program. This includes, but is not limited to:

       Evaluating how well you are doing according to your performance measures;
       Determining how effective your approach to designing a program has been;
       Analyzing how well your strategies have worked in undertaking each activity;
       Identifying any success factors; and
       Recognizing the obstacles you have faced.

You can use the worksheets you created in Chapter 2 (Worksheet 2-1: SC3 Activities and Performance
Measures to Reach Program Goals and Worksheet 2-2: SC3 Progress Report) and record progress
made.  If goals are on track or ahead of schedule, communicate this message of success to program
participants to sustain the momentum of your program.  Where you find that your actual results are
behind your desired results, you should address the issues in more detail. To do this, Worksheet 2-4:
Identifying Potential Obstacles and Solutions can be used to see if you and your team prescribed
actions to prevent or remove obstacles. You should work with your team to evaluate how to deal with
any existing obstacles and get progress back on track.  It may be necessary to create a new plan to
identify potential obstacles and solutions.
             Tip: Use Software to Track SC3 Activities

                 Remember that EPA provides a valuable software tool that gives school districts
          the ability to evaluate and manage different aspects of their school safety and health issues,
          including chemical management. The Healthy School Environments Assessment Tool
          (HealthySEAT) is downloadable for use by school districts to perform analyses at the school
          and district levels and easily manage school specific conditions and progress. Visit the
          Healthy SEAT Web site at http://www.epa.gov/schools1/healthvseat/index.html
In addition to evaluating the progress of your program, we recommend that you periodically review the
goals you and your core team created.  Evaluating the capabilities and objectives of your program is
something that you should do on an annual basis, at a minimum. For existing program goals, some
helpful resources to review and use are the following worksheets from Chapter 2:

       Worksheet 2-1: SC3 Activities and Performance Measures to Reach Program Goals;
       Worksheet 2-2: SC3 Progress Report; and
       Worksheet 2-4: Identifying Potential Obstacles and Solutions.

As your team evaluates school conditions and as the SC3 program matures, your team may want to
set new goals.  For example, some programs initially focus on only one or two aspects of the chemical
management lifecycle, such as Purchasing and Storage, but once they address these topics, they are
ready to move on to new challenges. Revisit your original evaluation of the school's chemical
management situation (see Chapter 1 Worksheet 1-1:  Evaluating Your School's Chemical
Management Situation, Policies, and Procedures) and determine how and where to expand your
program's capabilities to address issues identified at the time.  If you are adding new goals, you can
                                               5-2

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                                    Chapter 5 - Sustain Your SC3 Program


       use Worksheets 2-3: SC3 Staffing Plan and 2-5: SC3 Labor Cost Estimate to prepare budget requests,
       and assign new tasks to team members.

       Also remember that:

               New performance measures may be necessary to better track progress toward your goals; and
               Many aspects of your program will be subject to changes of one type or another.

       Your experiences should give you greater knowledge of and familiarity with the proper handling, use,
       and disposal of chemicals to make the school safer.  This, in turn, should help you to shape and refine
       program goals to create a program that can sustain success over the long term.
       ACTIVITY 2 - KEEP CHEMICAL MANAGEMENT POLICIES AND PROCEDURES UP-TO-DATE

       To determine that chemicals in your school or district are being handled in the best possible
       way, we suggest that you and your team regularly evaluate your chemical
       management policies and procedures. Staying current with best practices and
       methods should help avoid potential risks and cleanouts in the future. In addition, we
       believe that someone on the team should keep current on state and federal
       regulations regarding the purchase, use, storage and disposal of the chemicals in your
       inventory.
                                                                      From your core SC3 Team,
                                                                      assign one or two people to
                                                                      take the lead on reviewing
                                                                      and updating policies and
                                                                      procedures for responsible
                                                                          school chemical
                                                                           management.
                      How can I keep my chemical management policies and procedures up-to-date?
Whenever you update SC3
 policies and procedures
 ask:  "who needs to know
  about these updates?"
The long-term success of your SC3 program depends on being able to keep responsible
 chemical management policies and procedures up-to-date. Chapter 1  of this Workbook
  provides a worksheet for evaluating school conditions and practices that may need to be
   addressed by an SC3 program (Worksheet 1-1: Evaluating Your School's Chemical
      Management Situation, Policies, and Procedures). You may want to perform this
      self-evaluation activity at least once a year to improve your program and catch
      problems before they pose health and safety risks - make these SC3 self-
      evaluations a part of the way you do business.
  Then let them know!
                        Advances in school chemical management are likely to occur, so it's a good idea to
       keep up-to-date on new approaches that you may want to incorporate in your school's SC3 policies
       and procedures.  Visit the SC3 Web site periodically for new tools and information, and consult your
       state's environmental agency to check if there are new or revised regulations. Also, use team
       members, partners, and other available resources with knowledge of chemical requirements to ensure
       that chemical procedures at your school or district are aligned with all appropriate regulations.
                                                     5-3

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                                    Chapter 5 - Sustain Your SC3 Program
      ACTIVITY 3 - CONDUCT PERIODIC TRAINING

      Chapter 4 provided guidance on how to develop a chemical management curriculum and train those
      involved in the use and disposal of chemicals.  To sustain the progress your program has made in
      changing attitudes and behaviors regarding responsible chemical management, we believe it is
      important to periodically train new school personnel and students, and conduct refresher training for
      those who have already been trained. Your team will need to periodically update the curriculum
      developed as part of Program Management Activity #3 in Chapter 4 so that it is current and reflective of
      the most current best practices.  The SC3 Team should conduct periodic refresher training that focuses
      on the most important principles and practices. Just like the initial training, you can conduct refresher
      training in formal or informal settings and you can tailor the training to meet the needs of your target
      audience(s).
                                  What should our training program look like overtime?
      In launching your school's SC3 program, your team likely developed instructional materials and
      conducted initial training for those involved in chemical management. You should periodically update
      the training program, as well as train new teachers, facilities personnel, and students to reflect new
      approaches and regulatory requirements. Even if they have already received training elsewhere, it will
      probably be a good idea for them to learn about the specific requirements in your district.
For those who have already been trained, we suggest that you conduct "refresher" training
 on the most critical topics. Refresher training is most appropriate for teachers and
 facilities personnel who already went through the initial training when your school
   launched its SC3 program. You should provide practical information that staff can
       easily incorporate into their daily activities. A good way to develop 'refresher'
       training material is to take a look at the initial training and focus on emphasizing
       the most important topics. You may also want to address areas where you have
       seen difficulties arise since the last training.  Take into consideration any lessons
       learned and feedback you  may have received after holding the initial training
       sessions. Most importantly, you should keep training information consistent and
       up-to-date to ensure that your target audiences  are practicing responsible
       chemical management.
  Informal training can be
  very effective. Look for
opportunities to "piggyback"
onto existing training forums
 or convey reminders when
   staff and teachers are
 actually using, storing and
  disposing of chemicals.
                                                     5-4

