vfrEPA
United States	Office of Pollution Prevention	EPA 747-R-06-002
Environmental Protection and Toxics	December 2006
Agency	Washington, DC 20460
Chemical Management
Resource Guide for
School Administrators
Printed on Recycled Paper

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Acknowledgements
The time and effort that many individuals contributed to the review and development of this
document is gratefully acknowledged by the U.S. Environmental Protection Agency (EPA). This
document was prepared by Battelle Memorial Institute under contract EP-W-04-021 at the
direction of Mr. Clarence Lewis of the EPA Office of Pollution Prevention and Toxics.
Disclaimer
This document was prepared under contract to an agency of the United States Government.
Neither the United States Government nor any of their employees makes any warranty, expressed
or implied, or assumes any legal liability for any third party's use of or the results of such use of any
information, product, or process discussed in this document. Mention or illustration of company
or trade names, or of commercial products does not constitute endorsement by the EPA. As of
the date of this document, external links are current and accurate, and are offered by way of
example only for reference purposes. The EPA is not responsible for content of non-EPA links.

Chemical Management Resource Guide for School Administrators

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Summary
. .No one was sure what chemicals were involved in the fire [in the facilities maintenance warehouse at the
school]. Pallets of bleach, ammonia and sulfuric acid based drain cleaner had been stored adjacent to each other,
and rupturing of the chemicals during the fire created an acid vapor cloud as well as chlorine and phosgene gases.
The total cost of this event was about half a million dollars."
— From a case study of a suburban public high school in New England1
Are there
Dangerous
Chemicals in
YourSchoo\?
The sources of dangerous
chemicals in schools are not
always obvious. This guidance applies to any
school that purchases, uses, stores, or
disposes of chemicals or products containing
dangerous materials. Some of the most
common dangerous chemical products in
schools include:
•	Laboratory chemicals (e.g., acids, bases,
solvents, metals, salts)
•	Industrial arts or "shop" classes (e.g., inks,
degreasers)
•	Art supplies (e.g.
chemicals)
•	Pesticides, fertilis
•	Maintenance sup
(e.g., drain cleane
products, paints,
mercury switches
•	Health care equ
thermometers).
What Can Schools
Do to Prevent
Spills and
Costly Incidents
of Dangerous
Chemicals?
•	Establish a leadership team consisting of
qualified and experienced individuals to
oversee chemical management activities
and confirm the availability of budget and
resources (Section III.A)
•	Implement pollution prevention and green
chemistry (safer alternatives) principles,
whenever possible, to minimize the use
of hazardous chemicals at schools
, paints, photographic
;ers, and de-icers
plies and equipment
rs, floor stripping
oils, boiler cleaners, fuels,
and gauges)
>ment (e.g., mercury
Who Should Read
This Guidance?
This document is
\	designed primarily for
school administrators
(principals and other
policymakers), but may also be of value for
teachers, maintenance personnel,
superintendents, school business officials,
insurance industry risk managers, and
parents.
(Section III.B)
Establish a chemical management policy
and chemical hygiene plan (Section III.C)
Conduct periodic chemical inventories to
identify hazards (Section III.D)
Establish an environmentally preferable
purchasing policy (Section III.E)
Implement an appropriate chemical storage
and handling policy (Section III.F)
Establish a training program for hazardous
chemicals management and safety
(Section III.G)
Develop a hazard communication plan to
foster awareness among school personnel
and students about die range of chemicals
and products used in schools
(Section III.H)
Create an emergency response and spill
clean-up plan and ensure that all chemicals
are disposed of in accordance with federal,
state, and local regulations (Section III.I)
V
Chemical Management Resource Guide for School Administrators
ii

