Building Successful Programs to Address
Chemical Risks in Schools:
A Workbook with Templates, Tios. and Techniques
EPA530-K-07-007
OCTOBER 2007
hup; //www.epa.gov/scS
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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
Why does EPA care about chemicals in schools?
Why did EPA create this Workbook?
What are the key components of a school chemical management ii
program?
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 -5
Activity 4 - Conduct a visual tour to get first impressions of your 1 -6
school's chemical management situation, policies, and
practices
Activity 5 - Perform a comprehensive evaluation of your school's 1 -7
chemical management situation, policies, and procedures
How do I figure out the issues or concerns that my SC3 program needs to 1-13
address?
Activity 6 - Identify issues and agree to SC3 program goals 1 -13
How do I develop goals for my responsible chemical management 1 -13
program?
Activity 7 - Develop performance measures to track the progress of 1-15
your SC3 program
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Table of Contents fcont.)
Summary 1-17
Additional Tools and Examples 1-18
Worksheet 1-1: Evaluating Your School's Chemical Management 1-19
Situation, Policies, and Procedures
Worksheet 1-2: Defining SC3 Program Goals that Address Issues / 1-23
Areas of Need
Worksheet 1-3: Developing Performance Measures Based on Desired 1-24
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 2-6
partners 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
Activity 8 - Identify any regulations that may affect your SC3 program 2-12
Summary 2-14
Additional Tools and Examples 2-15
Worksheet 2-1: SC3 Activities and Performance Measures to Reach 2-16
Program Goals
Worksheet 2-2: SC3 Progress Report 2-17
Worksheet 2-3: SC3 Staffing Plan 2-18
Worksheet 2-4: Identifying Potential Obstacles and Solutions 2-19
Worksheet 2-5: SC3 Labor Cost Estimate 2-20
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Table of Contents fcont.)
Chapter 3 - Publicize your SC3 Program 3-1
Why is it important to publicize my SC3 program? 3-1
Activity 1 - Develop and deliver an effective program message with 3-1
an 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 3-10
Audiences
Worksheet 3-2: Methods of Communication and Publicity for your 3-11
Program Message
Chapter 4 - Put Your SC3 Program Into Action 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
Activity 2 - Establish and modify existing SC3 policies and 4-3
procedures
Activity 3 - Train appropriate personnel on responsible chemical 4-4
management
Section 2 - Special Chemical Management Projects 4-5
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Table of Contents fcont.)
Project 1 - Perform an inventory of all chemicals and chemical 4-5
products
Why should I conduct a chemical inventory? 4-5
What is involved in performing a chemical inventory? 4-6
What steps do I take after completing a chemical inventory? 4-8
Project 2 - Secure a chemical cleanout professional 4-9
Why should I conduct a chemical cleanout? 4-9
How do I get started on a chemical cleanout? 4-9
Sub-activity A - Evaluate your chemical inventory and create a 4-10
list of chemicals to dispose (a disposal list)
Sub-activity B - Identify a qualified professional(s) to assist in 4-12
the cleanout and disposal process
What is a Request for Proposal? 4-13
How do I advertise an RFP? 4-14
How do I select a qualified professional? 4-14
How do I estimate cleanout and disposal costs? 4-16
Are there ways to lower disposal costs? 4-17
Sub-activity C - Prepare for chemical cleanout and disposal 4-18
Sub-activity D - Take additional steps to reduce the need for 4-19
future chemical cleanouts
Summary 4-19
Additional Tools and Examples 4-20
Exhibit 4-3: Vendor Qualifications Checklist 4-21
Exhibit 4-4: Sample Price Quote 4-22
Exhibit 4-5: Examples of Cost Saving Techniques 4-23
Exhibit 4-6: Sample RFP 4-24
Worksheet 4-1: Post-Inventory Evaluation of your Chemical 4-31
Management Situation
Worksheet 4-2: Chemical Disposal List 4-32
Chapter 5 - Sustain Your SC3 Program 5-1
What can I do to sustain my program? 5-1
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Table of Contents fcont.)
Activity 1 - Evaluate and measure your program's progress, methods 5-2
and capabilities
Activity 2 - Keep chemical management policies and procedures up- 5-3
to-date
How can I keep my chemical management policies and procedures up-to- 5-3
date?
Activity 3 - Conduct periodic training 5-4
How should I go about training those involved in chemical management? 5-4
Activity 4 - Communicate progress and success to keep enthusiasm 5-6
and awareness high
Is communicating program progress important to sustaining success? 5-6
Activity 5 - Work with your partners for ongoing technical assistance 5-7
What kinds of ongoing technical assistance do I need? 5-7
Activity 6 - Estimate staffing and funding requirements and continue 5-8
to look for new funding sources for ongoing SC3 activities
What kind of funding do I need to maintain my SC3 program? 5-8
Summary 5-10
Additional Tools and Examples 5-11
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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, 1-8
Policies, and Procedures
Figure 1 -1: Blank Material Safety Data Sheet (MSDS) (Example) 1 -11
Figure 1-2: Chemical Safety Label 1-12
Exhibit 1-2: Defining SC3 Program Goals that Address Issues /Areas of 1-14
Need
Exhibit 1-3: Developing Performance Measures Based on Desired Goals 1-16
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 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: Post-Inventory Evaluation of your Chemical Management 4-8
Situation (Example)
Exhibit 4-2: Chemical Disposal List (Example) 4-11
Exhibit 4-3: Vendor Qualifications Checklist 4-15
Exhibit 4-4: Sample Price Quote 4-16
Exhibit 4-5: Examples of Cost Saving Techniques 4-17
Exhibit 4-6: Sample RFP 4-25
Exhibit 5-1: Training Topics Checklist 5-6
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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 Schools Chemical Cleanout Campaign 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 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:
LEAKRSHP & RESOURCES^] { CHEMICM. INVENTORY ]
I STOBAGE & HANDLIHC | | CHEMICAL CLEANOUT & DISPOSAL | PURCHASING
COMMUNICAIION El TRAINING
SPILL RESPONSE
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 Disim
ADMINISTRATOR:
R, &:
COLLEGES a
UNIVERSITIES
PARENTS &
CAREGIVERS
V
INDUSTRY
PARTNERS
TRADE &
PROFESSIONAL
ORGANIZATIONS
These potential partners can help your school(s) by cost-effectively assisting with:
Inventorying chemicals;
> Developing a sustainable chemical inventory system;
Packaging mismanaged/unnecessary chemicals for removal;
Removing mismanaged/unnecessary chemicals;
Proper disposal of unneeded chemicals;
> Developing a chemical management training program;
> Conducting chemical management training;
> Developing a chemical management program;
Implementing a chemical management program;
Recruiting other SC3 partners; and
Developing performance goals and measures to gauge chemical management success.
