Building Successful Programs to Address
Chemical Risks in Schools:
Recommendations from an Evaluation of Selected
Schools Chemical Management Programs
FINAL
EPA530-K-07-005
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Building Successful Programs to Address Chemical Risks in Schools
Acknowledgements
This report is part of an evaluation that was primarily performed by Indtai, Inc. State, tribal and local school
chemical management program implementers, and EPA personnel in the program offices and each of the
ten EPA Regions, contributed to the preparation of the publication through survey responses, comments
and editorial review.
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Building Successful Programs to Address Chemical Risks in Schools
The Formative Evaluation -
The Foundation of this Document
In 2005, EPA commissioned an evaluation of a number
of school chemical management programs. The
information from this evaluation was used in developing
the national Schools Chemical Cleanout Campaign
(SC3). Some of the programs that were evaluated
were initiated and funded by state and local entities,
while the federal EPA funded others. This type of
evaluation tool, known as a Formative Evaluation, was
used to assess activities undertaken in these programs
to furnish information that will guide program
improvement for new and existing programs.
Specifically, the Formative Evaluation was used to gain insights into the structure, processes, operations,
stakeholders, and implementers involved in school chemical management programs.
The analyses relied on document reviews and dynamic interviews1 of responsible chemical management
program implementers at the federal, state, and local levels. Interviewees provided accounts of their
programs from creation, through implementation, to the institutionalization of sustainable, preventative
chemical management policy.
Based on these activities, critical success and barrier factors, best management practices, and
recommendations were developed. In February 2006 EPA was presented with a final report on the
Formative Evaluation, which serves as the backbone for this document. The final report has been
restructured to be more useful to our intended school audience, while maintaining the independent quality
and substance of the evaluation.
Please refer to the appendices for the detailed discussion of the methodology, summaries of the programs
that were examined, and interview questions that were part of the Formative Evaluation.
1 A "dynamic" interview process tailors the list and order of questions asked based on the role, knowledge, and experience of an
interviewee. This ensures that appropriate questions are asked as not all interviewees have knowledge of all informational
objectives associated with the project.
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Building Successful Programs to Address Chemical Risks in Schools
Table of Contents
Executive Summary E-l
Introduction 1
Overview of the Problem 2
Checklist for Building a Successful SC3 Program 4
Practical Considerations and Advice from Interviewees 9
A. Creating Successful SC3 Programs 9
B. Potential Barriers to Achieving SC3 Program Success 14
C. Ensuring Sustainability of Program Results 16
D. Using SC3 Programs to Sustain Long-Term Chemical 19
Management Success
E. Measuring Program Performance and 21
Accomplishments
Conclusion 22
Appendix 1: Evaluation Methods 25
Appendix 2: Program Summaries 27
Appendix 3: Interview Questions 31
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Building Successful Programs to Address Chemical Risks in Schools
Executive Summary
Across the country, unneeded, excessive,
or dangerously mismanaged chemicals are
often found in K-12 schools. Accidental
spills involving these chemicals:
Endanger students and staff;
Result in school days lost;
Cost millions of dollars to clean up
each year; and
Are preventable, in many
instances.
Schools need sustainable solutions for managing the
chemicals in their facilities...
* Cleaning up chemical spills is more costly
than removing chemicals from schools and
implementing preventive measures.
* Cleaning up chemical spills cost schools,
school districts, and communities millions of
dollars.
* Removal costs vary, averaging between
$2,000 and $5,000, unless there are
radioactive or explosive chemicals, which
increase the removal costs substantially.
Dangerously mismanaged chemicals
represent one of the critical environmental
health and safety issues schools must
address to improve the learning
environment for children and to provide a
healthy workplace for teachers and staff. Several widely publicized incidents involving chemicals have
resulted in school closures and costly cleanups. As a result, the states and EPA investigated the problem
and found that a large majority of middle and high schools have unneeded, excessive, or mismanaged
chemicals, potentially putting students and staff at risk.
This report:
* Describes the problem caused by unneeded, excessive, or dangerously mismanaged chemicals in
K-12 schools;
* Recommends ways to address the problem; and,
* Provides "lessons learned" from state and local chemical management programs to address
chemical mismanagement in schools.
In 2004, using various state and local programs as models, EPA launched the Schools Chemical Cleanout
Campaign (SC3). The campaign uses a variety of innovative approaches to achieve its three goals:
Remove accumulations of potentially dangerous chemicals from K-12 schools;
Prevent future accumulations through improved chemical management; and
Raise national awareness of the issue.
As mentioned earlier in this document, in 2005, EPA commissioned a Formative Evaluation to study a
number of responsible chemical management programs across the country in order to learn why some of
these programs were successful and what problems were encountered during program development and
implementation. The checklist of recommendations we present in this document is based on lessons
learned, best practices, and the informed opinions of interviewees. The recommendations are useful to
those seeking to establish new SC3 programs. They can be used to improve and increase participation in
existing responsible chemical management programs by reducing barriers, easing implementation, and
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Building Successful Programs to Address Chemical Risks in Schools
leveraging existing resources and relationships. Each of these recommendations is fully explained later in
this document. Please remember it is not necessary to tackle all items on the checklist at one time to have
a successful SC3 effort; you can improve chemical management in your school by accomplishing any of
the following actions:
13 Assess chemical management concerns to identify program objectives.
13 Develop a clear and comprehensive program message.
13 Involve community stakeholders and form partnerships.
13 Gain senior management support for SC3 programs.
13 Measure achievements and identify improvements.
13 Identify and leverage existing outreach and communication mechanisms.
13 Provide focused training to teachers, facilities, and administrative personnel.
13 Incorporate chemical management into every day classroom activities, business
practices, and budget development.
13 Obtain technical assistance to support all phases of your SC3 program.
13 Develop incentives and strategies to overcome potential program participation hurdles.
In the section of this document entitled "Practical Considerations and Advice from Interviewees," we
discuss the findings upon which these recommendations are based.
Conclusion
Approaches for developing SC3 programs must be flexible and allow for adding components in phases
when resources and conditions are right for your school. While each school has its own set of unique
circumstances, the need for responsible chemical management practices that ensure schools are safe from
chemical risks is common among all. The experiences and practical knowledge presented in this report are
intended help you prevent chemical mismanagement in schools, thereby protecting children, teachers, staff
and the environment.
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Introduction
Inappropriate and mismanaged
chemicals can be found in
several locations in a school, not
just the chemistry laboratory.
Unneeded, excessive, or dangerously mismanaged chemicals are
often found in K-12 schools across the nation, potentially putting
students and staff at risk. Thus, mismanaged chemicals
represent one of the critical environmental health and safety
issues schools must address.
The Schools Chemical Cleanout Campaign (SC3) promotes the
removal of unneeded, excessive, or dangerously mismanaged
chemicals from K-12 schools. SC3 programs also promote the
creation of policies that prevent future unnecessary accumulations of chemicals and of practices that
sustain responsible management of necessary chemicals. These programs are designed to decrease the
risk of exposure, thus improving the learning environment and reducing lost school days.
Many different types of programs exist across the
country to address this issue. In this document you will
learn about existing chemical management programs
that have been implemented to improve the learning
environment for children and to provide a healthy
workplace for teachers and staff. You will learn about
factors that contributed to the success of these
programs, barriers that had to be overcome, as well as
the major recommendations drawn from the
experiences of the program implementers themselves.
Newspaper article about a school chemical spill.
Photo courtesy of Tennessee Department of Environment
and Conservation
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Building Successful Programs to Address Chemical Risks in Schools
Overview of the Problem
When handled responsibly, chemicals are useful educational tools. They allow students to conduct
experiments in the lab, create works of art in the studio, and restore vehicles in the automotive shop.
When they are mismanaged, however, chemicals can pose risks to students and staff. Examples of
potential chemical hazards are in the table below. More information can be found on the National Institute
for Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards on the Web at:
http://www.cdc.gov/niosh/npg/.