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Where Can I Get
Additional Help?
Each EPA Regional Office shares common
chemical management goals; each region has
its own contact point to best serve schools in
their respective states. For more information
on EPA programs for schools, such as EPA's
Schools Chemical Cleanout Campaign (SC3),
legal requirements that schools may face, and
where your school can receive additional
help, refer to the following regional contact
information and websites in the box below.
«
Local government entities that may be able
to help your school understand and address
chemical management issues (e.g., treatment
and disposal options) include Local
Emergency Planning Committees (LEPCs),
local health departments, state environmental
departments, and fire departments.
For more information about how local
organizations can help, visit EPA's SC3 -
Businesses and Community Organizations
website at http://www.epa.gov/sc3/.
Check It Out
& EPA Resources for Additional Information
•	EPA, Healthy School Environments, http://www.epa.gov/schools/
•	EPA's Schools Chemical Cleanout Campaign (SC3), http://www.epa.gov/sc3/
•	EPA, Where You Live, http://www.epa.gov/epahome/whereyoulive.htm
What Legal Requirements Do I Have?
Some chemicals purchased by schools may need to be managed as hazardous wastes and may
ultimately require disposal as such. Hazardous wastes need to be managed from their initial point of
generation until their ultimate point of disposal, known as "cradle to grave." The Resource Conservation
and Recovery Act (RCRA) gives EPA the authority to control the generation, transportation, treatment,
storage, and disposal of hazardous waste. Any school that generates hazardous wastes must notify their
state environmental agency and obtain an EPA Identification (ID) Number. This EPA ID Number must be
put on all manifests for tracking disposal of school wastes and must be site specific for the address given.
School liability does not end when the wastes leave the school, and school administrators must make sure
they receive a copy of the shipping manifest stating that their wastes arrived at their destination (e.g.,
treatment, storage, or disposal facility). Laws and regulations pertaining to RCRA are available at
http ://www.epa.gov/epaoswer/osw/laws-reg. htm.
EPA's Healthy School Environments Assessment Tool (HealthySEAT) provides information to help
determine if a school is subject to Federal OSHA requirements at
http://www.epa.gov/schools/healthyseat/frequentquestions.htm Although Federal OSHA does not have
jurisdiction over state and local government employees, including those in public schools, the 26 states
that operate OSHA-approved State Plans are required to extend their state standards to these workers.
A list of OSHA State-Plan states is located at http://www.cdc.gov/niosh/docs/2004-
101/appena.html#oshasps. Each state's programs are unique and may have additional regulations and
requirements. In states under Federal OSHA without State Plans, OSHA has no authority to inspect or
enforce standards in public schools; however, the local Federal OSHA office may be able to provide
hazard recognition assistance and technical support. Compliance assistance information is available
on OSHA's website at http://www.osha.gov.
The National Institute for Occupational Safety and Health (NIOSH) provides a comprehensive safety
checklist program for schools at http://www.cdc.gov/niosh/docs/2004-101/default.html, which contains
recommendations and detailed checklists on OSHA regulations, along with background information on
how to make sense of regulations that may be applicable to schools (http://www.cdc.gov/niosh/docs/
2004-101/chap1.html).
In addition, EPA may enforce certain OSHA standards, such as Hazardous Waste Operations
(29 CFR 1910.120) or relevant EPA standards in public schools. In addition to Federal
requirements, states may have their own laws. Legal requirements are often updated and vary
from state to state. In many states, the health and safety of public employees, including teachers
and other school staff, fall under the jurisdiction of a state agency, such as the state department
of labor or commerce.
Note:
This document is intended
to serve as guidance only
and does not supersede
any federal, state, or
local laws and regulations.
Chemical Management Resource Guide for School Administrators