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Introduction:
A Workbook with Templates, Tips, and Techniques
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
STEPt
Evaluate Chemical
Management
Practices
and Identify
Program Goals
Decide What
Your Program
Will Look Like
Publicize
Your
Program
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:
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 SC3 policies and procedures.
Train appropriate personnel on responsible chemical management.
Section 2: Special Chemical Management Projects
Perform an inventory of all chemicals and chemical products.
Secure a chemical cleanout professional.
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.
Work with your partners for ongoing technical assistance.
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
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 any problems and consider any 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);
r Publicize your SC3 program (Chapter 3);
," Put your SC3 program into action (Chapter 4); and
f Sustain your SC3 program (Chapter 5)
Piece by Piece: Addressing Chemical Issues in Separate and Manageable 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.
Remember that doing something is better than doing nothing.
1 - FIND A AND A FOR SC3
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 types of personnel 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;
r 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 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
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.
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 are 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
2 - AND
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. Knowing who can provide specific types of advice and services is
important to evaluating your school's chemical management situation, policies, and practices. 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.
A stakeholder is someone who has a stake in 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;
1-3
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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
,- Science, art, and vocational teachers;
r Business managers;
.>- Insurance representatives;
." School legal counsel;
." Facilities and custodial staff; and
^ Risk managers.
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, including:
," Inventorying chemicals;
Developing a sustainable chemical inventory system;
* Packaging mismanaged/unnecessary chemicals for removal;
," Removing mismanaged/unnecessary chemicals;
* Proper disposal of unnecessary chemicals;
Developing chemical management training;
," Conducting chemical management training;
Developing a chemical management program;
Implementing a chemical management program;
," Recruiting other SC3 partners; and
," Developing performance goals and measures to gauge chemical management success.
EPA has formed partnerships with several organizations under its SC3 program. These partners agree to
provide services to schools to remove potentially dangerous chemicals; assist schools to responsibly
manage chemicals; and raise awareness of the issue.
Other places you can look to for assistance are:
r State educational and environmental agencies;
-- Trade and professional organizations;
." Industry partners and local businesses;
." Colleges and universities;
^ Fire and police departments;
^ Parents;
r School service organizations; and
-- Local schools and/or districts that have an SC3 program.
1-4
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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
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 schools. A representative from a local
pollution prevention organization also educated the Intermediate Unit on the problems in 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.
3 - SC3
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 of one or more of the following:
r School management practices, including purchasing;
r Curriculum development;
? Chemical management safety and training;
r Health concerns;
f 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 experienced people later. We suggest that the core team not grow too large or it could become
difficult to make decisions and solve problems.
1-5
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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
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:
r Your school health or wellness team;
r Crisis planning team;
r Indoor Air Quality Tools for Schools team; or,
r Other groups that focus on environmental health in school.
4 - A TO GET OF
AND
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. At
least two people from your team who are familiar with chemicals should 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.
Chemicals should be handled or moved as little as possible. Chemical containers that are
leaking or distorted should not be touched. Bring a notepad and a camera (if available)
with you on the visual tour to record your observations and impressions. Also, in each area
where chemicals are found, ask school staff for their opinion about current conditions
and/or previous situations where chemicals may have been improperly stored, handled, Be sure to take and
or otherwise appropriate for attention. A chemical may be appropriate for attention when your
jt js; visual tour so that you,
your SC3 Team, and
r In a container that is in poor condition (e.g., corroded, has crystals growing Up^
around the cap); WhiCh to set
r Stored in inappropriate containers, such as buckets or reused food containers; priorities and to
r Expired' a potential chemical
- Unidentified or not clearly labeled with the chemical name, date, and storage situation,
and handling requirements;
r Stored near incompatible chemicals (alphabetical storage is also inappropriate);
r Stored on deteriorating, unstable, or inappropriate shelving (e.g., flammables stored on wooden
shelves, corrosives stored on metal shelves); or,
r Unsecured.
You should also note whether particular chemicals appeared to be 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.
1-6
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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
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.
5 - A OF
AND
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:
\%i"
r Collect:
o Information about the chemical management situation, policies, and procedures at
your school;
o Materials such as invoices for the purchase and disposal of chemicals;
o Information about science and art curricula; and The comprehensive
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, management
and up-to-date they are as well as how the policies and procedures are being and
followed; should be a effort
,>" Talk to staff involved in any phase of the "chemical management lifecycle" (i.e., led b^the SC3 Pr°9ram
anyone involved in the purchase, storage, inventory, use, and disposal of
chemicals and products containing chemicals); and
r 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.eDa.state.il.us/D2/qreen-schools/index.html
1-7
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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 address 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; 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)
Answer
of
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 "micro-scale"
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.
1-8
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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)
Answer
of
Storage
Does the school have a policy or set of procedures
for storing chemicals (e.g., a Chemical Hygiene
Plan)?1
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)? 2
Are all MSDSs kept together in a common
location?
Are all chemicals labeled, including name,
purchase/expiration dates, and storage
information? 3
Are chemicals stored according to type and group
(not alphabetically)? 4
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.
Head of chemistry department left; 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.
1See 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
2 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
3 See Figure 1-2 for an illustration of a chemical safety label from Dana Farber Cancer Institute (DFCI).
4 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/
1-9
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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)
Answer
of
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.