Location
Science Labs
Vocational and Trade
Shops
Visual and performing art
studios
Custodial/Maintenance
Areas
Product Type
Acids (undiluted)
Bases (undiluted)
Solvents
Oxidizers
Compressed gases
Toxins
Solvents (used in paints, paint
thinners, adhesives, lacquers,
primers, and other products)
Cleaning supplies, detergents
Compressed gases
Fuels, transmission, and brake
fluids
Solvents (used in paints, paint
thinners, adhesives, lacquers,
primers, and other products)
Pottery clear coating glaze
Pigments for paints and coatings
Acids for etching
Dry clay for ceramics and jewelry
Cleaning supplies/detergents
Hazardous Ingredient
Examples
hydrochloric acid
nitric acid
sodium hydroxide
methanol
methylene chloride
lead nitrate
oxygen
cyanides
chro mates
mercury salts
petroleum naphtha
turpentine
phosphoric acid
sodium silicate
acetylene
nitrogen
gasoline
mineral spirits
lead
cadmium
manganese
chromium
nitric acid
hydrochloric acid
silica
butoxy ethanol
trisodium phosphate
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Swimming Pools
Kitchens/Cafeterias
Nurses' Offices
Photography Laboratories
School Grounds/ Athletic
Fields
Administrative Offices
Drain cleaners (alkaline)
Drain cleaners (acidic)
Pesticides (including
disinfectants/sterilizers)
Paint thinners
Solvents (used in paints, paint
thinners, adhesives, lacquers,
primers, and other products)
Water treatment chemicals
Pesticides (including
disinfectants/sterilizers)
Cleaning supplies/detergents
Refrigerants
Medical equipment
Intensifiers/reducers
Developers
Stop baths and fixer
Pesticides
Fertilizers
Correction fluid
Solvents (used in paints, paint
thinners, adhesives, lacquers,
primers, and other products)
Printer/copier toners
potassium hydroxide
sulfuric acid
permethrin
sodium hypochlorite
toluene
xylene
"chlorine tablets"
sodium hypochlorite
ammonium hydroxide
freon
ammonia
mercury (thermometers and
blood pressure manometers)
potassium dichromate
hydrochloric acid
hydroquinone
acetic acid
2, 4-D
ammonium nitrate
ethylene glycol
trichloroethane
methyl ethyl ketone
petroleum distillates
carbon black
Schools are primarily managed at the local level, where they receive funding, operate, and set priorities.
Each school district has its own priorities, standard operating procedures, and challenges. Therefore,
schools and school districts must balance competing priorities and budget constraints. Environmental
health and safety issuessuch as responsible chemical managementare one of the many components
that must be considered to provide children with a safe environment that promotes education and
development. For more information on healthy school environments, please go to
http://www.epa.gov/schools.
The next chapter presents a checklist of recommendations for building a successful program. This
checklist is based on the section of this document entitled "Practical Considerations and Advice from
Interviewees," which will provide a wealth of information you can use in developing or improving your SC3
program.
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Building Successful Programs to Address Chemical Risks in Schools
Checklist for Building a Successful SC3 Program
This section provides a checklist of recommendations for building a successful SC3 program, which will
help you make responsible chemical management in your school or school district. You can design and
implement your SC3 program one item at a time, as resources become available. Accomplishing even one
of the recommendations likely will improve chemical management in your school.
Assess chemical management concerns to identify
program objectives.
Assessing how chemicals are managed in your school will help you identify the necessary components of a
responsible chemical management program and help you plan and budget accordingly. This exercise can
also be a good tool to identify areas that will require expertise from potential program partners at the
federal, state, tribal, or local community levels. Typical scoping questions might include:
How many and what type of schools (e.g., high school, vocational, private) are involved?
How many children are impacted?
How many faculty and facility staff persons are impacted?
Have there been chemical emergencies at any of the schools?
What chemicals were involved and in what amount?
What chemicals are currently in the school, in what location, condition and quantity, and for what
purpose?
Are there any "high risk" situations requiring immediate attention?
Are there any existing regulations that govern chemical management and safety?
Answering these questions will help you determine what steps you need to take and how much it will cost
to address your chemical management problems. Initially, SC3 programs may not have adequate funds to
tackle all of the schools' chemical management needs but the school may be able to carve out an aspect of
the program with which to start. At this stage, it is important that, at a minimum, administrators consider
chemical management among the top priorities. As the program develops and partnerships are established,
funds or services may become available to expand the program.
Develop a clear and comprehensive program message.
Developing a clear message should be one of the first steps in developing an SC3 program. It will help you
set the tone for the program, develop measurable goals and objectives, and ensure that all participants are
on the same page.
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Building Successful Programs to Address Chemical Risks in Schools
Involve community stakeholders and form partnerships.
Having an appropriate mix of partners who can offer technical expertise and financial resources throughout
the SC3 program can help create a robust program that offers a variety of benefits to schools. State, tribal,
and local agencies often have a direct impact on schools. Non-governmental bodies also may influence
school-level decisions including school and teacher accreditation organizations; associations representing
teachers, school administrators, facilities personnel, and school purchasing officials; parent/teacher
organizations; local emergency planning committees; unions; non-profit organizations; and community
leaders. Other partners that may interact with schools are manufacturers; chemical suppliers; insurance
companies; colleges and universities; waste management and environmental services firms; local
businesses; and, state and federal agencies. These organizations can contribute support for SC3 programs
and help champion and promote the cause to attract additional partners.
Gain senior management support for SC3 programs.
Gaining senior management support raises the level of priority for SC3 programs and mitigates resistance
to change. This high-level support can also be useful as you seek funding and dedicated staff for SC3
activities. Informing senior management of the program's short- and long-term goals, partner roles and
responsibilities, and achievements are just a few of the approaches to increasing management support.
Measure achievements and identify improvements.
SC3 programs should set performance goals or targets, and develop performance metrics for which data
can be cost-effectively collected. All programs need a way to measure accomplishments and improvements
and identify program deficiencies and corrective measures. Metrics can also be a useful tool for schools in
designing effective chemical management practices; meeting larger school or community environmental
goals; budgeting; and supporting funding decisions. Typical SC3 metrics may include: quantity of
chemicals removed, number of personnel trained, and number of student and staff affected. It is also
important to gauge the effectiveness of program components aimed at changing behavior, such as
assessing whether chemical management training improves teachers' knowledge and performance of
chemical safety in the classroom.
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Building Successful Programs to Address Chemical Risks in Schools
Identify and leverage existing outreach and
communications mechanisms.
A wealth of outreach and communication
avenues already exist that can be used to
generate interest in SC3 programs.
Piggybacking on existing events for teachers,
administrators, and facility personnel ensures a
captive audience and leverages limited financial
resources. It also eases scheduling difficulties
and allows school personnel to participate
without interfering with their personal time and
resources.
Outreach and communication
opportunities...
Teacher in-service days and staff
meetings;
College-level seminars;
Industry conferences;
Existing training opportunities for
teachers, facilities/maintenance, and
administrative staff;
Newsletters and relevant
publications;
Online resources such as listservs;
and
Partner mailing or distribution lists.
Provide focused training to teachers, facilities, and
administrative personnel.
In the majority of cases, adequate training about responsible chemical management is not part of the
college curriculum for teachers. Therefore, it is important to provide practical information so that teachers
can help implement responsible chemical management activities such as taking inventory of chemicals,
assisting with chemical cleanouts, and instituting responsible chemical management practices. Offering
training opportunities at little or no cost to teachers acts as an incentive for participation. Various entities,
such as technical experts or community partners, could share the responsibility of developing or providing
training. Program implementers should also remember that facilities personnel at the school district or
individual school level are often knowledgeable about chemical handling and storage, regulations, and
ordering practices. Whenever possible, facilities personnel should be engaged to provide assistance with
developing, understanding, and implementing chemical management policies and practices.