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Table of Contents
Page
Summary	ii
I.	Overview	1
I.A. Introduction	1
I.B. Organization of this Guide	2
I.C.	Why You Should Be Concerned	3
II.	Hazardous Chemicals and Products in Schools	4
II.A.	Chemicals and Products of Concern	4
II.B. Chemical Categories	4
II.C.	Where Chemicals and Products are Found	6
III.	Policies and Actions	8
III A. Leadership and Resources	8
III.B.	Pollution Prevention and Greener Alternatives	9
III.C. Chemical and Product Management	11
III.D. Chemical Inventory	12
III.E. Purchasing	13
III.F. Storage and Handling	15
III.G. Training	16
III.H. Hazard Communication	17
III.I.	Spills, Cleanup, and Disposal	17
IV.	Special Cases	20
IYA. Arsenic	20
IY.B. Asbestos	20
IV.C.	Lead	21
IV.D. Mercury	22
V.	Conclusion	24
References	25
Appendix	A-l
Chemical Hygiene and Management Plans	A-l
Sample Guidelines	A-3
Checklists	A-5
Chemical Purchasing, Storage, and Design Guidelines	A-7
Use of Chemicals in Schools	A-8
Chemical Management Resource Guide for School Administrators	iv

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I. Overview
I.A. Introduction
From elementary school maintenance storage
closets to high school chemistry laboratories,
schools house a variety of chemicals. Many
of these chemicals are hazardous and are
used daily; however, in some cases, these
chemicals have been unused for decades.
Ensuring that these chemicals are managed
properly will help school administrators to:
safeguard the health and safety of students
and school employees; avoid disposal
expenses and costly school closures associated
with spills and emergency incidents; maintain
a sense of trust between the district and the
surrounding community; and prevent damage
to the environment. School districts need
solid, useful, specific recommendations and
information on responsible chemical
management to facilitate the establishment of
sound district-level policies and procedures.
This document is intended to aid K-12 public
school districts and private, religious, and
independent schools and school system
policymakers in reducing dangerous chemical
use and implementing responsible chemical
management practices. Institutionalizing
such practices will help to minimize the
incidence of chemical spills, exposures, and
emergency scenarios in schools. This
document focuses on broad policy
considerations that EPA recommends school
administrators consider implementing to
properly manage and use all dangerous
chemicals. Parents and others in the
community interested in school health
and safety policies also may use this booklet
to determine whether their children's schools
are effectively minimizing potential exposure
to dangerous chemicals and products.
This document is part of EPA's Healthy
School Environments Initiative. The
Healthy School Environments website
(http://www.epa.gov/schools/) serves as a
gateway to on-line resources to help school
administrators, teachers, facility managers
and other staff, and parents address
environmental health issues in schools.
This document is also an integral part of the
EPA Schools Chemical Cleanout Campaign
(SC3) toolkit. The goals of the SC3 are to:
remove potentially harmful chemicals from
schools; emphasize the implementation of
preventive programs such as chemical
management training for lab instructors and
microscale techniques; and raise national
awareness of the issue of chemicals in
schools. The ultimate goal of the SC3 is
to create a chemically safer school
environment in which chemicals are
purchased wisely, stored safely, handled by
trained personnel, used responsibly, and
disposed of properly. Finally, this document
includes numerous boxes highlighting
information on relevant EPA and state
information, such as the HealthySEAT tool
developed by EPA as a resource to address
chemical management among other
environmental, safety, and health issues.
HealthySEAT^
Healthy School Environments Assessment Tod fa- 4,
EPA has developed a unique software tool to help
school districts evaluate and manage all of their
environmental, safety, and health issues, including
all aspects of their chemical management
programs. The Healthy School Environments
Assessment Tool (HealthySEAT) can be
customized and used, free of charge, by district-
level staff to conduct voluntary self-assessments
of their facilities and to manage information on
environmental conditions within each building.
Source: EPA, HealthySEAT,
http://www.epa.gov/schools/
healthyseat/index. htm I
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1