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                             Chapter 5 - Sustain Your SC3 Program
      Key to Sustained Success: Ongoing Training Efforts
         The Science Safety Project Committee of the Maryland Science Supervisors Association has
  developed a Science Safety Manual. The committee manual guides schools in making instructional
  decisions that would support improved performance for all students. The Manual communicates clearly
  the best safety practices in the science classroom and laboratory and provides guidelines for School
  Science safety, including guidelines for managing, handling, and disposing of hazardous chemicals. Read
  more at:
                    http://www.mdk12.org/instruction/curriculum/science/safetv

         The Kentucky Department of Education, in  cooperation with the Center for School Safety, the
  State Fire Marshall, the Department of Health, Kentucky Occupational Safety and Health Program, the
  Kentucky Science Teachers Association, and a private laboratory safety consultant,  created a CDROM-
  based tool. The CD promotes best practices, current information, and readily accessible resources and
  recommendations related to safety issues in the science classroom and laboratory. The CD also includes
  both professional and regulatory standards specifically for Kentucky teachers and students and provides
  practical resources for creating and maintaining a science safety plan, including a chemical management
  component.
As discussed in Chapter 4, students can have a role in responsible school chemical management too.
Educating students generally centers on three areas: safety, chemical lifecycle management, and
pollution prevention. Student chemical safety training primarily involves setting ground rules at the
beginning of a course regarding the proper handling of chemicals.  Common topics include:

           Raising awareness of hygiene, handling, and emergency procedures;
           Learning to properly use Personal Protective Equipment (PPE);
           Recognizing common safety symbols;
           Understanding materials safety data sheets; and
           Responding to a chemical accident.

It is also important to involve students in the concepts of overall chemical life cycle management and
pollution prevention. Some examples of topics to discuss with students are:

           The benefits of purchasing and using less hazardous and/or toxic chemicals;
           Safe storage practices;
           Designing experiments in a way that use smaller quantities of chemicals; and
           Proper disposal procedures.

On those days in which chemicals are in use, teachers can give helpful reminders when describing the
daily lesson. This kind of informal training is cost-effective and easily incorporated into school
operations. Your team should  refer back to the specific training content identified for target audiences
(See Exhibit 4-7) to get an idea of what topics to include in refresher courses.
                                               5-5

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                             Chapter 5 - Sustain Your SC3 Program
ACTIVITY 4 - COMMUNICATE PROGRESS AND SUCCESS TO KEEP ENTHUSIASM AND AWARENESS HIGH

Communicating SC3 accomplishments is a great way to bolster commitment to responsible chemical
management.  If you have a good story to tell, you should convey it in public forums, school
staff/management meetings, and widely circulated newsletters.
                   Is communicating program progress important to sustaining success?

Absolutely. Initial SC3 communications efforts aim at getting people involved.  Once a
school's SC3 program is up and running, the challenge is keeping people involved and
maintaining good habits regarding responsible school chemical management.  A
successful program is important to sustaining management support. It might be
beneficial to retain detailed information regarding your program, in case a change
in management or budgeting occurs.  Some examples of information to keep as
records might be:

           Yearly progress reports;
           Performance measures;
           Expenditures and other budgetary data; and
           Inventories of equipment and supplies.
 Consider maintaining a "days
without a chemical problem" sign
 in the teachers' lounge.  Most
  industrial plants prominently
 display similar signs as a daily
 reminder and to instill pride in
 making the work environment
          safe.
Having documentation of how your program functions and what it has accomplished is good for
instances where you should "sell" the effectiveness and benefits of your program.  Maintaining contact
with local media outlets and community members should also give you an opportunity to announce any
changes or successes in your school or district.

In addition, we recommend that you continue to cultivate good relationships with current
partners to keep them committed to providing expertise and assistance. Furthermore,  if you
find that your program's needs aren't being met or you've expanded your program's
capabilities and developed new needs, it may be necessary to find and involve new
partners to provide support (e.g., a local university may be helpful to your school's efforts
to develop a new chemistry curriculum). You should refer back  to Chapter 2 for
guidance on approaching potential partners and acquiring their support.
        An effective way to
          sustain senior
      management backing is
      to give them a chance to
       speak with the media
      during publicity events.
                                              5-6

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                             Chapter 5 - Sustain Your SC3 Program


ACTIVITY 5 - MAINTAIN RELATIONSHIPS WITH PARTNERS

Open communication and frequent recognition are key for encouraging partners to continue assisting
your school's SC3 program.  Keeping partners aware of, and new partners involved in, your school's
plans will help them understand the next steps in improving your program and how they can provide
expertise and resources to ensure progress is made in keeping your program up-to-date.
                    How do I maintain an effective ongoing relationship with my partner?
As we've mentioned before, it is possible that your school will not have all the expertise or the time to
undertake the different aspects of chemical management.  Therefore, it is likely that partnerships will be
important to sustaining your SC3 program  year after year.