1-10
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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
Emergency Telephone Number
Address (Number, Street, City, State and ZIP Code)
Telephone Number for Information
Date Prepared
Signature of Preparer (optional)
Section IIHazardous Ingredients/Identity Information
Hazardous Components (Specific Chemical Identity, Common Name(s))
OSHA PEL
ACGIH TLV
Other Limits
Recommended
% (optional)
Section IIIPhysical/Chemical Characteristics
Boiling Point
Specific Gravity (H20 = 1)
Vapor Pressure (mm Hg)
Melting Point
Vapor Density (AIR = 1)
Evaporation Rate (Butyl Acetate = 1)
Solubility in Water
Appearance and Odor
Section IVFire and Explosion Hazard Data
Flash Point (Method Used)
Flammable Limits
Extinguishing Media
Special Fire Fighting Procedures
Unusual Fire and Explosion Hazards
(Reproduce locally)
OSHA 174 Sept. 1985
1-11
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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
Figure 1-2: Chemical Safety Label
4 May detonate - Vacate
area if materials are
exposed to fire
3 Strong shock or heat mag
detonate - Use monitors
from behind explosive
resistant barriers
Violent ch*m1c*l
change possible
- Use hose
streams from
distance
1 Unstable if heated
- Use normal
precautions
0 Norm-ally 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 5
And
http://www.cdc.gov/niosh/docs/2007-107/6
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
5 From the Environmental Health and Safety Office at the DFCI.
6 School Chemistry Laboratory Safety Guide from CPSC, CDC, and NIOSH.
1-12
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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
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.
6 - Am To SC3
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.
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:
r Look at your self-evaluation and set goals that address its main concerns;
> Consider insights and concerns from stakeholders, customers, and potential partners;
r Set goals that can be measured;
r Set reasonable goals that can be achieved within the desired timeframe; and
r Make sure your goals lead to a sustainable, successful SC3 program.
1-13
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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.
Goals of your SC3 program should 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
Purchasing
/ of
(1) My school does not have a
chemical purchasing policy.
(1) Establish purchasing policy that avoids 'bulk'ordering and
emphasizes less or non-toxic alternative chemicals,
(2) Centralize chemical purchasing at district level.
Storage
(1) Some stored chemicals are
unlabeled.
(2) Storage areas are not secured.
(1) Establish policy requiring all onsite chemicals to be labeled
according to state regulations.
(2) Have copies ofMSDS for all chemicals stored onsite to 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.
Inventory
(1) There is no way to know how many (V Establish an inventory policy and set of procedures.
and what type of chemicals are (2) Establish chemical inventory database that is updated
present in the school. when chemicals are purchased, used, or disposed of.
Use
(1) Our school has no contingency
plan for a chemical emergency.
(2) Chemistry curriculum uses many
chemicals that are known
carcinogens.
(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.
Disposal
(1) Chemicals are routinely poured
down drain and put in trash.
(1) Develop disposal procedures for each chemical type used
in the school.
1-14
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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'.
? - TO THE OF SC3
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 need to 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 someone 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 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:
r Amount, by type and weight, of chemicals removed; Measure progress by
f Number of training sessions completed; department, when
f Number of teachers, facilities personnel, and administrators trained; and a little
r School populations protected or serviced. can be good for
and spur progress,
,,..,.,. iti -ii- j. i Consider ways to challenge
Keep in mind that measurements of changes in behavior are an important each depart^ent to reduee
indicator of program success. Evaluations of how well training exercises purchasing,
improve a staffs knowledge and expertise in chemical handling is an example of and disoosai
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. Its OK if
your worksheet does not look like the one in the example, just try to be as detailed as possible.
1-15
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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 on site
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
2years
2 Years
1 Year
6 mo.
7 Year
2 Years
1 Year
7 Year
7 Year
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
Program Manager.
Number (and %) of passed
"inspections" performed by the
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 on site
storage.
1-16
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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
1-17
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Chapter 1 - Evaluate your Chemical Management Practices and Identify SC3 Program Goals
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
1-18
^
-------
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
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
1-19
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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 (cont'd)
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
1-20
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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)
of
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
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
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)
Answer
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
1-22
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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
S3 j ! A f N d Goal
J
Purchasing (1)
(2)
Storage (1)
(2)
Inventory (1)
(2)
Use (1)
(2)
Disposal (1)
(2)
1-23
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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
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 (cont'd)
Program
Component
Inventory
Use
Goal
Deadline
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
Disposal
Goal
Deadline
1-26
-------
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.
LEAQERSHP & RESOURCES [ CHEMICAL INVENTOKY
| STORAGE & HANDUNC CHEMICAL CLEANOUT & DISPOSAL \ PUUCHASINC
POLLUTION PREVENTION
COMMUNICATION & TRAINING
SPILL Rtspcmst
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.
Remember that no matter which areas and components of a chemical management you are developing at
this point, doing something is better than doing nothing. 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
-------
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 detailed 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:
r Chapter 3 for crafting an SC3 message and conducting communication efforts; and
r Chapter 4 for ideas on how to put your program into action.
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.
r Identify ways that potential partners can contribute to achieving the goal by providing funds and in-kind
services.
r 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
1 - THE WILL
In most cases, there is more than one way to achieve a goal. Your team should evaluate various options
for achieving a goal and adopt the best option for your school.
First, identify some basic options for approaching 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:
r Determining if a chemical is really needed to do the job or if there are non-chemical methods to
accomplish the task;
r Identifying appropriate less-toxic alternatives to chemicals in use;
r Evaluating using smaller quantities of toxic chemicals when alternatives are not readily available;
f Pushing for changes in district-level purchasing;
r Creating an 'accepted use' list for chemicals allowed in your school; or
r Some combination of the above.
Second, for each option, 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 need to 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 of a 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)
SO
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 could be incorporated for use, 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.
vi. 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. .
viii. Consult with person or department in charge of purchasing alternative
chemicals and reduced quantities of toxic chemicals to purchase.
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].
2 - A FOR AND
When setting deadlines for the completion of SC3 activities, we suggest that they be realistic so that
assigned personnel are motivated to stay on track and goals can be achieved. 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. Worksheet 2-2 in the Additional Tools and Examples section at the end
of this chapter can be used 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.
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Chapter 2 - Decide What Your SC3 Program Will Look Like
Exhibit 2-2: SC3 Progress Report (Example)
SC3
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
20oz
7oz
5
After
Woz
lib
9
Status as of _/_/_
Phasing out toxic usage;
working to phase out bulk
orders of HVAC 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
3 - THE I AND
WHO CAN SC3
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
of school
personnel to perform an
SC3 task, don't
to out to a
or
vendor
Exhibit 2-3: SC3 Staffing Plan (Example)
SC3
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. Advise person or department in charge of
purchasing of alternative chemicals and
reduced quantities of toxic chemicals to
purchase.
do we 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.
can do
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
Chemical supplier
representative(s)
Chemical expert
(if nobody is available
internally to do this)
Fanner familiar with
chemicals and ideally,
curriculum planning
Fanner 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
4 - AND TO
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. Be sure to allow for 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)
SC3
Actiwity
to or the
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 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 maybe
safer, but some are substantially
more expensive.