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I.B. Organization of this Guide
Section I explains the need for responsible
chemical management policies and why
school administrators must be concerned
about chemical management in their schools.
Section II provides an overview of the
various classes of hazardous chemicals and
products of concern found in schools, and
discusses where these chemicals and
products of concern might commonly be
found in schools.
Section III presents recommendations for
school administrators to develop their own
consistent and effective policies, promotes
concepts such as pollution prevention and
green chemistry, and provides information
on best practices for the purchase,
identification, tracking, storage, use, and
disposal of hazardous chemicals found in
elementary and secondary schools.
Section IV discusses special types of
chemicals that are of particular concern.
Section V presents conclusions.
The Appendix lists specific examples of
various "how to" forms, templates, and
checklists for establishing policies and
procedures that schools may use to
facilitate the implementation of EPA's
recommendations.
This document contains numerous
references and endnotes to school-focused
guidance documents and materials on
chemical management, green chemistry,
pollution prevention, environmentally
preferable purchasing, and school cleanout
campaigns initiated in school districts. For
example, the Los Angeles Unified School
District, one of the largest school districts in
the country, along with its home state of
California, have been committed to spreading
awareness about chemicals in schools, as
illustrated below.
The Los Angeles Unified School District (LAUSD) has been particularly active on issues related to chemicals in
schools. The LAUSD's Office of Environmental Health and Safety (OEHS) website contains a wealth of resources
for school officials, including a searchable product review tool available on the OEHS Chemical Evaluation Program
page (http://www.lausd-oehs.org/productreview chemeval.asp) and comprehensive information about its Chemical
Hygiene Program. The OEHS Chemical Hygiene Program page (http://www.lausd-oehs.org/chemical-hvqiene.asp)
contains links to various handouts and the Science Safety Handbook for California Public Schools (http://www.lausd-
oehs.orq/docs/Misc/CAScienceSafetvHandbook.pdf). It also lists chemicals approved by the State of California and
OEHS for use in LAUSD school laboratories. These chemicals can be viewed by clicking the "View Approved
Laboratory Chemicals" button on the OEHS Chemical Hygiene Program page (listed above).
The State of California has customized EPA's HealthySEAT software to incorporate California's regulations and
links to other state-specific information, including funding sources. State-customized versions of HealthySEAT make
it easier for individual school systems to adapt and use the tool.
2
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I.C. Why You Should Be
Concerned
There are five key reasons why school
administrators should be concerned about
chemical management in their schools:
Improper chemical management
poses health and safety risks to students
and school employees. Health, learning,
and behavior risks to students are
of particular concern, as children are
more vulnerable than adults to chemical
exposures because their bodily systems are
still developing; they eat more, drink more,
and breathe more in proportion to their
body size; and their behavior can expose
them more to chemicals than adults.
The expenses incurred from disposal
spills, and other incidents, including
potential liabilities/lawsuits, can
be considerable. The costs of
responding to chemical incidents can
reach hundreds of thousands of dollars or
more at a single school.2 In addition to
response costs, improper chemical waste
management can result in fines and
increased insurance premiums.
~ It only takes one chemical incident,
such as a spill, explosion, or
chemical exposure, to break the trust
with the community. Reported school
incidents can lead to increased parental and
community concern, negative publicity,
and embarrassment to the school and
school district.
Improper chemical management
may result in school closures that
result in a loss of valuable education
time.
Improper chemical management
5 can lead to unintended chemical
discharges and spills, which inflict
damage upon the environment where
students, teachers, staff, and parents live
and work. Improper chemical discharges
into sanitary sewer lines or on-site waste
treatment systems (including septic tanks)
can have adverse effects on rivers, streams,
and groundwater. Chemical releases and
spills can also contribute to air pollution.
Spills to the ground can ultimately result