In Chapter 2 Activity 7: Enter into Partnerships (page 2-15), we briefly outline some of the factors your
SC3 Team should consider to keep your partner relationships healthy.  Consider the following
recommendations to help maintain an effective working relationship with your partner(s):

           Keep open lines of communication.  Staying in contact with your partner is
           very important as the program progresses. Agree on how often you should
           meet or have phone calls. It is especially important to communicate with
           partners well in advance concerning upcoming events with which they should be
           involved.  Be sure to keep partners updated about any changes that may affect
           your school's SC3 program, including priorities, budgets, or roadblocks, as a
           partner may be able to fill a need when it arises.
           Re-evaluate the partnership and make adjustments.  Even if you have not
           entered into an official partnership agreement, the SC3 Team should plan on
           periodically meeting with partners to revisit commitments and accomplishments,
           as well as to share upcoming  plans, and to gauge a partner's continued interest
           in helping the school.
           Work with partners to identify additional help. Current partners can be very
           helpful  in  reaching out to other potential partners. Talk with your partners about
           contacts they may have with other organizations that can help your school.
           Discuss national partnership opportunities. You may find that a partner
           wants to make a greater commitment to helping SC3 programs.  Be sure to
           inform them of the opportunity to become a national partner with EPA.
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                              Chapter 5 - Sustain Your SC3 Program


Remember, you can look to partners and vendors to provide the following kinds of assistance:

        Performing a periodic evaluation of your school's chemical inventory and storage areas (see
        Chapter 1);
        Performing, if necessary, chemical cleanout and disposal services (see Chapter 4);
        Providing information about advances in microscale or green curricula (see Chapter 4);
        Providing information about new developments in responsible chemical management;  and
        Conducting training and refresher workshops.
      Key to Sustained Success: Ongoing Partner Assistance
    The Jefferson County Local Emergency Planning Committee (JCLEPC) provided assistance to Colorado
public schools by developing policy guidelines for procuring environmentally preferable chemicals to help curb
the use of toxic chemicals in chemistry lab exercises. JCLEPC will also develop training and policy guidelines
that can be adopted statewide.

    The Illinois Environmental Protection Agency's (IEPA) Office of Pollution Prevention delivers a workshop
modeled for science teachers.  By sending a teacher to the workshop, the participating school can receive a
free pickup of hazardous school waste through the IEPA. The workshops themselves offer information on
several issues, including:

        Methods of teaching with non-toxic and less hazardous materials in science classes;
        Safe storage practices for hazardous materials; and
        Procedures for disposing of hazardous materials.
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                            Chapter 5 - Sustain Your SC3 Program


ACTIVITY 6 -  ESTIMATE STAFFING AND FUNDING REQUIREMENTS AND CONTINUE TO LOOK FOR NEW
             FUNDING SOURCES FOR ONGOING SC3 ACTIVITIES

To ensure that the different aspects of your program have the support they need, we suggest that you
and your team determine the funding and labor costs necessary to maintain your SC3 program on a
yearly basis.
                       What kind of funding do I need to maintain my SC3 program?
By this time, you have put a well thought out program in place that addresses responsible chemical
management. Through this process, you have planned and budgeted SC3 program activities to most
effectively and efficiently achieve your goals.  By doing this, you have taken proactive steps to minimize
the cost of maintaining your program. The purpose of an SC3 program is to make responsible
chemical management a part of day-to-day operations in your school. Ideally, there should be a level
cost to operate and maintain your SC3 program. Each year, the SC3 program manager should
estimate the hours and budget required to do the following:

       Re-evaluate and update chemical management policies and procedures;
       Further develop and evaluate the effectiveness of training curricula;
       Update and evaluate the functioning of the inventory system; and
       Properly dispose chemicals that are no longer needed.

Your school's budget may not cover all the costs of maintaining responsible chemical management.
We have provided examples of methods for potentially procuring funds to sustain your SC3 program:

       The Local Hazardous Waste Program in King County's Rehab the Lab program in King
       County, Washington, offered assistance, free of charge, to King County schools to manage
       their hazardous chemicals.  The cost was $560,000 over a four-year period and was primarily
       funded by surplus sewer and garbage collection fees. In addition, the state provided matching
       grants to  cover the cost of the initial site audit, collection and disposal costs, and teacher
       training.

       Kansas Department of Health and Environment (KDHE) launched Kansas's Lab Chemical
       Sweep to offer a free, one-time collection of obsolete or unwanted potentially hazardous
       chemicals. Funding for the program originated from the $1.00 per ton solid waste tipping fee
       paid to the state for all waste disposed of at landfills.

Remember to keep in mind the costs of any new or expanded SC3 program activities. If you only
developed a few components of your program at a time, costs for adding components and improving
your program should be considered.
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                             Chapter 5 - Sustain Your SC3 Program
                                                   Summary
The activities to sustain your functioning SC3 program are:

   Activity #                            Description

       1.        Evaluate and measure your program's progress, methods, and capabilities;
       2.        Keep chemical management policies and procedures up-to-date;
       3.        Conduct periodic training;
       4.        Communicate progress and success to keep enthusiasm and awareness high;
       5.        Maintain relationships with partners; and
       6.        Estimate staffing and funding requirements and continue to look for new funding sources
                for ongoing SC3 activities.
                                       VISIT THE SCHOOLS
                                  CHEMICAL CLEANOUT CAMPAIGN
                                           WEB SITE
1PAIGN
                                      www.epa.gov/sc3
                                             5-10

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                              Chapter 5 - Sustain Your SC3 Program
                                       Additional Tools and Examples
Here are some links from the SC3 Resources Web site, where you can find other valuable information
and tools: http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/resources.htm
      General School Resources
            SC3 Tool Kit
             Evaluation of Results from EPA's Schools Chemical Cleanout Campaign
             Protecting Health and the Environment at K-12 Schools, Including Art Programs
             o   Environmental Compliance and Best Management Practices: Guidance Manual for K-12
                  Schools
             o  Environmental Health & Safety in the Arts: A Guide for K-12 Schools, Colleges and Artisans
             Healthy School Environment Resources
             Healthy School Environments Assessment Tool  (HealthySEAT)
             National Institute of Health (NIH) Mad as a Hatter Mercury Abatement Campaign
             Children's Health Protection
         >   Healthy Schools for Healthy Learning
             Health and Safety Guide for K-12 Schools in Washington
             Tribal Schools Compliance Assistance Notebook
             EPA's Schools and Mercury Web site
             EPA Schools Web Portal

     Developing a Chemical Management Program
       General Chemical Management Program Resources:
             CPSC and NIOSH School Chemistry Laboratory Safety Guide
             Chemical Management Resource Guide for School Administrators
             Idaho's Department of Environmental Quality's Waste Management Educational Tools: Chemical
              Roundup
             Pollution Prevention Measures for Safer School Laboratories
             The Los Angeles Unified School District (LAUSD) Office of Environmental Health and Safety (OEMS)
         >   Lansing Michigan School District Case Study
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                        Chapter 5 - Sustain Your SC3 Program
        Rehab the Lab
        Colorado Department of Public Health and Environment: Guidance on Chemical Management in
          Schools
 Chemical Inventory:
        Montana DEQ School Labs: Evaluating School Lab Chemicals
        The State of Tennessee's SC3 Inventory Procedures Web site
 Material Safety Data Sheets (MSDS):
        The NIOSH Pocket Guide to Chemical Hazards
        Where to Find MSDS on the Internet
 Regulatory Requirements:
        A List of State Environmental Departments
        Occupational Exposure to Hazardous Chemicals in Laboratories
        EPA's Hazardous Waste Generators
        Lab Waste at Educational Institutions
        Environmental Management Guide for Small Laboratories