Work with staff in each department to alter
curriculum and usage patterns to lower costs.
Enlist the Program Champion to back budget
requests.
v. Advise person or department in charge of
purchasing of 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.
5 - THE TO
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.
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Chapter 2 - Decide What Your SC3 Program Will Look Like
Exhibit 2-5: SC3 Labor Cost Estimate (Example)
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 of 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.
6 - OF FOR THE SC3
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 options 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 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/grants/index.htm) for more information regarding
matching funds from state programs.
The Fort Worth School
AND Some SC3 programs require that in that
schools contribute to the costs of chemical removal, training, or other EPA *as a for
activities. A school's financial contribution into its own program validates board to $55 ooo to
., ., . . ... , . . . \/ , , 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 sea
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.
AND 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 need to 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.
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/
2-10
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Chapter 2 - Decide What Your SC3 Program Will Look Like
7 - INTO
Another source of technical expertise and in-kind support, in addition to the
funding aspect mentioned in Activity 6, is to approach and engage your partners,
with whom you can establish a lasting and beneficial relationship. Review the list
of potential partners you generated in Chapter 1 and identified as appropriate to
specific SC3 activities (see Exhibit 2-3). Reach out to them to gauge interest and
get them on board. You may wish to take any one or a combination of the
following actions to accomplish this:
r Identify the person who can make or influence decisions to support your
school and set up a one-on-one conversation;
/ Arrange for a meeting with an appropriate organization; or
r Pull together a number of potential partners for a school-sponsored meeting.
Cultivating an appropriate mix
of who are
dedicated to offering long-term
and
will help
a robust SC3
program.
do I to the
Partners in your area should be approached with the notion that, as taxpayers and parents, they not only
have valuable expertise, they want a safe learning environment for children. The EPA SC3 Team, EPA
Regional offices, as well your state, may help coordinate potential partners in your area to provide support
for your SC3 program. To help you get started, here are some things you can do:
r Explain the problem and how they can be part of the solution;
^ Provide potential partners with program details and specify where you see them being able to
contribute. Be flexible as they may have some good ideas you haven't thought of;
f Gauge the level of interest and determine the resources that partners are willing to contribute
to the program; and
f Choose a range of partners who will remain active and provide assistance throughout the life
of your SC3 program.
Tip: Be Prepared with Information when Reaching out to Potential Partners
It would be beneficial to bring handouts or other documents (such as completed status worksheets)
with relevant chemical information, local statistics, photos of what you are trying to prevent or manage,
contact information, and even a partnership agreement to any meeting held with potential partners. Being up
front about any and all issues can provide a potential partner with a clearer picture of the situation for which
they may be inclined to assist.
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Chapter 2 - Decide What Your SC3 Program Will Look Like
Developing incentives for partners to come on board can help
get a partnership started. One possible incentive for some
potential partners is their desire to align themselves with a
school chemical safety program. For example, some
organizations may want to do community service to garner
positive public recognition. An SC3 program would serve that
purpose very well. They may also have a commitment to doing
this type of work through a corporate responsibility program.
Joining a federal campaign that has the backing of the US EPA
and other agencies will provide a partner with local and national
recognition (See the Additional Tools and Examples section at
the end of this chapter for a list of Charter SC3 partner
programs).
When considering potential partners,
explore entities that have existing
relationships to schools. They already
have knowledge, personnel, and other
resources for working with schools.
You are likely to find the most success
with those entities with ties to your
school, so start there!
Another useful source of information for recruiting partner organizations:
/- The SC3 Web site at EPA provides a table of information giving examples of potential roles that
partners can play in school cleanouts. To learn more about this, visit the SC3 Partners page at:
http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/partners.htm
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
8 - ANY MAY SC3
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
environment safe. To comply, you will want to investigate pertinent legal issues prior
to taking any action.
Cultivate the involvement of
partners who understand
applicable regulations related
to school chemical
management. These partners
can be invaluable sources of
legal and technical advice.
2-12
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Chapter 2 - Decide What Your SC3 Program Will Look Like
There are a variety of ways in which laws and regulations may play a role in how your SC3 program
operates. For example:
/ 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, MSDS sheets
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.
/ 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 (110):
http://www.epa.gov/region1/
Keys to Sustained Success: Use Best Practices
J
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
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
WEB SITE
www,epa,gov/sc3
2-14
-------
Chapter 2 - Decide What Your SC3 Program Will Look Like
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
r OSHA Standard for Occupational Exposure to Hazardous Chemicals in Laboratories
»- Informational booklet from OSHA (gives an overview of Chemical Hazard Communication)
r 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
Worksheet # 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
2-15
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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
IV.
v.
VI.
a.
b.
c.
d.
e.
2-16
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Chapter 2 - Decide What Your SC3 Program Will Look Like
Worksheet 2-2: SC3 Progress Report
Goal:
a.
b.
c.
d.
e.
Baseline
Year
After
After
Second
Year
as of _jL£^.
2-17
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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.
do we to
accomplish?
can
In-house
External
2-18
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Chapter 2 - Decide What Your SC3 Program Will Look Like
Worksheet 2-4: Identifying Potential Obstacles and Solutions
IV.
v.
to or the
2-19
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Chapter 2 - Decide What Your SC3 Program Will Look Like
Worksheet 2-5: SC3 Labor Cost Estimate
Goal:
2-20
-------
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.
1 - AND AN WITH AN
OR
Creating a program message is important to publicizing your SC3 program and gaining the necessary
support for long-term success.
Communication and publicity are critical to SC3 program success. 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.
3-1
-------
Chapter 3 - Publicize your SC3 Program
do 1 an
9 »,/
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 "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
and maintain
interest. Examples of program names
and slogans include:
"Rehab the Lab;"
"Clean Program;"
"Healthy Schools;"
"Safer Schools Initiative;"
"No 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 quickly and
effectively to
containers can be
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 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:
r Relevant to the audience receiving it;
/- Credible;
^ Concise and memorable;
r Clear and non-technical; and
r Focused and compelling.
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Chapter 3 - Publicize your SC3 Program
2 -
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.