Training will allow relevant school staff to:
Prepare chemical inventories;
Arrange for cleanouts;
Identify hazards; and
Institute responsible chemical management practices.
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Incorporate responsible chemical management into
classroom activities, business practices, and budget
development.
To prevent the need for future cleanouts, it is
essential that responsible chemical
management practices be incorporated into a
school's approach to providing a safe learning
environment. Disposing of unneeded,
outdated, and excessive chemicals is critical
to creating safe schools and an important step
in achieving proper chemical management. It
is essential that schools develop and
implement responsible chemical management
and waste minimization practices to decrease
the risk of accidents and exposures and the
need for cleaning out future chemical
accumulations.
Examples of responsible chemical
management practices...
Purchasing policies;
Chemical inventory management;
Small scale chemistry;
Disposal;
Chemical inventory
control/procedures;
Proper chemical storage;
Routine training of relevant school
personnel about chemical
management; and
Budgeting to support these activities.
Obtain technical assistance to support all phases of your
SC3 program.
Technical resources might include...
* A website with critical SC3
information or web links;
* Guidance or "how to" materials;
* A technical assistance center or
hotline; or
* SC3 program partners.
Looking for opportunities to obtain easily accessible
technical assistance resources that provide help and
advice to program implementers in the near term and
throughout the chemical management lifecycle is an
important part of an SC3 program. SC3 program
implementers can consider using available technical
resources that have been developed by other SC3
programs. If that is not feasible, SC3 program
implementers should develop technical assistance
resources to meet your school's needs.
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Develop incentives and strategies to overcome potential
program participation hurdles.
The use of incentives is a powerful tool. Discounts on insurance rates, public acknowledgement of SC3
program success, and other forms of recognition can motivate a school and other partners to participate in
an SC3 program. Realistically, however, your SC3 program may encounter hurdles from a variety of
sources. Being aware of potential hurdles can help you strategize how to overcome them when they arise.
Putting Recommendations into Practice.
Considering the above recommendations as you develop, implement, or improve your SC3 program will
help to create a robust, self-sustaining program with measurable results. The following section of this
report will provide you with practical considerations and advice from program implementers to support
putting the recommendations into practice.
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Practical Considerations and Advice from Interviews
The checklist of recommendations in the previous section was developed from the experiences of those
who have designed and implemented chemical management programs at the state and local school and
district level.2 In this section you will find practical considerations and advice from first-hand experiences of
SC3 program implementers across the country. What follows are real examples from program
implementers of critical success factors; barriers to successful programs; tips to ensure results; and,
methods to sustain SC3 programs that achieve long-term responsible chemical management.
A. Creating Successful SC3 Programs
Many factors are critical to the success of SC3 programs.
The "Message" Is Important
Develop a clear message. To catch or hold the school's attention, develop a clear message about
chemical cleanout activities and responsible chemical management practices. Make sure it is
concise and easily understood. However, it is important to remember that while a state, tribal, or
local SC3 program may have a clear message, if school administrators do not believe their school
has a chemical management problem or that it is a priority, then the message will be lost. Messages
such as "Mismanagement of Chemicals Puts Students at Risk" sometimes prove to be useful. This
message was used in public service announcements that were placed by EPA into trade magazines.
In many SC3 programs, including King County, Washington's "Rehab the Lab" program,
implementers use pictures of poor chemical management from local schools to illustrate the
problems that result if chemicals are not removed or properly stored. The use of visual images and
personal stories are often effective ways to illustrate the magnitude of the problem and enhance the
message.
Determine who should deliver the message. It is important to identify who will be most effective in
delivering the message. Some schools tend to pay more attention to a message coming from a state
Department of Education than from an environmental agency, because they believe that they are
more accountable to an education agency. Furthermore, schools may perceive a message coming
from an environmental agency as an enforcement threat. If this happens, the school may be
disinclined to admit the presence of chemical hazards in their school due to concern about a penalty.
In this case, a program message should clearly state that the SC3 program is not an enforcement
program.
Provide program details up front. Providing details on the program's requirements, level of
implementation effort, and benefits may increase participation by removing or mitigating
preconceived barriers. For example, a school may assume participation will require a large amount
of staff time and resources when, in fact, these are obstacles that can be overcome by forming
partnerships with the community or industry. In at least one instance, providing more information up-
2 The facts and opinions expressed during the interview process of the evaluation served as the primary source of information for
answering the main questions of the evaluation project and are the basis for this section of the report.
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front increased the number of schools interested in participation because they were aware of the
expectations and "knew what they were getting themselves into."
Enlist Participation
Secure school participation. By instituting requirements or prerequisites for participation, the SC3
program implementer can measure the degree of adherence to responsible chemical management
practices. In Tennessee, Maine, and Vermont, program implementers used written participation
agreements that each school signed. In the "Rehab the Lab program in King County, Washington, a
small fee was imposed to get potential participants "invested" in the program. In Vermont's "School
Science Lab and Mercury Clean-Out Project" and Ohio's "Hazardous Waste Removal Program,"
teachers were required to attend training sessions to fulfill SC3 program requirements.
Leverage available resources and knowledge holders. A comprehensive SC3 program requires
expertise not only in environmental issues, but also in school management and administration;
education and curriculum development; chemical management safety and training; health concerns;
regulatory requirements; and risk management. It is not economical or practical for one entity to
have resources to meet all of the various program requirements. Therefore, it is essential that the
state, tribe or local SC3 program implementers call upon available resources and expertise housed in
other agencies, industry, and the community.
Form Partnerships
Form partnerships. Form and use effective partnerships to gain specialized knowledge, resources,
and staff. Some factors that affect the ultimate effectiveness of these partnerships are:
* Definition and delineation of roles and
responsibilities;
* Open lines of communication; and
* Agreement on time and resource commitments.
It will be necessary to perform an initial assessment of partner
interest The SC3 program implementer should engage potential
partners early in the SC3 scoping process to gauge the level of
interest and determine the resources they are willing to contribute
to the program. This up-front assessment will decrease the risk of
seeming to have a lot of partners when only a few actually
contribute to the program. The key is to choose a range of partners
who will remain active and provide assistance throughout the life of
the SC3 program.
Also, it will be necessary to define roles and responsibilities. Once
partners are identified, their respective roles and responsibilities
need to be defined. This can be done by the SC3 lead organization or collaboratively with the
partners. Defining roles is essential to a productive and responsive partnership that takes advantage
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of organizations' specialized expertise while establishing involvement expectations. Below is a list of
potential partners and what they may contribute.
* Chemical Suppliers and Manufacturers
Provide technical assistance to schools on how to inventory their chemicals, manage and dispose
chemicals responsibly;
Offer cost-effective waste analysis and handling solutions for periodic cleanouts;
Assist schools in establishing best practices and developing a chemical management plan;
Offer training and workshops to teachers and facilities personnel; and
Promote product stewardship through full service chemical management.
* Waste Handlers and Environmental Services Providers
Assist with the management of waste chemicals and encourage schools to keep different types of
waste separate at the point of generation;
Help schools set up a secure and segregated hazardous waste storage area that is clearly marked
if hazardous waste is stored on-site before it is disposed;
Offer cost-effective waste analysis and handling solutions; and
Provide schools with waste manifests and accurate records of the final disposition of their wastes.
* Fire, Police, and Emergency Response
Establish effective communication with the schools or school districts
in your community;
Provide schools/school districts with information on fire codes and
identifying applicable requirements regarding chemical use, storage,
and disposal. This information could be conveyed through periodic
walkthroughs;
Offer training or guidance on responsible chemical management;
Work with schools to identify potentially harmful and dangerous situations related to the use and
storage of chemicals;
Assist with the handling of dangerous chemicals; and
Help develop school-specific chemical management and emergency response plans.