in long-term harm to the land and
considerable remediation costs.
A safe school environment that prevents
harm to students and protects school
employees from dangerous chemicals must
be promoted. Responsible chemical
management is likely to lead to improved
learning in the classroom and improved
overall health of the environment and the
community.
Chemical Management Resource Guide for School Administrators
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II. Hazardous Chemicals and Products
in Schools
II.A. Chemicals and Products
of Concern
Approximately 75,000 chemical substances
are in commercial use today.3 Many of these
chemical substances are considered toxic or
otherwise hazardous to humans and other
living beings. Toxic chemicals are associated
with a variety of serious health problems,
including cancer, brain and nervous system
disorders, reproductive disorders, organ
damage, as well as asthma. Toxic chemicals
that are persistent in the environment and
bioaccumulate through the food chain can
make exposure during childhood and
adolescence especially dangerous. Chemicals
also can irritate the skin, eyes, nose, and
throat. Some chemicals pose significant
safety hazards, such as fire or explosion risks.
The risks associated with exposure to a
chemical are dependent on many factors, including
the chemical's hazard level (degree of flammability,
toxicity, etc.), the route of exposure (e.g., absorbed
through skin, inhaled, consumed, injected), and the
duration of exposure.
Many hazardous chemicals can be found in
school facilities. Material Safety Data Sheets
(MSDS), comprehensive fact sheets prepared
by chemical manufacturers, describe the
physical properties, health effects, and
other characteristics of chemicals, as well as
procedures for handling, storing, and
disposing of these substances.4 Chemical
manufacturers should supply MSDSs along
with each shipment of chemicals delivered to
your school. The proper use and
management of these substances, as well as
the products that contain them, are critical to
maintaining a healthy atmosphere for school
occupants and the surrounding environment.
The term "hazardous chemicals" may include
(but is not limited to) the following:
•	Laboratory chemicals used or stored in
science laboratories and preparation areas;
•	Art supplies, including paints, stains, inks,
glazes, and photo processing chemicals,
used in (visual and performing) art and
shop;
•	Cleaning products utilized by custodial,
cafeteria, and maintenance staff;
•	Pesticides, fertilizers, and de-icers/salts/
sands used for grounds maintenance,
as well as pesticides used for building
maintenance;
•	Paints, solvents, fuels, degreasers, and
lubricants used in building operation and
maintenance;
•	Oils, fuels, paints, antifreeze, and other
chemicals used to maintain and repair
equipment for transportation, school
maintenance, and shop classes;
•	Inks, solvents, and adhesives used for
printing in school offices; and
•	Chemicals used to treat water associated
with drinking water and swimming pools.
II.B. Chemical Categories
Chemicals can be grouped based on the type
of hazard they pose. Understanding the
different types of chemicals in a school is
important for developing an effective
chemical management policy. Hazardous
substances in schools may fall into one or
more of the following categories:
flammables/explosives, corrosives (the
majority of which in high school laboratories
are acids and bases), oxidizers/reactives,
toxins, and compressed gases. Federal
agencies and legislative authorities have
developed specific definitions for each of
those categories; however, the hazards can be
described generally as follows:5
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1 Chemical Type
¦ Description and Examples 1
Flammables/
Explosives
n
Chemicals that have the potential to catch fire rapidly and burn in the air. Liquids, gases,
and solids (in the form of dusts) can be flammable and/or explosive.
Examples: paint thinner; laboratory solvents (acetone, alcohols, acetic acid, hexane);
adhesives (some)
Corrosives
A
Chemicals that can burn, irritate, or destroy living tissue or corrode metal through direct
chemical action. This category includes strong acids and bases (alkalines), as well as
dehydrating agents and oxidants.
Examples: sulfuric, nitric, and hydrochloric acids; potassium, ammonium, and sodium
hydroxides (bases); hydrogen peroxide or chlorine (oxidants); acetic acid
Oxidizers/
Reactives
%
Chemicals that react violently when combined with heat, light, water, or atmospheric
oxygen, causing explosions or violent chemical reactions.
Examples: nitrates; chlorates; nitrites; peroxides; picric acid (crystallized); ethyl ether
(crystallized); water reactive metals (e.g., sodium)
Toxins