Chemical Use and Management
 Green Cleaning:
        EPA's Environmentally Preferable Purchasing (EPP)
        Green Janitorial Products and Services
        Green Cleaning Pollution Prevention Calculator
        Guide to Green Cleaning: Healthier Cleaning & Maintenance Practices and Products for Schools
        New American Dream Clean Schools
        Household Products Database
        Western Regional Pollution Prevention Network: Janitorial Products Pollution Prevention Project
        INFORM's Cleaning For Health: Products and Practices for a Safer Indoor Environment
        Association for Professionals in Infection Control and Epidemiology (APIC) Guideline for
          Selection and Use of Disinfectants
 Integrated Pest Management:
     >  Integrated Pest Management in Schools
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                         Chapter 5 - Sustain Your SC3 Program
        National School IPM Information Source
Greening Labs and Lesson Plans:
      Green Chemical Alternatives Purchasing Wizard
      Green Chemistry Experiments for High Schools
      Green Your Lesson Plans
      Least Toxic Chemistry Labs: King County, Washington
      Green Chemistry Institute: American Chemistry Society
      National Microscale Chemistry Center
      Science Safety Information Guides
School Nurses:
      Children's Health: Safe Workplaces and Healthy Working Places, Environmentally Healthy Schools
      EnviRN
      The National Association of School Nurses Position Statement on Environmental Impact Concerns in
        the School Setting

Communication
  Brochures:
      Chemicals in Schools: Partner for Healthy School Environments
      Chemicals in Schools: Solutions for Healthy School Environments
  Public Service Announcements:
      Is Chemical Safety Part of the Eguation?
      You Work Hard to Keep Your Students Safe from Bullies and Drugs. But What About Chemicals?
  Presentations:
      Chemical Safe Schools in Rhode Island (PDF)
      o  PowerPoint Version
      Improving Chemical Management in Maine Schools (PDF)
      o  PowerPoint Version
      No More " Methyl Something": Improving Management of Curriculum Chemicals in Schools (PDF)
      o  PowerPoint Version
      Planning for Environmental Health and Safety Issues in Schools (PDF)
      o  PowerPoint Version
                                           5-13

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Chapter 5 - Sustain Your SC3 Program
               5-14

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          Why Become Involved in School Chemical Management?


Your organization can play an important role in addressing a critical health and safety issue facing many schools:
chemical management.  The United States Environmental Protection Agency has launched a national Schools
Chemical Cleanout Campaign (SC3) to address this issue.  Critical to the success of local SC3 programs in schools
is the contribution of expertise and resources from organizations like yours.

Chemicals are found throughout schools, and when handled responsibly, are useful and necessary educational
tools. They allow students to conduct experiments in the lab, create works of art in the studio, and restore vehicles
in the automotive shop.  However, when chemicals are improperly managed, they can pose risks to students, staff,
and the environment, as well as cause lost school days.  Potential chemical  hazards such as explosives, toxics, and
cancer-causing agents can be found in science classes, vocational and trade shops and visual arts studios.
Chemicals like formaldehyde, cadmium, and mercury may be present in classrooms or maintenance areas,
cafeterias,  nurses' offices, school grounds, and athletic fields.

Because you are reading this, your organization most likely has an interest in becoming involved in helping schools
responsibly manage their chemicals. By assisting schools with their chemicals, your organization can help
prevent fires and spills, protect the environment, avoid  lost school days, and most importantly, protect the
health and safety of children and school personnel in your community. By partnering with a school, EPA, or
state agency, your organization can make a difference in the lives of many.
WHAT ARE THE BENEFITS OF BEING A PARTNER IN SCHOOL CHEMICAL MANAGEMENT?
Becoming an SC3 Partner is a win-win proposition for you and the schools you assist. Your organization can
benefit from becoming involved in school chemical management in the following ways:
                          Benefits to a Partner Organization
       >  Organizational pride and satisfaction from improving school health and safety;
       >  Enhanced image as a leader in the community;
       >  Recognition that comes with being part of a federal campaign that has the backing of EPA and
          other agencies;
       >  Heightened organizational visibility via recognition on high-traffic Web sites, in the media, and
          at recognition events; and
       >  Eligibility for credit for EPA's Performance Track program (if applicable).
More details on the benefits of becoming an SC3 Partner follow. First, let's examine the value your organization
can bring in the growing campaign to improve school chemical management.
                                                A-1

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          Why Become Involved in School Chemical Management?

HOW CAN YOUR ORGANIZATION IMPROVE CHEMICAL MANAGEMENT IN SCHOOLS?
Many schools or districts do not have the necessary experience and resources to develop and sustain a
responsible chemical management program. That's where organizations like your's can step up and help make a
difference in schools. Your organization can be part of a team made up of schools, school districts, other SC3
Partners, states, EPA and others, all representing a wide variety of expertise and sharing an interest in safe
schools.  Partners, each with discreet responsibilities, are vital to successfully designing, initiating, and maintaining
a comprehensive and responsible chemical management program.

The graphic below illustrates the key elements of a successful SC3 program - these are areas and issues a school
or district may require your organization's expertise  and experience to address.  Please note the components and
functions represented here are in no particular order. While some of these themes may be related, the connections
portrayed are random and do not imply any dependency.
                          I STORAGE & HANDLING

ChtMICAL CltANOUl & DISPOSAL
                             COMMUNICATION & TRAINING
Examples of activities that current SC3 Partners are performing or participating in include:
       Conducting cleanouts of outdated, unknown, or unneeded chemicals;
       Performing chemical inventories;
       Developing a chemical management plan;
       Providing technical expertise for unfamiliar processes (e.g., requests for proposals or writing contracts);
       Establishing a system to track the purchase, storage, and disposal of chemicals;
       Developing performance goals and measures to gauge chemical management success;
       Developing and conducting chemical management training; and
       Recruiting other organizations to become partners and  help achieve program goals.
                                                A-2

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            Why Become Involved in School Chemical Management?