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* Colleges and Universities
Share expertise of environmental health and safety staff with area K-12 schools and help assess
chemical cleanout, management, and disposal issues, such as:
Conducting a chemical inventory;
Offer courses and training in environmental health and safety for teachers and school
district employees;
Consider offering opportunities to local schools to share in the college or university's waste
collection and disposal system;
Incorporate environmental health and chemical safety training into the curriculum of pre-
service teachers; and
Encourage teachers to evaluate the chemicals they use in their lessons and recommend
the use of less toxic alternatives or lessons that create less chemical waste.
* Environment, Health, and Education Agencies
Provide technical assistance to schools in conducting chemical inventories and cleanouts;
Allow schools to dispose of some of their chemicals in household hazardous waste collections, if
feasible; and
Assist schools with funding chemical management programs.
When considering potential partners, explore existing and natural relationships to schools. Alow cost,
high return investment for SC3 program developers is to make good use of existing relationships with
schools. Entities with an existing relationship with schools are often natural partners for SC3 efforts.
They already have knowledge, personnel, and other resources dedicated to providing services to
schools. In Rhode Island's "Chemical Safe Schools Committee," personnel at the Rhode Island
Department of Health used existing relationships with personnel at the state environmental agency,
local college and university, and others to gain support of SC3 efforts. In addition, SC3 programs can
take advantage of existing infrastructure that can be used for communication, outreach, training, and
other activities. The Tennessee Department of Environment and Conservation (TDEC) use an existing
pollution prevention program's infrastructure (Tennessee Pollution Prevention Partnership) to secure
state agency and business partners for their SC3 program. Also remember that personnel overseeing
the facilities and grounds and others, such as the school nurse, often know a lot about chemical
handling, storage, and ordering practices. Whenever possible, these personnel should be engaged to
provide assistance with chemical management policies and practices.
And finally, do not forget to involve the local community. Local community partners extend past
parents and teachers to include local fire departments; emergency personnel; local businesses;
colleges and universities; municipal solid waste districts and others. These groups strive to provide
services to the local community and may have children in schools, making the incentive to help even
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greater. You should consider what a resource they can be to help with outreach, technical assistance,
program implementation and sustainability.
Plan for Full Chemical Lifecyde Implementation
Inventory existing chemical supplies. Completing a chemical inventory not only provides schools
with a baseline characterization of the situation, but also serves as a tool for future chemical
management. Knowing the amounts and types of chemicals is also useful when estimating removal
and disposal costs.
Another type of inventory is an actual on-site audit.
These audits not only inventory chemicals for
disposal, but also allow trained staff to educate
teachers and other relevant school staff on storage
practices and related safety issues. In Oshkosh,
Wisconsin on-site audits showed that more than
double the amount of chemicals were removed from
schools than had been originally stated on the
inventory sheet completed by teachers before the
audit.
A chemical storage area in a Tennessee school that
was inventoried as part of TDEC's SC3 efforts. Photo
courtesy of TDEC.
' Include responsible chemical management and chemical cleanout as program elements.
Disposing of inappropriate and dangerous chemicals is critical to creating safe schools; what is
equally important is to institute responsible chemical management practices. Responsible chemical
management practices and policies will prevent the need for large cleanouts in the future and will
mitigate potential accidents, exposures, and other risks. Such practices may include: chemical
purchasing polices; chemical management plans; required staff training; naming a school chemical
hygiene officer (i.e. someone responsible for implementing responsible chemical management
practices); and budgeting for appropriate storage and disposal.
Provide training to school administrators, teachers, and facility personnel. Offering training as
part of an SC3 program provides tools and information that administrators, teachers, and other
facilities personnel can use in taking inventory of chemicals, conducting a cleanout, and instituting
management practices. Furthermore, it is important to provide training throughout the different
stages of the SC3 program, in order to provide current, relevant and practical information in a way
that can be retained in the memory. Providing one comprehensive training session covering a broad
array of topics may overwhelm trainees and prove ineffective.
Vermont's 'School Science Lab Chemical and Mercury Clean-Out Project' used a multi-phased
approach to training. As a requirement of participation, and to receive a certification of completion,
school staff had to attend a training session prior to the chemical inventory phase, which covered
topics such as conducting an inventory and general lab safety. A second training workshop was held
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Building Successful Programs to Address Chemical Risks in Schools
following the chemical cleanout, which presented cleanout results, chemical management plans, and
responsible purchasing practices.
You may want to consider incentives to make training opportunities more attractive to participants.
These may include offering training at little or no cost to teachers or providing continuing education
credits.
B. Potential Barriers to Achieving SC3 Program Success
Program implemented noted some common
barriers to successful SC3 programs...
* Insufficient funding;
* Limited staff resources for program
implementation;
* Chemical management not
considered a high priority;
* Resistance to change from
established teachers;
* School staff turnover;
* Inadequate pre-service or practical
training for all relevant school staff;
and
* No follow-up compliance or technical
assistance visits.
Insufficient Resources and Low
Priority Consideration for SC3
Programs
Funding. Funding directly impacts many of the
critical success factors that lead to ultimate
program success. A state, tribal, or local SC3
program may have developed a comprehensive
program incorporating responsible chemical
management and cleanout, but without adequate
funding, may not be able to effectively implement
the program.
In many cases, SC3 programs may not have
enough funds to tackle all of the schools that
need assistance with chemical cleanout and
training; however, they can provide funds to
accommodate a portion of the activities or program components. An example of a program that did
not have funding for chemical cleanout but still achieved success is the Montana Department of
Environmental Quality "School Lab Outreach Program." The Department of Environmental Quality
(MTDEQ) launched an extensive and comprehensive outreach effort and developed a detailed Web
site to assist schools with responsible chemical management. Most schools funded their chemical
cleanout with their own budget. However, interviewees in Montana said that with additional funding
MTDEQ could reach out to more schools, update outdated chemical inventories, and achieve greater
success.
Low priority given to SC3 programs. Chemical management must compete with other school
budget priorities, from student academic achievement to keeping schools safe from crime. If
chemical management is not seen as an imminent problem or concern, it may not be considered a
top priority. Adding complexity to the budget decision-making and prioritization process is the fact
that many school administrators, such as principals, do not feel qualified to tackle chemical
management issues. Teachers and administrators may also feel they lack the time and knowledge
necessary to understand these issues.
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Staff Turnover, Knowledge, and Perspective
Staff turnover. Many schools have to deal with high rates of staff turnover. When teachers or other
staff members leave their positions, there may not be procedures in place to capture and transition
important information on chemical management activities to new staff. Information as basic as the
location of all of the chemicals (e.g., cabinets, storage rooms, janitorial closets) may not be known.
Programs such as Maine's Department of Environmental Protection "Schools Program" and
Vermont's "School Science Lab Chemical and Mercury Clean-Out Project" noted instances when
new teachers found chemicals by accident or in unexpected locations. This lack of institutional
knowledge could hinder implementation and the sustainability of SC3 programs. The impacts of
turnover can be mitigated through a solid transition and training to whoever will assume chemical
management responsibilities.
Resistance to change from established teachers. Program implementers found that teachers
who have been at a school for a while may want to hold on to unneeded "legacy" chemicals, even
though they do not typically use them in routine classroom activities. This practice may stem from a
belief that the chemicals will be useful in a future experiment or demonstration, or a concern that
because of school budget constraints they won't be able to purchase needed materials in the future.
In other cases, some teachers may be hesitant to experiment with unfamiliar, newer "green"
approaches to teaching chemistry.