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)
Administrators
Potential Industry
Partners
Teachers & Staff
Students
Parents
Local Business
SC3
Purchasing
X
X
X
X
X
X
X
X
X
X
X
Use
X
X
X
X
X
Disposal
X
X
X
X
X
X
"Hot"
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
3 - USE TO
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 widely read newsletter or heavily attended meeting (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 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
and forums a
and time and
money. It also scheduling
difficulties and school
to without
i/ith their 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.mwatodav.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)
Continuing Education/Teacher and Facilities Personnel Training
Creates 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 for PTA 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 setup
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
i:. ^ '': and to the
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 touch to recruit a partner for their financial 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.
The main message here is that 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.
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Chapter 3 - Publicize your SC3 Program
4 - THE THE OF TO AND
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.
It has been said, "timing is everything." Most schools have a lot of ongoing 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:
r 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.qov/pinkbook/paqe7
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Chapter 3 - Publicize your SC3 Program
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
CLEANOUT
WEB SITE
www.epa.gov/sc3
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Chapter 3 - Publicize your SC3 Program
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
f Stage 3 of NCI's Making Health Communication Programs Work
EPA's Pay As You Throw Program:
f http://www.epa.gov/pavt/top5.htm
," http://www.epa.gov/payt/pdf/other.pdf
Worksheet # Title
3-1 SC3 Program Components of Interest to Target Audiences
3-2 Methods of Communication and Publicity for your Program Message
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Chapter 3 - Publicize your SC3 Program
Worksheet 3-1 : SC3 Program Components of Interest to Target Audiences
Administrators
Potential Industry
Partners
Teachers & Staff
Students
Parents
Community
Local Business
Use
Disposal
"Hot
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Chapter 3 - Publicize your SC3 Program
Worksheet 3-2: Methods of Communication and Publicity for your Program Message
Pros
Method:
Method:
Method:
Method:
Method:
3-11
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r********************^^
I Chapter 3 - Publicize your SC3 Program
3-12
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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 still want to refer to Chapter 2 to make sure that you have covered all the bases (e.g.,
assigning and scheduling tasks, obtaining necessary budget and assistance from program partners).
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:
r 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:
LEADERSHIP & RESOURCES | CHEMICAL INVENTORY
| STOWAGE & HANDLING CHEMICAL CLEANOUT & DISPOSAL ' PUB-CHASING
POLLUTION PREVENTION
COMMUNICATION & TRAINING
SPILL RESPONSE
These chemical management themes are commonly found in successful SC3 programs, so we encourage
you to consider them if have not already done so.
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Chapter 4 - Put Your SC3 Program Into Action
do I put my SC3 into
!i ,/ y sjp
OK. You've done the preparation work discussed above. You've talked to a lot of people; checked your
school for any issues that needed to be addressed immediately; created a detailed action plan with
milestones and performance measures; identified a champion that is working to communicate your
message loud and clear; and worked to build a team that is ready to go. So what's next? Now it's time to
put all of that hard preparatory work into action.
As you go through this chapter, you will find a list of three (3) activities and two (2) projects that will help
you to successfully carry out your SC3 program; they fall into two distinct categories: the first three are
program management activities that continue the development of you r SC3 program, while the last two are
projects to be completed within your program. We plan to fully develop and add more activities and
projects to this Chapter in the future. You may have questions about this chapter that you would like to
discuss, especially for those activities that are not completely developed. Please look on the SC3 Web site
under "Where you live" for the appropriate contact for your state that can help you by discussing things
further. The SC3 Web site is an excellent source of additional information, as are the resources listed at
the end of this document. Here is a list that will enable you and your team to get your SC3 program off the
ground:
Activity # Description
Program Management
1. Begin to put your SC3 program into action;
2. Establish and modify existing SC3 policies and procedures; and
3. Train appropriate personnel on responsible chemical management.
Project #
Special Chemical Management Projects
1. Perform an inventory of all chemicals and chemical products; and
2. Secure a cleanout professional.
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Chapter 4 - Put Your SC3 Program Into Action
1 - TO PUT SC3 INTO
Put your SC3 program into action by:
Determining which activity or activities to tackle first;
Confirming that you have the necessary resources to carry out the activity or activities;
Developing a "chemical management plan" (discussed in Activity 2 of this chapter);
Assigning tasks to your SC3 Team and program partners and setting deadlines for performing the
tasks;
Tracking progress; and,
Beginning data collection.
I Tip: Use Software to Track SC3 Activities
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. Be sure to visit the
Healthy SEAT Web site at http://www.epa.gov/schools1/healthvseat/index.html
2 - mo SO AMD
As you, your team, and your partners carry out the different aspects of your SC3 program, you may find
that you need to modify existing policies and procedures for your school. Unfortunately, policies are often
designed for accident response rather than accident prevention, and SCS's goal is to prevent accidents in
the first place. You may also find that you need to identify and establish additional policies and procedures
to achieve your SC3 goals. In doing so, you will form the foundation of a chemical management plan. A
chemical management plan is a written document outlining a school or district's chemical management
policies and procedures that can include guidelines on:
Purchasing;
Curriculum;
Conducting inventories;
Chemical hygiene in areas where chemicals are used1;
Hazard communication and response;
Labeling;
Storage; and
Disposal.
1 See OSHA's Laboratory Standard for a Chemical Hygiene Plan (CHP) for more information:
http://www.osha.gov/pls/oshaweb/owadisp.show document?p table=standards&p id=10106
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Chapter 4 - Put Your SC3 Program Into Action
Developing a chemical management plan is important, so that the components you established in your SC3
program can be effectively understood and replicated. As you and your team set out to develop a chemical
management plan, you should not only involve partners, but also look at plans created and used by other
schools and districts.
For helpful administrative guidance, see the Chemical Management Resource Guide for School
Administrators from EPA's Office of Pollution Prevention and Toxics.
3 - ON
It will be important to initially train teachers, facilities personnel, and other staff on procedures within your
SC3 program and keep them up-to-date for all important aspects of chemical management. New teachers
and staff will also need to be trained as they enter your school or district. You should consider periodically
holding refresher courses, to not only get new staff up to speed on responsible chemical management, but
to keep it on the minds of everyone at the school. (See Chapter 5)
Be sure to visit the Resources page at the SC3 Web site, where you will find sample training presentations,
such as:
- "Planning for Environmental Health and Safety Issues in Schools - Do you know where your
chemicals are?" (Developed as part of the Emergency Management Institute's course E362 - Multi-
Hazard Emergency Planning for Schools Train-the-Trainer (TTT)).