HOW CAN MY ORGANIZATION BENEFIT FROM PARTNERING WITH A SCHOOL?
Your organization is an essential part of a community.  By teaming up with a local school or school district and other
organizations that care about children, you will be demonstrating your leadership and your concern for that
community. There are a number of ways a school or school district may publicly recognize your organization's efforts
to make schools safer:

     >  Presenting an award to a partner at a public ceremony or school board meeting;
     >  Drafting a press release or contacting local  media outlets to inform them of a partner's efforts;
     >  Publicizing a partner's assistance in a school newspaper or Web site; and
     >  Informing the U.S. EPA of a partner's successful collaboration.

Different schools will have different approaches to recognizing partners. Once you find a school to help, your
organization can discuss more specifically how the school may publicly recognize your contributions.  See Chapter 4,
page 4-13 of this SC3 Workbook for an example of a press release a school might use to recognize your
organization's efforts.

HOW CAN MY ORGANIZATION BENEFIT FROM PARTNERING WITH EPA?
In addition to partnering locally with a school or district, EPA encourages you to consider signing an EPA SC3
Partnership Agreement1.  This agreement can echo the terms of a partnership with an individual school, and also
define the terms and conditions for participating in other SC3 projects.  EPA helps partners find schools and offers
guidance on how to work effectively with schools.  The agency also offers a number of ways in which it can recognize
a partner's efforts:
(1) SC3 INDIVIDUAL PARTNER PRESS EVENT
Organizations can sign an SC3 Partnership Agreement (note: a blank
agreement is provided at the end of the appendix).  This agreement
indicates that your organization is committed to promoting
responsible chemical management in K-12 schools.  EPA will
recognize your commitment to promoting responsible chemical
management in K-12 schools by presenting your organization with a
plaque at a recognition event that will include the press and other
media.

(2) SC3 PARTNER RECOGNITION WEB SITE
Your organization will also be added to the Partners Page on the SC3
Web site as an official national partner. Once you have worked with
the school or school district and have results to share, those results and successes will be posted on the EPA Web
site so other schools, partners, and the public can learn about your achievements.

(3) SC3 RECOGNITION EVENTS
EPA routinely holds recognition events to recognize schools and partners.  In 2007, when the national SC3 program
was launched, EPA held two national press events to recognize SC3 Partners.  EPA has plans to hold similar events
in the coming years.
From left to right: Deborah Edwards, Deputy
Director, Office of Safe and Drug Free Schools, US
Department of Education; Jennifer Abril, Director,
ChemStewards, SOCMA; Susan Bodine, Assistant
Administrator, OSWER, EPA.
         1 http://www.americanchemistrv.eom/s rctoolkit/sec.asp?CID=1819&DID=6828

                                                  A-3

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            Why Become Involved in School Chemical Management?
(4) SC3 PARTNER NETWORK
As an SC3 Partner, your organization becomes part of a national network of companies, federal, state and local
agencies, and national organizations. These organizations have committed to facilitating responsible chemical
management in K-12 schools. Through this network, you have the opportunity to learn about and share best
practices and solutions to overcoming barriers and issues in SC3 partnerships, programs, and projects. SC3
Partners will also have the opportunity to build valuable business relationships with other partners. Periodic SC3
Partner meetings that include other partners, EPA, and other agencies will give you a chance to provide input to EPA
on the direction of the national SC3 program.

(5) TRADE JOURNAL ARTICLES
SC3 has placed articles about the program in trade association journals. EPA will work with your organization
to incorporate your contributions into similar articles.
                      From left to right: Elin Miller, Regional Administrator, Region 10; Kolin Anglin,
                   President, NAHMMA; Deborah Edwards, Deputy Director, Office of Safe and Drug Free
                      Schools, US Department of Education; Susan Bodine, Assistant Administrator,
                                               OSWER, EPA.


                         PRESS RELEASES FOR EVENTS THAT INCLUDED PARTNERS:
             http://vosemite.epa.gov/opa/admpress.nsf/a7b2ee8e45551c138525735900404444/d42fad48425c6a80852573
                                           7d005f72eO!OpenDocument

             http://vosemite.epa.gov/opa/admpress.nsf/eebfaebc1afd883d85257355005afd19/c8d3e8745b91ddd6852572a
                                           700523fc3!OpenDocument
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            Why Become Involved in School Chemical Management?
Once you decide to enter a partnership, there are some key steps you need to take before getting started.  Refer to
the "How Do I Get Involved in a School Chemical Management Project" section of the appendix for more information
on how to get started on helping out schools and districts in your area.
                        Background on EPA's Performance Track Program

          EPA's Performance Track Program recognizes environmental excellence by encouraging facilities
             with strong environmental records to go above and beyond their legal requirements. The
            Performance Track program recognizes SC3 partnerships as credit for meeting the renewal
          requirements. To qualify for membership renewal, a facility (or organization) must meet all of the
          criteria required for entrance into the program. In addition, the facility must demonstrate good-faith
          improvement toward meeting its environmental performance goals. Check out the examples below
                for more information on how partnering with a school can benefit your organization.

             DESCRIPTION OF A SAMPLE ALTERNATE GOAL INVOLVING SC3 UNDER PERFORMANCE TRACK
                    http://www.epa.gov/performancetrack/program/sample_altcomm.htm

                 EXAMPLE OF ONE COMPANY USING SC3 AS A PERFORMANCE TRACK ALTERNATE GOAL
         https://vosemite.epa.aov/opei/ptrack.nsf/vRenewalViewPrintView/D5F924FC36CAB985852572F8005C924A
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            Why Become Involved in School Chemical Management?
                   How Do I Gat Involved in a Sdhaol Onemiieal Management Project?
Regardless of whether a school or school district has already launched an SC3 program or is simply interested in
improving its chemical management situation, you can work with school officials to figure out how to best support their
efforts. The first step is to get your management to determine the level of support that your organization is willing to
provide. The next step is to identify a school or school district that could use your assistance, and determine the kinds
of projects in which your organization can play a role.  EPA can help you identify schools in your area, offer guidance on
how to work with schools on SC3 projects, and recognize skills and  resources within your organization that would be
useful to a school's chemical management program.

WHAT ARE SOME THINGS TO THINK ABOUT WHEN APPROACHING MANAGEMENT?