Lack of adequate pre-service or practical training. School staff involved with chemical
management activities may not have adequate or up-to-date training in responsible chemical
management. For instance, many teachers have not specifically taken chemical safety or
management courses as part of their college training. Some of the training that is offered does not
provide practical information that teachers can easily apply when they return to their classrooms. In
addition, the school's purchasing officer may not be well-versed in things that they could do to
support responsible chemical management. Without proper training that emphasizes practical
applications of information and techniques, SC3 programs may encounter implementation and
sustainability difficulties, such as not knowing: Safer alternatives to chemicals used in classroom
activities; proper chemical management and lab safety practices; which chemicals are no longer
needed or are not stored properly; and, the benefits of keeping an updated chemical inventory.
Lack of Follow-Up
Lack of follow-up compliance or technical assistance visits. States and other organizations
implementing SC3 programs often do not have sufficient funds, staff, or authority to provide follow-up
visits to ensure that schools comply with SC3 program requirements. In addition, many schools still
require guidance and technical assistance following the cleanout process to properly institute and
sustain responsible chemical management activities. This lack of follow-up visits and subsequent
technical assistance and enforcement of the program requirements was cited as a barrier to success
and program sustainability.
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C. Ensuring Sustainability of Program Results
Program implementers identified the following best practices and approaches for sustaining successful SC3
programs. Ensuring that an SC3 program will prevent future chemical management problems is a key goal.
Program implementers should consider incorporating provisions at the outset of an SC3 program for
sustaining responsible chemical management and for conducting regular cleanouts in the future.
Champions, Technical Assistants, and Partners
Find a champion. Involving someone who is not only knowledgeable but also passionate about
SC3 issues is a key to program success and longevity. A champion can help secure funding,
conduct outreach, and provide technical assistanceall factors that increase the likelihood of
program success and sustainability. In Ohio, a retired chemistry teacher with a strong background in
chemicals and lab safety gathered public support for Ohio's "Hazardous Waste Removal Program,"
taking the issue to the state legislature and securing over $2 million in funding. In Iowa's "Rehab the
Lab" program, a staff person at the Metropolitan Waste Authority provided a significant portion of her
time to promote the advantages of chemical management both in Iowa and to others around the
country. Her knowledge and enthusiasm for the cause motivated individual schools and other SC3
programs. Ideally, a school principal, department chair, or superintendentsomeone in a
management position with input on budgeting and policy matterswould serve as an effective SC3
champion.
Use local universities and community partners for technical assistance. Local colleges,
universities and other community partners can provide technical expertise, training, and continuing
education opportunities. In Rhode Island, the "Chemical Safe Schools Committee" program
partnered with Brown University. The university provided technical assistance on chemical
management activities. The Tennessee Department of Environmental Conservation has tapped a
local college to create a Green Chemicals Manual that provides environmentally preferable "green"
chemistry experiments for teachers.
Use partnerships to sustain long-term goals. Partnerships are not only critical to building
successful SC3 programs, but also to sustaining program goals. One way to sustain productive
partnerships is to demonstrate partner benefits. In Iowa's "Rehab the Lab" program, the Metropolitan
Waste Authority approached the state's school insurance carrier, EMC Insurance. The insurance
company had been impacted by a chemical mismanagement incident that cost the company
$750,000. To reduce the risk of similar losses in the future, they became an active partner in Iowa's
program by including provisions for technical assistance for cleanout and responsible chemical
management in all Iowa school insurance policies. Participating schools were offered a discount of
five percent on their insurance policies for meeting the requirements of the SC3 program. This win-
win solution offered incentives to both the schools and the insurance company; however, the real
winners were the children and staff who worked in safer schools.
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Building Successful Programs to Address Chemical Risks in Schools
Incentives
Provide financial incentives to increase participation and sustainability. In addition to the
example above where participating schools were offered a discount of five percent on their insurance
policies for meeting the requirements of the SC3
program, states have incorporated other financial
incentives into their programs. Several interviewees
mentioned that they required schools to "invest" in the
program by paying a small fee for participation, based
on criteria such as the number of students in the school
or whether the school has more resources because it is
in a city rather than in a less accessible location. Many
interviewees observed that schools with some stake in
the program are more motivated to participate and
meet program requirements. An additional incentive was provided in one school district where
substitute teachers were hired to attend to classrooms while the school's permanent teachers were in
chemical management training.
Explore partnering with state agencies to discuss potential regulatory incentives. Consider
approaching appropriate state, tribal, or local agencies (such as the departments of the environment,
health and safety, or education) to discuss whether it is possible to use existing regulatory authority
to promote compliance with SC3 program requirements. For example, in Maine, schools must
inventory and submit a list of their on-site chemicals to the Department of Environmental Protection
and the Department of Education on an annual basis. If a school does not comply, the Maine
Department of Education can withhold vital school subsidy funding.
Another approach is offering schools regulatory amnesty for cleanouts and disposal of chemicals.
Some schools may not want regulatory agencies to know the extent of their chemical management
problems. Providing such schools an opportunity to participate without risk of regulatory or
enforcement action is an incentive, which will likely result in more hazardous chemicals being
removed.
Recognize successful efforts. Publicly recognizing the organizations achieving results from an
SC3 program can be a useful approach to motivate other schools to increase their chemical
management efforts. In the Tennessee Department of Environmental Conservation (TDEC)
program, schools receive pledge certificates, flags, decals, and public recognition that denote their
participation in the program as well as their level of accomplishment. The TDEC program
implementers also use these "success stories" when promoting the program to others, further
recognizing the school's achievements.
Funding
Mitigate unnecessary paperwork and transactional burdens on schools.
Rather than burdening individual schools with additional paperwork, SC3 program
administrators should consider centralizing the management of the disbursement of
funds to cover cleanouts, training, and other expenses associated with a
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Building Successful Programs to Address Chemical Risks in Schools
responsible chemical management program. This will also make it easier for SC3 program
administrators to track program progress. For example, in the Rhode Island "Chemical Safe Schools
Committee" program, funds were dispersed through a master purchase agreement that covered only
SC3-related activities.
Utilize cost-effective chemical disposal principles and techniques. Schools usually have tight
budgets and adding the cost of safely removing unwanted chemicals often poses difficulties. SC3
programs should try to set up a central chemical collection point or leverage the services of Solid
Waste Management Districts to defray the costs to schools and the program. EPA's Region 5 asked
school representatives in Oshkosh, Wisconsin to bring chemicals slated for disposal to a household
hazardous waste facility that served as a central collection point. Vermont's Department of
Environmental Conservation worked with a Solid Waste Management District to use a licensed and
insured hazardous waste collection truck to pick up chemicals slated for disposal, thus saving money
in transportation costs.
Training and Outreach
Conduct multiple trainings throughout the
lifecycle of chemical management. It is
important to provide training and education
opportunities throughout the chemical
management lifecycle. Each step, from taking
inventory of chemicals to instituting long-term
responsible chemical management policies,
requires different types of knowledge and skills.
It is not always feasible, appropriate, or effective
to have one training session that provides
information on each aspect of responsible chemical management. Instead, providing training
sessions at different points in time, covering different topics, will help teachers remember more in the
long run, thus promoting overall SC3 program success. Providing practical, hands-on training is
best. King County, Washington's "Rehab the Lab" program used this approach to help teachers
identify hazardous chemicals in lab stockrooms and mark them for disposal.
Use existing training programs and forums to educate teachers and school staff. Consider
piggybacking on teacher in-service days, staff meetings, industry conferences, and other training
opportunities to provide chemical management training to teachers and other staff. Using existing
forums may improve attendance; leverage limited financial resources; ease scheduling difficulties;
and allow teachers to participate without placing a burden on their personal time and resources. In
Tennessee, SC3 program implementers made a list of opportunities such as conferences and in-
service days that they used to schedule chemical management training, thereby maximizing
participation and minimizing cost.