.- Chemical Safe Schools in Rhode Island (PDF) (11 pp, 32 K) | PowerPoint Version (56 K) highlights
Safe Schools in Rhode Island; discusses utilizing schools resources, such as the chemical hygiene
officer and business officers; and mentions accessing outside resources, such as local health and
safety officers and fire marshals.
- Improving Chemical Management in Maine Schools (PDF) (22 pp, 1.5 MB) | PowerPoint Version
(1.6 MB) addresses where chemicals can be found, origin of the chemical program, costs
regarding chemical management, and the importance of business managers.
- No More" Methyl Something": Improving Management of Curriculum Chemicals in Schools (PDF)
(42 pp, 739 K) | PowerPoint Version (3.4 MB) discusses where chemicals are found, the risks of
chemicals, chemical storage practices, actions that can be taken to reduce chemical risks, and
chemical resources.
Planning for Environmental Health and Safety Issues in Schools (PDF) (40 pp, 1 MB) | PowerPoint
Version (40 pp, 5.5 MB) provides basic information about safe chemical management, examples of
mismanaged and inappropriate chemicals in schools, and actions schools can take to address the
problem.
Another helpful document in planning training activities is OSHA's Model Training Program for Hazard
Communication.
More information about these activities will be added to this workbook at a later date.
4-4
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Chapter 4 - Put Your SC3 Program Into Action
This section presents two detailed projects that are common among successful chemical management
programs. At the very least, we highly recommend that you develop a chemical inventory.
1 - AN OF ALL AND 2
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 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);
r 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).
2 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.
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Chapter 4 - Put Your SC3 Program Into Action
Establishing an accurate inventory is very 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:
r Number and type (e.g., high school, vocational) of schools;
Location of schools and proximity to each other;
Locations of chemicals (within school facilities);
r 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;
r 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:
In a container that is in poor condition (e.g., corroded, has crystals growing around the cap);
r 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,
f Unsecured.
You should also 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
completeit 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 very important to inform them.
If you are new to the school and/or a recent inventory has not been conducted, you need to be especially
cautious. Serious injury can result from touching or moving chemicals that have become shock sensitive or
pressurized. If any chemical container is unmarked, bulging, leaking, rusted, cracked; or has a degraded
top; or contains a liquid above a solid; or crystals in a liquid; we recommend that it not be moved unless
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Chapter 4 - Put Your SC3 Program Into Action
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 remember 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. You should 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 be sure to pronounce the names correctly and confirm that they 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
After completing your comprehensive inventory, you should meet with your team to discuss potential next
steps for your SC3 program to take. In Exhibit 4-1, 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. In the Additional Tools and Examples section at the end of this Chapter, we provide a blank
version of Exhibit 4-1 [Worksheet 4-1] that you and your team can use in evaluating your chemical
management situation after conducting an inventory.
Exhibit 4-1: Post-Inventory Evaluation of your Chemical Management Situation (Example)
How many chemical containers are:
1) Unlabeled?
2) In poor condition?
3) Expired?
4) Not essential to the school's
function?
5) Unsecured?
1) 22
2) 15
3) 10
4) 30
5) 145
Properly dispose of any
mismanaged chemicals in
compliance with applicable
regulations.
How much of the following chemical
do I use every year?
>" Chemical A
f Chemical B
f Chemical C
Chemical A: 1 gallon
Chemical B: 50 ounces
Chemical C: 100 ounces
See next step.
Given the amounts above, how many
years worth of chemical do I currently
have?
Chemical A: 3 years
Chemical B: 200 years
Chemical C: 27 years
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 to Project 2: Secure a Chemical C/eanout Professional).
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Chapter 4 - Put Your SC3 Program Into Action
2 - A
If your chemical inventory identified chemicals in your school and your SC3
Team determined they presented 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.3
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)
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.
3 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
A - AND A LIST OF TO
(A 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 be as detailed and as comprehensive as possible. You can use lf , .... ,.
... .. . ,' .. . . ri- j r 11 j i i i If you are not qualified to
this supporting information in securing a qualified professional to conduct a cleanout do an initia| evaluation of
(See Tip: What do I include in the disposal list?). Completing this disposal list will help your chemicals, ask a
you to: technical expert from
your partner team.
r Identify chemical management problems or cleanout issues that need
immediate attention or action (e.g., situations that might pose health and safety concerns to
students and staff, such as potential explosions or fires);
r 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
f 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?^
Sub-Activity B) to give bidders a clearer picture 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, provide as much as you can):
I* Types of chemicals including chemical name and/or hazard classification;
r Chemical Abstract Service (CAS) registry number;
/ Chemical concentration;
I* Chemical expiration date;
I* Type and condition of storage container (e.g., glass bottle, broken seal);
>- Amount of each chemical (e.g., liters, milliliters);
r Location of chemicals in school and/or location within classroom or storage area; and
r Chemicals requiring specialized handling or disposal techniques (e.g., radioactive, explosive,
shock sensitive, unknown).
This information included in Exhibit 4-2 is provided as an example disposal list. Worksheet 4-2 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 4-2: 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
B - A. TO IN THE AMD
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:
f Identify additional chemicals to add to your disposal list;
* Identify chemicals that can be safely disposed without a chemical cleanout professional4;
r Prepare chemicals for disposal;
f Develop requests for proposals for cleanout service providers;
r 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 clear 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.
4 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 without a
contractor's professional removal.
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Chapter 4 - Put Your SC3 Program Into Action
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 4-6 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 4-6 in the Additional Tools and Examples section at the end of this chapter is an actual RFP 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
J
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
do I
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.
You in
Issuing an RFP. Consider
for
advertising, collecting vendor
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.
. -,. led a
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 4-3 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 meets 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 4-3: 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 provided 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?
r Will you be using subcontractors for any of your services?
/ Is your company bonded, licensed, insured?
," Does your company have copies of necessary permits?
r 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
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 4-4 is
an example of a price quote that a qualified professional may send in response to your
RFP; it contains some typical costs associated with chemical deanout and disposal.
Exhibit 4-4: 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
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 4-5 provides examples of some real world cost saving techniques that you can consider for your
SC3 program.
Exhibit 4-5: 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.
of
Sawings
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.
The Tennessee Department of Environment and
Conservation used an existing contract to do HHW
collection and facilitate simultaneously 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 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 4-5: 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.5
Rochester City School District, NY 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.