Before approaching a school or school district, you will likely need to get management approval. Your management
will need to decide whether school chemical management is an area in which it would like to volunteer staff time and
expertise.  If the answer is 'yes,' then you will want management to focus on the types and level of support your
organization is willing to offer (e.g., time, money, resources); this will allow your organization to approach a school
with a clear idea of what it is willing to do in an SC3 partnership. Regardless of the method you choose to approach
and inform your management, there are  a few topics you may want to cover with them:

         >  The ways your organization can benefit from getting involved in SC3;
         >  The benefits to the school, school district and community;
         >  The various ways your organization can help; and
         >  The level of investment your organization could make in SC3.

There are a few different ways that an organization can support a school or school
district in SC3:
    >  Provide assistance through a single project with a defined start and end date,
       such as a chemical cleanout or a training;
    >  Provide ongoing sustainable support to the school through activities such as
       yearly responsible chemical management training for teachers and other staff; or
    >  Be available only in the event of an emergency or natural disaster.

Your organization may choose one or more of these paths over time.  Regardless, any level of assistance your
organization can provide will help to improve school safety.

Once your organization has decided to get involved in school chemical management, it's time to identify a school or
school district to help.
0J   VISIT THE SCHOOLS
  CHEMICAL CLEANOUT CAMPAIGN
         WEB SITE

     www.epa.gov/sc3
             Partnering with EPA to Address Chemical Management in Schools
          When approaching your management regarding getting involved in school chemical
          management, consider how becoming a partner in EPA's national SC3 program might be of
          interest to your organization. Refer to Part 1 of this Appendix, Why Become Involved in School
          Chemical Management?, for a listing of the benefits of partnering with EPA.
                                                  A-6

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           Why Become Involved in School Chemical Management?
                  How Do I Gat Involved in a Sdhaol Onemiieal Management Project?
HOW DO I GET STARTED?

Your organization may have an existing relationship with a school(s) that you can use to help the school get started with
responsibly managing its chemicals. In addition, you should contact the EPA SC3 Account Manager responsible for
your region to enlist their help in finding a school or school district with which to work. The table below provides a listing
of EPA SC3 Account Managers to contact for answers to questions about SC3 and how your organization can get
involved with a school on an SC3 project. Please refer to the SC3 Web site for the most up to date account manager
contact information1:  http://www.epa.qov/epawaste/partnerships/sc3/live.htm.
EPA Points of Contact on the Schools Chemical Cleanout Campaign (SC3)
By Geographic Region
Kristina Meson
Meson. kristinaO.epa.qov

703-308-8488
EPA Reqion 2
New Jersey
New York
Puerto Rico
US Virgin Islands
7 Tribal Nations
EPA Reqion 6
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
65 Tribal Nations
EPA Reqion 7
Iowa
Kansas
Missouri
Nebraska
9 Tribal Nations
Eileen Naples
Naples.eileen@epa.gov
703-308-0216
EPA Reqion 1
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Tribal Nations
EPA Reqion 10
Alaska
Idaho
Oregon
Washington
Pacific Northwest
Indian Country
EPA Reqion 8
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
27 Sovereign Tribal
Nations
Cyndy Merse
Merse.cynthiaO.epa.gov

703-308-0020
EPA Reqion 4
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
6 Tribal Nations
EPA Reqion 5
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
35 Tribal Nations
EPA Reqion 9
Arizona
California
Hawaii
Nevada
Pacific Islands
Over 140 Tribal Nations
Rhonda Minnick
Minnick. rhonda@epa.gov

703-308-8771
EPA Reqion 3
Delaware
Maryland
Pennsylvania
Virginia
West Virginia
District of Columbia


        1 You may also contact Kristina Meson, SC3 National Program Manager, by phone at (703) 308-
          8488, or by email at meson.kristina@epa.gov.

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            Why Become Involved in School Chemical Management?
                  How Do I Gat Involved in a Sdhaol Onemiieal Management Project?
    In addition to the above contacts, there is a SC3 contact in each region who knows about schools that can
    use your assistance. The contact information for each region can be found at the "Where You Live" page
                                      on the SC3 Web site:
                   http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/live.htm
HOW WILL EPA AND MY ORGANIZATION WORK TOGETHER?

EPA will work with you to answer your questions and help your organization get involved in a school SC3 project that
fits well with your capabilities. EPA provides information resources and guidance on various chemical management
topics on the SC3 Web site.  You can also contact an EPA Account Manager or a regional SC3 lead for help with the
following:

    >  Identifying schools which may need assistance;
    >  Brainstorming ways your organization can assist a school; and
    >  Forming teams to make the project a success.

When you contact the EPA SC3 Account Manager or a regional SC3 lead, there are a few questions they may ask to
assess how your organization can be of greatest assistance to a school (see below).  Some of these questions are
good ones to pose to your management as you brainstorm how the organization will get involved in SC3:
Potential Questions When Considering A School Chemical Management Project
1.
2.
3.
Where is your organization located?
Has your organization ever worked with a school or
school district? If so, might you want to work with
them again?
What type of expertise can you offer to a school?
a. Chemical inventory? Cleanout? Disposal?
b. Providing chemical management training?
c. Providing emergency chemical management
services to a school or school district?






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            Why Become Involved in School Chemical Management?
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          Potential Questions When Considering A School Chemical Management Project
       d.   Writing contracts or request for proposals for
           school cleanouts?
       e.   Enlisting other partners/building a partnership
           team?
 4.  Does your organization belong to another EPA
     program such as Performance Track or the National
     Partnership for Environmental Priorities?
Communicate openly with EPA about the types of assistance your organization can provide and any reservations that
you may have.  EPA SC3 Account Managers and regional SC3 leads are skilled at matching a school's needs with an
organization's capabilities, and in finding other partners to complement your organization's role on a school project.

If your organization decides to become an EPA Partner, you will be asked to sign an SC3 Partnership Agreement2.
This agreement simply indicates that your organization is committed to promoting responsible chemical management
in K-12 schools, and does not impose specific requirements upon your organization.

EPA will recognize your commitment to promoting responsible chemical management in K-12 schools by presenting
your organization with a plaque at a recognition event that will include the press and other media. EPA will also add
your organization to the Partners Page on the SC3 Web site.

HOW WILL EPA HELP MY ORGANIZATION?