Use innovative outreach tools and approaches. Use creative approaches to spread the word and
educate teachers and school staff about the SC3 program and how to manage chemicals
responsibly. For instance, in Iowa, all schools are equipped with a public television station that
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Building Successful Programs to Address Chemical Risks in Schools
broadcasts information to every school. Their "Rehab the Lab" program used these TV stations to
promote the SC3 program and to conduct training sessions.
Conversely, some programs preferred to use a less direct approach, to avoid making school
chemical management sound like a crisis to the public. For example, King County's "Rehab the Lab"
program was publicized through word-of-mouth bolstered by advertisements in science teacher
newsletters.
Preventing Future Chemical Management Problems
Incorporate environmentally friendly, small-scale chemical practices into purchasing
decisions. Purchasing less hazardous chemicals in smaller amounts is a critical component in
maintaining long-term responsible chemical management. Not only should the science department
adopt this practice, but also the art, vocational and custodial departments. The key is to change
behavior that will be reflected in a school's business practices. Examples of such practices include:
* Purchasing self-contained lab kits;
* Maintaining a single school or district wide, up-to-date chemical inventory;
* Centralizing chemical purchases;
* Evaluating and authorizing potential chemical purchases; and,
* Developing a budget for chemical needs.
Incorporate performance measures. Developing and incorporating performance measures will
highlight the program's accomplishments and improvements. Examples of things to measure include
the number of students and staff affected by the SC3 program; the amount of chemicals removed;
the number of teacher training sessions that were completed; the number of teachers and
administrators that were trained; and the number of schools making commitments to prevent future
chemical mismanagement. These performance measures can be used to support budgeting and
funding decisions, increase awareness, and garner support from potential partners.
D. Using SC3 Programs to Sustain Long-Term Chemical
Management Success
FLAMMABLE ^"1''e cnem'ca' cleanout is a critical near-term focus of SC3 programs, other
KHP rmt **ta program elements are equally important to prevent the need for future
cleanouts and change behavior to decrease chemical risks in schools. SC3
programs should implement activities that change behavior and will ultimately
result in achieving long-term outcomes and goals. When you institute
practices for responsible chemical purchasing, use, management, and
disposal it will result in program sustainability and self-sufficient schools in
control of their chemical management situation. Consider integrating the
following common program elements into your SC3 program.
A Flammable Chemicals storage
cabinet helps achieve long-term
responsible chemical management.
Photo courtesy of TDEC.
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Building Successful Programs to Address Chemical Risks in Schools
Institute long-term chemical management policies and regulations. Policies and standard
operating procedures that promote responsible chemical management, such as chemical purchasing
and proper chemical storage, should be implemented at the individual school or school district level
in order to achieve long-term chemical management goals. Be mindful of unique situations in your
state that may dictate how policies are developed and who is responsible for implementation.
Institutionalizing and reinforcing policies and standard operating procedures will ensure good
chemical management despite staff and teacher turnover.
Consider long-term planning and budget development. Many of the common components of an
SC3 program can be useful tools in long-term program sustainability. For instance, a chemical
inventory can also be used as a planning and budgeting tool. Schools can assess the amount and
type of chemicals they will need to carry out classroom, facilities and maintenance activities. This will
help make informed planning, purchasing, and budgeting decisions and reduce the likelihood of
unnecessary, improper, or duplicative
chemical purchases.
Establishing and sustaining SC3 program
success...
* Institute long-term chemical
management policies and
regulations
* Consider long-term planning and
budget development
* Maintain responsible chemical
management practices
* Maintain performance and
compliance measures
* Acquire long-term technical
assistance
* Cultivate a mix of partners interested
in long-term responsible chemical
management
Maintain responsible chemical
management practices. It is essential
that SC3 programs put policies in place
that advocate responsible chemical
management practices. Implementing
these policies will sustain chemical
management progress. This will help
schools ensure that future activities do
not undermine accomplishments, trigger
the need for future cleanouts, or
increase the risk of accidents and
exposures.
Maintain performance and
compliance measures. Develop a
process for schools to easily report that
they have met or exceeded the
requirements for participation,
showcase accomplishments, and identify challenges they overcame. Program results, in the form of
a report or some other communication, should be sent at regular intervals to program implementers.
This process is not only a low-cost compliance tool, but can also be used by schools to measure
incremental success. Program implementers can also potentially use performance results in a variety
of ways such as seeking program funding or attracting additional participants.
Acquire long-term technical assistance. Schools are not necessarily equipped to tackle chemical
problems without technical assistance. Providing a way for the school to get technical assistance,
such as providing a contact in the school district who can answer questions about chemical disposal
options, will help the school achieve long-term chemical management success. Such assistance will
increase the schools' confidence in their ability to maintain their SC3 program success.
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Cultivate a mix of partners dedicated to long-term responsible chemical management. Having
an appropriate mix of partners who can offer long-term technical expertise and financial resources
will help maintain a robust SC3 program. Engaging partners early and assessing their potential
contributions is important to determine if they will provide long-term assistance. Call upon local
community partners, parents and teachers. These are partners who may have children in schools
and who strive to provide community services. Industry partners can provide long-term technical
assistance and other resources to ensure that responsible chemical management is sustained into
the future.
E. Measuring Program Performance and Accomplishments
Performance measures are an important
component of an SC3 program to monitor
progress toward meeting goals; identify
program deficiencies and corrective
measures; and report program
accomplishments. Performance
measures can also be a useful for
budgeting; meeting school or community
environmental goals; making funding
decisions; and designing effective
responsible chemical management
practices.
Typical performance measures used by
the state and local SC3 programs include:
Type and Class Of Chemicals removed; Chemicals ready for disposal. Photo courtesy of TDEC.
Amount of chemicals removed;
Number of training sessions completed;
Number of teachers and administrators trained;
School populations protected or serviced;
Cost of cleanout per school; and,
Number of schools making commitments to responsible chemical management or other "beyond
compliance" activities.
In addition to these metrics, consider developing an approach or specific metrics to assess changes in
behavior over time. A teacher's ability to identify improper chemical storage or to enter chemical purchases
into a central tracking system are examples of changes in behavior that can be documented. Because
changes in behavior are difficult to measure, and measurement must take place overtime in order to see
the extent that new behaviors have become routine, SC3 programs implementers may want to set
intermediate indicators or goals of behavior change. For example, if teachers continue to purchase
chemicals without adhering to school-wide purchasing practices even after they have been trained to do so,
follow-up discussions with teachers and modifications to the training should take place. Effective SC3
programs will result in behavior changes and create practices that will sustain chemically safe schools. It is
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critical to develop a variety of performance measures that accurately and routinely capture a program's
progress towards meeting its short, intermediate, and long-term goals.
Conclusion
Approaches for developing SC3 programs must be flexible and allow for adding components in phases
when resources and conditions are right for your school. While each school has its own set of unique
circumstances, the need for responsible chemical management practices that ensure schools are safe from
chemical risks is common among all. The experiences and practical knowledge presented in this report are
intended help you prevent chemical mismanagement in schools, thereby protecting children, teachers, staff
and the environment.
ISIT THE SCHOOLS
CHEMICAL CLEANOUT CAMPAIGN
WEB SITE
www.epa.gov/sc3
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APPENDICES
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Appendix 1 ~ Evaluation Methods
Existing state/local SC3 programs were identified that might provide the best insights. Being mindful of the
desire to evaluate a diverse, yet representative selection of programs, we worked to identify both EPA's
SC3 funded as well as non-EPA funded state and local programs. We developed a list of candidate
programs that reflected a diversity of locations, program budgets and scopes, and program maturities (see
Appendix 2).
The next step involved developing selection criteria. Four categories of selection criteria were developed:
program scope; program structure; program/school characteristics; and "other", which reflected data
availability criteria. Based on those criteria we evaluated the following programs:
EPA SC3 Funded Programs
Rhode Island, "Chemical Safe Schools Committee";
Tennessee Department of Environment and Conservation SC3 Program;
SC3 Project in Oshkosh, Wisconsin; and
Iowa "Rehab the Lab".