C - FOR AND
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 or other constraints, you may
not be to remove a|l of the
chemicals at one from one or more
schools. Any amount of potentially
chemicals.that can be removed
from a school to prevent
they
While you may not personally be involved in cleanout activities, someone knowledgeable about the
conditions and locations of chemicals in your school should be available to answer questions and facilitate
communication to help guarantee cleanout success.
5 Learn more about the Illinois Emergency Management Agency's Orphan Source Recovery Program-High
School Initiative: http://www.state.il.us/iema/publications/pdf/RadiationJn_Schools.pdf
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Chapter 4 - Put Your SC3 Program Into Action
D - TO THE FOR
Congratulations on completing the chemical cleanout of your school. You should 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:
r You should keep your policies and procedures current by periodically evaluating your SC3 program
(Activity 2: Keep Chemical Management Policies and Procedures Up-to-date}, and
r See the Textbox "Key to Sustained Success: Maintaining Chemical Inventories''on page 5-1.
We plan to fully develop and add more activities and projects to this Chapter in the future. You may have
questions about this chapter that you would like to discuss, especially for those activities that are not
completely developed. Please look on the SC3 Web site under "Where you live" for the appropriate contact
for your state that can help you by discussing things further. The SC3 Web site is an excellent source of
additional information, as are the resources listed at the end of this document.
As you went through this chapter, you worked through a list of five (5) 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. Mobilize your SC3 program;
2. Establish and modify existing SC3 policies and procedures; and
3. Train appropriate personnel on responsible chemical management.
Project #
Special Chemical Management Projects
1. Perform an inventory of all chemicals and chemical products; and
2. Secure a cleanout professional.
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.
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Chapter 4 - Put Your SC3 Program Into Action
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
« Chemical/Disposal Inventories
Exhibit #
4-3
4-4
4-5
4-6
Worksheet #
4-1
4-2
Title
Vendor Qualifications Checklist
Sample Price Quote
Examples of Cost Saving Techniques
Sample RFP 6
Post-Inventory Evaluation of your Chemical Management Situation
Chemical Disposal List
6 This detailed and complete example of an RFP was used to solicit vendor bids on a school chemical
cleanout and disposal project. This sample RFP is for illustration purposes only. The applicable authorities
within your organization should approve the use of any and all content in your RFP.
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Chapter 4 - Put Your SC3 Program Into Action
Exhibit 4-3: 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 provided 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 4-4: 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
Exhibit 4-5: 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.
of
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
The Tennessee Department of Environment and
Conservation used an existing contract to do HHW
collection and facilitate simultaneously 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 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.
Rochester City School District, NY 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.
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Chapter 4 - Put Your SC3 Program Into Action
Exhibit 4-6: Sample RFP
ABC Regional Education Unit
123 Main St.
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 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 qualification 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,
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Chapter 4 - Put Your SC3 Program Into Action
whether handled by the contractor or its subcontractor. The ABC Regional
Education Unit shall be named as additional insured for all policies.
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.
* Truck Drivers - All drivers must have the
appropriate training required in 29 CFR 177 and
383. These are DOT standards for Hazardous
Material Transporters.
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.
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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: $_
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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"):
4-28
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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.
4-29
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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.
4-30
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Chapter 4 - Put Your SC3 Program Into Action
Worksheet 4-1: Post-Inventory Evaluation of your Chemical Management Situation
How many chemical containers are:
1)
2)
3)
4)
5)
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?
4-31
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Chapter 4 - Put Your SC3 Program Into Action
Worksheet 4-2: Chemical Disposal List
Chemical
Name
CAS
Number
Concentration
Exp.
Date
Amt. & Size of
Container for
Disposal
Type of
Container
Amount
(est.)
Storage Location
4-32
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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 implement the responsible chemical management policies and procedures and that you
regularly evaluate your program to see that you are achieving your goals. 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. Work with your partners for ongoing technical assistance; 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
J
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.
Also 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
1 - AND AND
After initially putting your program into place, you should be prepared to evaluate 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 methods and approaches to issues have been in putting your
program in place;
* 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. Be sure to
visit the Healthy SEAT Web site at http://www.epa.gov/schools1/healthYseat/index.html
In addition to evaluating the progress of your program, you also should 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 worksheets from Chapter 2:
.> Worksheet 2-1: SC3 Activities and Performance Measures to Reach Program Goals,
r Worksheet 2-2: SC3 Progress Report, and
/- Worksheet 2-4: Identifying Potential Obstacles and Solutions.
You should also review your SC3 program to see if there are new goals to be added. Especially if you
initially chose to focus on only one or two aspects of the chemical lifecycle, such as Purchasing and
Storage, you should return to your original evaluation in 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 include additional chemical management issues. It is possible,
and highly likely that as your program matures, your initial set of goals will be achieved and new ones
5-2
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Chapter 5 - Sustain Your SC3 Program
should be set. If you are adding new goals, then you can use Worksheets 2-3: SC3 Staffing Plan and
2-5: SC3 Labor Cost Estimated prepare budget requests, and assign new tasks to team members.
Also remember that:
^ Other existing goals may need to be refined with new performance measures; and
r Many aspects of your program will be subject to changes of one type or another.
Your experiences should give you greater knowledge and familiarity of the proper handling, use, and
disposal of chemicals to create a safer environment within the school. This, in turn, should help you to
shape and refine your program goals to create a program that can sustain success for the long-term.
2 - AND
To determine that chemicals in your school or district are being handled in the best possible
way, you and your team should regularly evaluate your chemical management policies
and procedures. Staying current with best procedures and methods should help avoid
potential risks and cleanouts in the future. In addition, 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.
ow can
From your core SC3 team,
you should assign one or
two to take the lead
on reviewing and updating
policies and procedures for
school chemical
management.
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
°^ ^'s Workbook provides a worksheet for evaluating SC3 program needs
(Worksheet 1-1: Evaluating Your School's Chemical Management Situation,
Policies, and Procedures}, and you may want to periodically complete this self-
evaluation activity to improve your program and catch problems before they pose
health and safety risks. In addition, 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. Check the
SC3 Web site periodically for new tools and information. You may also want to
check with your state's environmental agency to find out if there are new or
revised regulations that would affect your chemical management program because
chemical vendors may be unaware of state requirements. Your school's chemical vendors are usually
up-to-date on national regulations impacting their products. 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. You should schedule these
evaluation activities regularly - make them a part of the way you do business.