Once your organization reaches out to EPA and expresses  an interest to get involved in an SC3 project, EPA will do a
variety of things to arrange an SC3 project that matches your expertise and  resources with a school or school district:

       1.   EPA will form a team to help you find a school. At a minimum, the team will include your organization, EPA
           SC3 Account Managers, and regional SC3 leads. State agencies and other SC3 partners (refer to the SC3
           Web site: www.epa.gov/sc3 and  click on "Partners") may join the team as well.
       2.   Once a school is identified, the team will:

           >  Identify an SC3 Champion at the school or school district who will generate support within the school or
              school district and, possibly, the community (the champion will likely be your primary point of contact
              within the school);
           >  Determine the scope of the project; and
           >  Assist in defining roles and  responsibilities.
         2 http://www.americanchemistrv.eom/s rctoolkit/sec.asp?CID=1819&DID=6828

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            Why Become Involved in School Chemical Management?
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       3.   EPA can then help to:
           >  Attend (possibly through conference calls) initial meetings with the school; and
           >  Put you in contact with other organizations that have conducted or facilitated an SC3 project.

       4.   EPA will be available to you throughout the project if you have questions or need support.  When the
           project achieves a significant milestone or after the  project is successfully completed, the team—especially
           EPA- will help you gain local and national recognition by posting your accomplishments and successes on
           the SC3 Web site.

       5.   Your organization may be eligible to receive an award (note: An enforcement screen will likely be  needed to
           qualify your organization as an award recipient).


HOW SHOULD I APPROACH THE INITIAL MEETING WITH A SCHOOL OR SCHOOL DISTRICT?

It depends.  If you find a school or school district has already evaluated or begun to evaluate its chemical management
situation, school officials will not need background on the merits of establishing an SC3 program. Instead, consider
speaking with them about how your organization's experience and expertise could help them. If a school has  not
addressed its chemical management situation or launched an SC3 program, it may be more appropriate to discuss the
merits of undertaking projects to improve school chemical management. In this section we provide you with tips to
handle either situation.

When you begin working with a school, it will be important to gauge how far along the school is in developing and
implementing an SC3 plan. In your initial discussions with school officials,  listen carefully to how your organization can
best address their needs and  then be prepared to offer suggestions. If a school is unsure about how to proceed,
discuss potential approaches, referring them to the graphic below to get an idea of how developed their chemical
management program may be. Let school officials know how your organization can help with any or all of the  "steps to
a safer school..."
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            Why Become Involved in School Chemical Management?
                   How Do I Get Involved In a School Clnemiieal Management Project?
                           THE STEPS TO A SAFER SCHOOL

                    THROUGH RESPONSIBLE CHEMICAL MANAGEMENT
                                                               HOC-
                           Decide What
                           Your Program
                           Will Look Like
STEP1
Evaluate Chemical
 Management
   Practices
  and Identify
 Program Goals
                                                                                   ' I". •'
For schools that are not familiar with the importance and benefits of responsible chemical management, the initial
meeting gives your organization the opportunity to provide the school with some background on the topic and convey
how you can help.  We suggest that you tie your service efforts to tangible benefits, such as:

   >  Saving money on purchasing and disposing of chemicals;
   >  Reducing the use of dangerous chemicals in schools;
   >  Preventing dangerous and costly spills and releases, resulting in school days lost;
   >  Reducing liability and loss of public confidence; and
   >  Making the school safer for students and staff.

In your initial discussions with a school or school district, refer to the following graphic which illustrates the key
elements of a successful SC3 program. Point out to the school those areas and issues that your organization's
expertise and experience may address. Please note the components and functions represented here are in no
particular order.  While some of these themes may be related, the connections portrayed are random and do not
imply any dependency.
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            Why Become Involved in School Chemical Management?
                   How Do I Gat Involved in a Sdhaol Onemiieal Management Project?
            IJAEBSHP & RESOURCES  ]           CHEMICAL INVENTORY

                              ^^^^^^^
                         \ STORAGE & HANDLING |      |  CHEMICAL CLEANOJT & DISPOSAL  |          PURCHASING
                                                                  POLLUTION PREVENTION
                            COMMUNICATION & TRAINING]
               [    SPU RESPONSE    ]
As you prepare for the initial meeting, keep in mind that some schools or school districts may:
   >  Require more information on developing or improving an SC3 program, which EPA provides in other parts of
      this Workbook. You can find other resources on the SC3 Web site.
   >  Be somewhat skeptical about why your organization wants to get involved. Keep it positive and focus on the
      ways your organization can improve the school's chemical management situation.
   >  Be somewhat cautious about going into detail concerning their chemical management situation.
   >  Have competing priorities and may not want to start tackling this issue right away.
   >  Have a chain of command and may need to get approval from people not at the meeting.  This may take some
      time.
   >  Need to be reassured that they will be working with a team to ensure the success of the project.
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          Why Become Involved in School Chemical Management?
                 How Do I Gat Involved in a Sdhaol Onemiieal Management Project?
  BACKGROUND ON HOW SCHOOLS OPERATE

  Perhaps you are a parent of a K-12 student and are familiar with the school at which your child attends.  If
  you do not have ties to a school in your area, however, it may not be immediately apparent how schools
  operate.
  Working with schools and school districts may present challenges that are not found when working with other
  institutions. Some things to keep in mind include:
    >  Schools are operated and managed at a local level;
    >  Schools are governed and influenced by a complex set of institutions (which means that it may take
       longer than expected to arrange and carry out a project);
    >  Schools have unique priorities, standard  operating procedures, and challenges; and
    >  Schools may not realize that they have a chemical mismanagement problem or may want to avoid the
       appearance that they are not protecting their students adequately.
HOW SHOULD I FOLLOW UP AN INITIAL MEETING WITH A SCHOOL?

We recommend that you follow up the initial meeting with a school by:

   >  Answering questions;
   >  Providing additional information;
   >  Bringing in EPA for added support;
   >  Scoping out the project(s) discussed; and
   >  Capturing and/or codifying the specific terms of the project(s).

As with any joint venture, it is necessary to define the terms and expectations of the agreement early on so
both parties know what to anticipate as the project moves forward.  A good way to outline the roles,
responsibilities, and limitations of both parties is by preparing a partnership agreement, a team charter, a
statement of purpose, or some other document agreeable to both parties. If you choose to use a partnership
agreement, you may use the Sample Partnership Agreement at the end of this section as a model and modify
the language so that both you and the school are comfortable.  Whatever form the document may take, it
should address the following:

   >  The specific tasks that your organization and the school intend to perform; and
   >  A proposed schedule for agreed upon activities, including a beginning and end date, if applicable.