Non-EPA Funded Programs
Maine, Department of Environmental Protection's "Schools Program";
Vermont, School Science Lab Chemical and Mercury Clean-Out Project;
Ohio, "Hazardous Waste Removal Program";
Montana, Montana Department of Environmental Quality's "School Lab Outreach Program"; and
King County, Washington "Rehab the Lab".
The evaluation project aimed to address the following information objectives:
Critical success factors and barriers to SC3 program implementation;
Best practices and approaches to building a successful SC3 program;
Factors that contribute to program sustainability (including recruiting and retaining partners);
Performance measures; and
Ways to improve existing SC3 programs.
The evaluation methodology relied upon an interview-based approach that was supplemented by Internet
research and document review. The objective of the interview process was two-fold: meet the information
objectives and identify potential programmatic elements to serve as examples/case studies.
Although a list of interview questions was developed, a dynamic interview approach was adopted that
adapted to the knowledge and experience of each interviewee. The dynamic approach allowed the
interviews to be tailored based on a series of background or contextual questions (e.g., program
implementers were asked about critical success factors). Using this approach makes the most efficient use
of limited interview time while honing in on the interviewees expertise and knowledge. It also allowed us to
seek input on unexpected findings and hypotheses put forth throughout the interview process. Program-
specific questions included such topics as program description, funding, and program goals and outcomes.
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For each state and local program, we typically interviewed Regional EPA personnel first, followed by a
state, local, or other program contacts. Keeping in mind this is a formative evaluation, we asked program
administrators to comment on program management recommendations in addition to specifics on
state/local programs. In all we spoke with 19 people representing the 9 programs.
Throughout the interview process, we supplemented our information collection efforts with Internet
searches, such as Lexis-Nexis, and document review. We reviewed numerous documents received from
interviewees including presentations, press materials, status reports, funding applications, and
communications and outreach materials. When available, we also visited each of the program websites for
additional background information on the programs.
We established and adhered to a Quality Assurance Plan throughout the evaluation process. We crafted
interview questions that tied to information objectives. Every interview involved two contractor personnel,
thereby ensuring that comprehensive notes were taken and all relevant questions and follow-up inquiries
were made. We sent follow-up emails to certain interviewees to clarify statements and collect additional
documents and information for review.
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Appendix 2 - Program Summaries
Twelve candidate programs were identified for consideration in the formative SC3 evaluation. The
candidate programs include 6 initiatives that were funded by EPA in 2004 and 6 state or local initiatives that
were not funded with EPA SC3 funds. The location and name of the programs are as follows:
EPA Region 1, Rhode Island, "Chemical Safe Schools Committee"
The "Chemical Safe Schools Committee" (CSSC) is a public-private partnership working to address
chemical management issues in schools. The partnership members include the Rhode Island Departments
of Health, Education, Environmental Management (DEM), and Labor and Training; Brown University;
Community College of Rhode Island; Rhode Island Committee on Occupational Health and Safety; Rhode
Island Fire Marshall's Office; and private business. Their goal is to support schools and districts in
minimizing health risks from chemicals through development of guidance materials, training and
professional development opportunities, and the use of regulatory authority.
The CSSC successfully worked to incorporate a list of banned chemicals into the Rhode Island Rules and
Regulations for School Health Programs in 2003. The Rhode Island Department of Health, on behalf of the
Committee, used EPA SC3 funds to assist public and charter high schools with chemical removal. Only
schools that have developed a Chemical Hygiene Plan were eligible for assistance. The Chemical Hygiene
Plan must address chemical purchase, storage, disposal, personal protective equipment and contain an
inventory. Greater consideration is also given to school systems that have a greater community need
(defined as a percentage of children receiving free or reduced cost lunches). As of 2006, 4,686 students
were impacted by the chemical cleanouts in a total of eight schools.
Currently, the CSSC works to educate school personnel and others on chemical management issues. The
Rhode Island DEM also assists schools by providing technical expertise. DEM works with the Department
of Labor, who has the authority to conduct school inspections, to share information on chemical
management concerns at schools.
EPA Region 4, Tennessee Department of Environment and Conservation SC3 Program
Beginning in the fall 2004, selected schools in Tennessee participated in the School Chemical Cleanout
Campaign. The SC3 program was an expansion of a previous pilot program facilitated by the Tennessee
Department of Environment and Conservation (TDEC)/ Division of Community Assistance's "Green
Schools Program". The Green Schools Program stems from a partnership among TDEC, the Tennessee
Science Teachers Association, the Tennessee Valley Association, Onyx Environmental, and the
Tennessee Department of Agriculture.
TDEC's SC3 programs seek to reduce waste, eliminate outdated, unknown and unusable chemicals from
schools, encourage environmentally sound use of chemicals in classrooms, bring cost savings to schools
through responsible chemical management, and promote SC3 success state-wide. TDEC's programmatic
components included lab chemical inventories, disposal, and teacher training. TDEC staff conducted
numerous trainings and also partnered with a local university to develop a green chemistry handbook for
teachers.
TDEC has been successful in reaching their goals and is has even assisted school districts in other states
with their SC3 programs. In total, 69 schools were cleaned out with 23,000 Ibs of hazardous chemicals
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Building Successful Programs to Address Chemical Risks in Schools
removed. TDEC leveraged various EPA grant-funding sources by requiring schools to contribute funds
based on their socio-economic status.
EPA Region 5, Oshkosh, Wisconsin SC3 Project
EPA Region 5 is using SC3 funds to reduce the amount of hazardous chemicals, including mercury and
lead, and increase chemical awareness in schools. The program focuses on schools in under-served
areas. Each school must complete a chemical audit. This audit will not only identify the hazardous, expired
and infrequently used laboratory chemicals, but will serve as a teaching tool to identify lab safety issues
and assist teachers in more effective purchasing of chemicals. Following the audit, chemicals will be
collected for disposal.
Each school is provided intensive technical assistance, both on-site and by phone, to assist implementation
of best management practices for chemical reduction and management. Schools are encouraged to make
commitments to proper chemical management "beyond compliance" with the program. For example,
schools may change purchasing policies or refuse to accept donated chemicals. The ultimate goal of the
program is to promote increased self-sufficiency in chemical management and also strengthen existing
partnerships with departments of health, education and environmental organizations.
EPA Region 7, Iowa's "Rehab the Lab"
The EPA Region 7 currently facilitates the Iowa school cleanout effort through onsite compliance
assistance visits and a partnership with Des Moines Metro Waste Authority (MWA). As of 2006,182
schools of 366 have been reached, with 206,905 Ibs of hazardous chemicals removed. The Iowa program
not only focuses on the removal of excess laboratory chemicals, but also waste storage practices,
responsible chemical management, and education of teachers, administrators, and facilities personnel.
The MWA has been supporting SC3 efforts in Iowa since approximately 2000. The EPA SC3 funding has
allowed MWA to reach out to more schools and develop a series of training sessions to complement the
efforts. MWA has been successful in partnering with EMC Insurance Company to expand the program
throughout the state and ensure chemical management efforts are in place for years to come. EMC works
with schools to implement responsible chemical management activities as a requirement of their insurance
packages. This also results in discounts on insurance premiums and ensures relevant schools are
adequately trained. The school staff completes extensive training that focuses on environmental
compliance awareness, waste stream identification, alternatives, and a review process for on-site
assessment.
Maine Department of Environmental Protection's "Schools Program"
In 2003 and 2004, the Department of Environmental Protection (DEP) conducted a mercury and chemical
cleanout program for schools. Through the program, 6,500 pounds and over 1,000 gallons of hazardous
wastes and 800 pounds of mercury were removed from science labs, maintenance departments, art and
vocational classrooms, and nurses' stations in 80 schools. Radioactive materials were also discovered in
nearly a dozen schools, and were subsequently removed. As part of the program, DEP, in partnership with
the Department of Labor, also held chemical management workshops for school faculty.