Whenever you SC3
policies and procedures
ask: "who needs to know
about what's changed in
how we go about school
chemical management?"
Then let know!
5-3
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Chapter 5 - Sustain Your SC3 Program
3 -
To sustain responsible chemical management practices, you should keep people within your school or
district aware of SC3 program components and how they fill a role in maintaining a healthy and safe
learning environment.
i qo in
ical
In launching your school's SC3 program, you developed instructional materials and conducted initial
training of those involved in chemical management. Now you should periodically update the training
program, as well as train new teachers and facilities personnel, to reflect new approaches and
regulatory requirements. Even if they have already received training elsewhere, they should learn
about the specific requirements in your district.
For those who have already been trained, you should conduct "refresher" training on the
most critical topics. Refresher training is most appropriate for teachers and facilities
personnel who already went through the formal training conducted when your school
launched its SC3 program. You should provide practical information that staff can
,«, , .. . . . easily incorporate into their daily activities, and look back at Chapter 4 for
Informal training can be ' ... , ,. . . . . -,-.. . ...
very Look for guidance on setting up successful training mechanisms. This may be a good time
to for employees to reflect on how the program is working for them and to suggest
onto forums improvements.
or convey reminders
and are
actually using, storing and
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 and ensures 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.
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.
Under safety, training students primarily involves setting ground rules at the beginning of a course
regarding the proper handling of chemicals. This can include topics such as:
r Awareness of hygiene, handling, and emergency procedures;
f Proper use of personal protective equipment;
/- Recognizing common safety symbols;
r Understanding materials safety data sheets; and
,« How to respond to a chemical accident.
It is also important to involve students in the concepts of the overall chemical life cycle management
and pollution prevention. Some examples of topics to discuss with students are:
r 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
f 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 in school
operations. Exhibit 5-1 lays out what facilities personnel, teachers, and students should know.
5-5
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Chapter 5 - Sustain Your SC3 Program
Exhibit 5-1: Training Topics Checklist
SO
Storage &
Inventory
Use & Disposal
to
How to keep storage areas secure
How chemicals are properly stored
How to update inventory database
Where to locate Material Safety Data Sheets and any hazard
information for every chemical
Location and proper use of protective equipment
Safe handling procedures
Safe cleanup practices
Proper disposal methods for all chemicals in use
Micro-scale and green chemistry curriculum options
What to do in the case of an emergency or spill
&
Staff
X
X
X
X
X
X
X
X
X
X
Students
X
X
X
X
X
X
X
X
4 - AND TO AND HIGH
Communicating SC3 accomplishments is a great way to bolster commitment to proper 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.
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:
r Yearly progress reports;
r Performance measures;
r Expenditures and other budgetary data; and
r Inventories of equipment and supplies.
You should 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.
5-6
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Chapter 5 - Sustain Your SC3 Program
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.
£\J < In addition, you should continue to cultivate good relationships with current partners to
I '- 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
An effective way to capabilities and developed new needs, it may be necessary to find and involve new
sustain senior partners to provide support (e.g., a local university may be helpful to your school's
management backing is effo|ts fo deye| g new chemistry currjcu|um). you should refer back to Chapter 2
10 give inem a cnance 10 . . .
speak with the media for guidance on approaching potential partners and acquiring their support.
during publicity events.
5 - FOR ; 1
As we've mentioned before, it is unlikely that your school will have all the expertise on hand or even the
time to perform all SC3 activities and keep the program up-to-date. From time to time, you should
bring in experts and outside help to provide technical support to your SC3 program.
For ongoing assistance with your SC3 program, you can look to partners and vendors to provide the
following kinds of technical 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 micro-scale or green curricula (see Chapter 4);
r Providing information about new developments in responsible chemical management; and
,' Conducting training and refresher workshops.
5-7
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Chapter 5 - Sustain Your SC3 Program
Key to Sustained Success: Ongoing Technical 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:
r Methods of teaching with non-toxic and less hazardous materials in science classes;
r Safe storage practices for hazardous materials; and
r Procedures for disposing of hazardous materials.
6 - AND AND TO FOR
FOR SC3
To ensure that the different aspects of your program have the support they need, you and your team
should determine the funding and labor costs necessary to maintain your SC3 program on a yearly
basis.
cine! do I to
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 minimal
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:
r Re-evaluate and update chemical management policies and procedures;
f Further develop and evaluate the effectiveness of training curricula;
^ Update and evaluate the functioning of the inventory system;
r Properly dispose chemicals that are no longer needed.
5-8
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Chapter 5 - Sustain Your SC3 Program
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:
r The Local Hazardous Waste Program in King County's Rehab the Lab program in King
County, Washington, which 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.
5-9
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Chapter 5 - Sustain Your SC3 Program
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. Work with your partners for ongoing technical assistance; and
6. Estimate staffing and funding requirements and continue to look for new funding sources
for ongoing SC3 activities.
VISIT THE SCHOOLS
CLEANOUT CAMPAIGN
WEB SITE
www.epa.gov/sc3
5-10
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Chapter 5 - Sustain Your SC3 Program
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
'r 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)
f National Institute of Health (NIH) Mad as a Hatter Mercury Abatement Campaign
," Children's Health Protection
/- Healthy Schools for Healthy Learning
r Health and Safety Guide for K-12 Schools in Washington
>- Tribal Schools Compliance Assistance Notebook
<" EPA's Schools and Mercury Web site
f The SC3 Grant page
Developing a Chemical Management Program
General Chemical Management Program Resources:
/" CPSC and NIOSH School Chemistry Laboratory Safety Guide
/" Idaho's Department of Environmental Quality's Waste Management Educational Tools:
Chemical Roundup
r Pollution Prevention Measures for Safer School Laboratories
/ The Los Angeles Unified School District (LAUSD) Office of Environmental Health and Safety
(OEMS)
r Rehab the Lab
5-11
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Chapter 5 - Sustain Your SC3 Program
Chemical Inventory:
Montana DEQ School Labs: Evaluating School Lab Chemicals
- Florida SC3
.< 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
, National School IPM Information Source
5-12
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Chapter 5 - Sustain Your SC3 Program
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
EPA530-K-07-007
5-14
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Chapter 5 - Sustain Your SC3 Program
5-15
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