Defining the elements of the relationship makes both parties aware of their responsibilities and can help to
manage expectations over time.

Maintain an open dialogue with your partnering school  and adjust formal agreements, as necessary. Get to
know and communicate regularly with the school's SC3 Champion as he or she will be a source of
information on the school and its chemical management needs as the project moves forward.

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           Why Become Involved in School Chemical Management?
                  How Do I Gat Involved in a Sdhaol Onemiieal Management Project?
Below is an example of a partnership agreement that your organization can sign to partner with a school to
responsibly manage their chemicals.
                                    Sample Partnership Agreement
         Partnership Agreement Between	(Partner Name) and	(School/District Name)

Through this agreement, [Partner's Name], hereafter referred to as "SC3 Partner", joins in partnership with [School/District
Name], to help create healthier school environments for students and personnel.  SC3 Partner intends to support the goals of
the Schools Chemical Cleanout Campaign (SC3) program, which are to: remove accumulations of unnecessary chemicals from
schools; facilitate implementation of responsible chemical management practices; and raise awareness of the potential risks to
students and school personnel created by mismanaged chemicals.  The SC3 Partner intends to promote responsible chemical
management in [School/District Name]. [School/District Name] intends to cooperate with other parties to this agreement to
support these same goals.


Partner Role
SC3 Partner intends to provide, without charge to [School/District Name], resources or services in the following areas at [insert
name of school(s) or school district(s)]:

    Q  Inventory chemicals
    Q  Develop a sustainable chemical inventory system
    Q  Package mismanaged/unnecessary chemicals for removal
    Q  Remove mismanaged/unnecessary chemicals
    Q  Proper disposal of chemical waste
    Q  Develop chemical management training
    Q  Conduct chemical management training
    Q  Assist with the development of a chemical management program
    Q  Assist with the implementation of a chemical management program
    Q  Recruit other SC3 Partners
    Q  Develop performance goals and measures to gauge chemical management success
    Q  Administer SC3 Partner Program to Trade Association/Organization member companies and other interested parties
    Q  Other (describe)	
        (Use additional pages if necessary)

The SC3 Partner agrees to provide services to [School/District Name] in the amount of [# of hours] each [duration of time (e.g.,
semester, year, etc.) to addressing the aforementioned resources and services.
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           Why Become Involved in School Chemical Management?
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                                    Sample Partnership Agreement


School / District Role
[School/District Name] will provide the SC3 Partner with the following recognition opportunities:
    Q      Presence at publicity opportunities (e.g., local media events, PTA meetings, etc.)
    O      Prominent display of SC3 Partner name and logo in communication and outreach materials to stakeholders
    Q      Recognition as program partner in all press releases, with opportunities for SC3 Partner quotes


Limitations
This Partnership Agreement describes the actions [Partner Name] agrees to undertake as a SC3 Partner. It does not impose
any legally binding obligations on [School/District Name], nor is [School/District Name] imposing, through this Agreement, any
legally binding obligations on the SC3 Partner or on any other entity.

This Partnership Agreement does not create any right or benefit, substantive or procedural, enforceable by law or equity against
[School/District Name],  their officers or employees, or any other person.


Effective Date, Modification, and Termination
This agreement becomes effective upon the date of the last signature.  This agreement will be in effect for [# of years] from the
date of the last signature. It may be modified or amended only through written agreement of all signatories. Any signatory may
terminate this agreement by providing 30 days written notice to the other  parties.
Signature and Date, SC3 Partner Representative
Signature and Date, School's Legal Counsel / Principal / School Board Director
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          Why Become Involved in School Chemical Management?
            How Can I Continue to Kelp Schools Improve Chemical Management?

Ideally, your organization will continue to work with a school beyond the initial SC3 project to improve the chemical
management situation and be available to assist with new challenges.  Near the end of your organization's initial
project, you will probably ask, "What's next?" We offer a variety of steps you can take to answer that question, and
continue to find ways to improve school chemical safety:
 Periodically revisit and reassess any
 agreements with your partnering school.
 You may find that your organization's role in
 improving a school's chemical management
 situation changes over time.  Revisit your
 commitments and adjust them, if necessary, to
 meet both your organization's needs and those
 of your partnering school.
  Engage EPA for guidance. As your SC3
  project develops, you may need additional
  help or advice.  The EPA SC3 Account
  Manager* and regional SC3 lead are valuable
  resources to contact. They may know of a
  partner with the expertise that you need or
  they may have  heard how another partner
  resolved a similar situation.  Don't hesitate to
  call on them with your questions. ("Please refer
  to the SC3 Web site for the most up to date account
  manager contact information)
   Keep open communication with the project team,
   especially the SC3 champion. As your initial project
   progresses, make sure to stay in touch with the school
   SC3 Team, especially the SC3 Champion and the EPA
   SC3 Account Manager* (or the regional SC3 lead).
   Agree on a time to periodically catch up with the
   school.  Inquire about other projects, initiatives, and
   plans, and explore the school's receptiveness to your
   assistance. (*Please refer to the SC3 Web site for the most up
   to date account manager contact information)
  Achieve results and communicate them to
  your management and the SC3 project team.
  As your project nears completion, be sure to
  inform your management of positive impacts and
  results. Keep track of the types and levels of
  assistance your organization  provided so that
  your organization can make an informed decision
  about partnering with other schools or districts.
  Consider communicating your results through a
  success story or through a local or national press
  event.
          Have a plan for issue
          resolution, should that become
          necessary.  Everybody on the
          SC3 Team wants a project to be a
          success, but sometimes a
          problem arises that requires the
          perspective of someone not so
          close to the situation.  Consider
          developing a procedure ahead of
          time for addressing problems that
          may arise and following it when
          necessary.
Consider helping other schools. You may find
that after a time, the school you have been
helping has its chemical management under
control and requires little to no ongoing assistance
from your organization.  You might explore other
schools in the area to find one that could benefit
from the guidance and help you can offer.
 Consider assisting when there is an emergency.  Even if the school or school district has established a
 sustainable responsible chemical management program and your help is no longer required, consider how your
 organization may be of assistance when there is a natural disaster or other emergency.
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Why Become Involved in School Chemical Management?
 How Can I Continue to Kelp Schools Improve Chemical Management?
                     EPA530-K-08-003
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