In 2005 as a result of the growing concern over hazardous chemicals in public schools, the Maine
legislature directed the Departments of Education and Environmental Protection to develop
recommendations for assisting school districts. The resulting stakeholder group recommended hiring a
statewide chemical coordinator as well as local/regional coordinators to ensure sound chemical
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management programs in schools. Legislation will likely occur with respect to the recommendations of the
stakeholders group in 2007.
In 2006, the Department of Education coordinated a clean out effort for nearly 75 schools. Chemicals were
cleaned out of schools at each school's own expense, but at a negotiated reduced rate available through a
particular vendor.
Vermont, "School Science Lab Chemical and Mercury Clean-Out Project"
The School Science Lab Chemical and Mercury Clean-Out Project was established and funded by the
Vermont Department of Conservation (DEC) from 1999-2001. The project's objectives were to dispose of
outdated and hazardous chemicals, reduce the amount of hazardous chemicals purchased, encourage
school labs to remove all mercury compounds and discontinue future mercury use, and educate science
teachers on proper handling, storage, and disposal of hazardous chemicals. Participating schools were
assisted with conducting chemical inventories, chemical disposal and establishing safe storage systems. In
addition, the project offered teacher training workshops and required all schools to develop a chemical
management plan for labs.
DEC considered the project highly successful, not only from the lab cleanout perspective, but for its lasting
impact on proper chemical management in schools. Eighty-three middle and high schools participated in
the project, representing over half of the Vermont student population. According to DEC, the project
resulted in about 17,000 pounds of hazardous materials and 156 pounds of mercury. It has been reported
that the average total cost per school for cleanout and training was $1,450. The DEC minimized costs by
using state agency staff and the municipal solid waste district staff.
Ohio, "Hazardous Waste Removal Program"
In the late 1990s, the Ohio EPA and the Ohio Department of Education partnered to implement a state
legislature funded $2.9 million hazardous waste removal program in Ohio schools. According to the Ohio
EPA, the program was the first of its kind in the country and ultimately removed over one million pounds of
chemicals from 196 schools (90% of Ohio school districts). All of the 196 schools had "high hazard"
materials that required special handling to be removed. Many of the chemicals collected were acquired
prior to World War II. As a result of the two-year effort, student safety and awareness dramatically
increased. Nearly 1,000 school officials and teachers attended chemical management and safety
seminars. Prior to the effort, only about 1.6% of teachers had received any type of training. It has been
reported that the cost of removal averaged less than $3,000 per school and the cost savings per school
averaged $10,000money that would have been spent on a commercial cleanup service.
Montana Department of Environmental Quality "School Lab Outreach Program"
In August 2004, Montana Department of Environmental Quality (MDEQ) surveyed 408 middle and high
schools statewide to collect information on the types of chemicals present in school science labs. Over 38%
of the schools responded, reporting a total of 570 different chemicals. As of June 2006, a total of seven
schools and approximately 3,000 pounds of hazardous chemicals have been removed and properly
disposed. Cleanouts are planned for an additional three schools including two in Indian Country.
MDEQ also organized a series of one-day training courses on school lab chemical safety and management
during the last two weeks of September 2005. The workshops, which were conducted by Safety and
Science Education Consultants, Inc., were held in nine communities. Personnel from schools in 43
communities attended the workshops. 114 teachers, administrators and school custodians completed the
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workshops. The Business and Community Assistance Program of MDEQ has received grant funding that
will be used to assist schools in the proper removal and disposal of unwanted chemicals.
MDEQ has a comprehensive website that provides chemical management resources on lab safety,
suggested approaches for taking inventory of chemicals, ideas for improving chemical purchasing and
other topics. MDEQ has also received funding from EPA to expand the Laboratory Cleanout Program and
the funds are to be dedicated to removing chemicals from more schools in Montana.
King County, Washington's "Rehab the Lab"
King County, Washington's "Rehab the Lab" Program offered assistance, free of charge, to King County
schools to manage their hazardous chemicals. The Program provided chemical experts from the County's
hazardous waste office to train teachers about chemical storage and disposal. The program also helped
teachers to rethink what chemicals they actually needed and for what purpose. At the outset, there was
some reluctance by school officials and teachers to dispose of the chemicals, citing no funds were available
to order replacement materials. However, in the end, most decided to participate in the program. Over a
four-year period, the program cost $560,000 and was primarily funded by surpluses in sewer and garbage
surplus collection fees. The program paid 100% of laboratory chemical disposal and partial assistance for
removing art supplies and photo chemicals. In total, 39.5 tons of chemicals were removed.
The program continues to provide education, assessment and advice aimed at school laboratories. The
state provides matching grants to cover the cost of the initial site audit, collection and disposal costs and
teacher training. In addition, fully scripted lesson plans, chemical lists, and various informational brochures
are available online. The King County program has not only served as a model for others in Washington,
such as Thurston County, but to schools across the nation including Iowa, Missouri and Colorado.
(For more information about state programs in general, please see the document Building Successful
Programs to Address Chemical Risks in Schools: Summaries of State, Tribal, and Local Schools Chemical
Cleanout Campaign Programs available at: http://www.epa.gov/sc3/)
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Appendix 3 ~ Interview Questions
SC3 Evaluation Questions for EPA Regional Personnel
Background/Context
Describe your involvement in the program/describe your interaction with those leading the program
How long have you been aware/involved with the program?
How long has the program been in existence?
What is the program's purpose? Is it part of a larger effort?
Is a chemical management program/cleanout/inventory required by law/regulation?
Program Specific Questions
Program Description
Please describe the main themes of your program. For example, does it involve cleanout? Taking
inventory of school chemicals/hazards? Outreach? Guidance? Policy development?
What was the impetus for the program?
What was the thought process behind determining the main themes or components of your
program?
What are the program components?
Give us a sense of the scope of the program. For example:
How many schools are involved? What percentage of total? Elementary, middle (define), high
school? How many kids impacted, faculty impacted?
How many people were involved in the program and what was the total FTE required to
implement the program? (e.g., 2 FTE of 10 teachers' time)
Please describe the structural elements of your program. For example,
Describe the roles and responsibilities of key personnel in the program.
Was work performed under an already existing contract/grant vehicle?
What is the labor mix (e.g., # teachers)
Compensation - was there a voluntary/pro bono/in kind aspect of the program? Who got
compensation (e.g., do teachers get paid?)?
Please describe any partnerships formed or stakeholder involvement in the implementation of the
program.
What was their role?
What impact did they have?
Do you feel they are an integral part of the program? Why or why not?
Do you feel it would be helpful to speak with any of the partners or stakeholders? If so,
could you provide me with contact information?
Was a stakeholder group formed/used? Was it ad hoc, already established, did it become
permanent?
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Funding
What has been the total funding to date? Can you provide an approximate estimate of the funding
for each year of the program to date?
What are the sources of your funding? Did the program have matching funds or another source of
funds besides EPA? If so, how do you think that impacted the success of the program?
Program Goafs and Outcomes
What has been the biggest accomplishment(s) of the program?
Do you feel the program has made schools safer? Please describe.
Do you feel the program has reduced risks of releases / exposure going forward?
Describe any changes in policies, procedures, or behavior (e.g., chemical purchasing or chemical
management policies).
Does your program establish performance measures up front? If not, when were performance
measures defined and tracked? Please provide any details on your program's consideration and
use of performance measures.
Has there been any resistance to this program? Please describe the substance and source of any
resistance encountered.
What factors would you identify as being critical to the success of the program?
In that area/local vs. global
Was the program primed or were other environmental/conservation/p2 type activities taking place
prior to the SC3 program?
What factors would you identify as being impediments to the success of the program?
Do you have any suggestions for improvement of your program?
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