r
*
r
Any substances that, even in small amounts, can injure living tissue when ingested,
inhaled, or absorbed into the skin.
Examples: mercury; arsenic; lead; asbestos; cyanide
Compressed
Gases
t
i
i
U

Gases stored under high pressure such that cracks or damage to the tanks and valves
used to control these gases could cause significant physical harm to those in the same
room.
Examples: acetylene; helium; nitrogen
Check It Out
Improper storage practices may increase the risks associated with certain chemicals, particularly those that are flammable,
corrosive, or reactive. The King County Laboratory Waste Management Guide (http://www.govlink.org/hazwaste/
publications/LabGuidelinesRevAugust06.pdf) provides suggestions for safe and effective chemical storage, including shelf
storage patterns for small stockrooms (see Table 1).
EPA's "No More 'Methyl Something': Improving Management of Curriculum Chemicals in Schools" presentation provides
examples of dangerous storage scenarios: http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/pdfs/chemsafe.pdf.
Chemical Management Resource Guide for School Administrators
5

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II.C. Where Chemicals and
Products are Found
Chemicals can be found throughout a school.
They are used in both the maintenance of
schools and the curriculum taught.
Chemicals help students to perform
experiments and learn new skills, among
other benefits. In the absence of chemicals,
schools would lack certain fundamental tools
needed to educate students. Despite their
useful purposes, chemicals can be dangerous
to students and staff when managed
improperly. Hazardous chemicals are found
in classrooms, laboratories, storerooms,
maintenance sheds, and numerous other
areas. High schools usually have larger
inventories and more hazardous chemicals
than middle and elementary schools.
Chemicals may have been purchased by the
school or brought in by employees or
students for their personal use.
The table on the following page: lists some
specific locations in which chemicals and
products of concern might be found in a
typical school. Please keep in mind that this
list is by ho means all-inclusive, and that
chemicals, when used appropriately, can be
important to the educational process.
Hazardous chemicals are found in classrooms, laboratories,
studios, maintenance areas, and numerous other areas.
The photo above depicts one location where chemicals and
products of concern might be found in a typical school. This photo
also demonstrates a properly organized chemical storage area.
Photo Credit: Rehab the Lab Program,
Local Hazardous Waste Management,
King County, Washington
Check It Out
Types and Locations of Hazardous Chemicals/Products in Schools:
•	EPA, Chemical Management and Usage, http://www.epa.gov/Region7/education_resources/teachers/
ehsstudy/ehsl .htm and "No More 'Methyl Something': Improving Management of Curriculum Chemicals in
Schools," http://www,epa.gov/epaoswer/osw/conserve/clusters/schools/pdfs/chemsafe.pdf
•	Colorado Department of Public Health and Environment, One Hundred Most Commonly Found Explosive
and Shock-Sensitive Materials, www.cdphe.state.co.us/cp/lnstitutions/Schools/ChemslnSchools/
ExplosiveTop40.PDF
Alternatives to Products of Concern:
•	EPA, Environmentally Preferable Purchasing, http://www.epa.gov/epp/Massachusetts Environmentally
Preferable Purchasing Program, Product and Service Information, http://www.mass.gov/epp/products.htm
•	Maryland State Department of Education, Safety in Ordering, Storing, Using and Disposing of Chemicals,
http://www.mdk12.org/instruction/curriculum/science/safety/chemicals.html
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Hazardous Ingredient I
¦ Location |
| Product Type |

Examples 1

Concentrated Acids (undiluted)

Hydrochloric acid
Nitric acid

Concentrated Bases (undiluted)
Sodium hydroxide

Solvents
Methanol
Methylene chloride
Science laboratories
Oxidizers
Lead nitrate

Compressed gases
Oxygen

Toxins
Cyanides
Chromates (VI)
Lead salts
Mercury salts
Vocational and
trade shops (can also be
referred to as Career and
Technical Education)
Solvents (used in paints, paint thinners, adhesives, lacquers,
primers, and other products)
Petroleum naphtha
Turpentine
Cleaning supplies/detergents
Phosphoric acid
Sodium silicate
Compressed gases
Acetylene
Nitrogen

Fuels, transmission, and brake fluids
Gasoline

Solvents (used in paints, inks, paint thinners, adhesives,
lacquers, primers, and other products)
Toluene
Mineral spirits

Pottery clear coating glaze
Lead
Other heavy metals
Visual and
performing art studios
Pigments for paints and coatings
Cadmium
Manganese
Chromium

Dry clay for ceramics and jewelry
Silica

Acids for etching
Nitric acid
Hydrochloric acid

Cleaning supplies/detergents
2-Butoxyethanol
Trisodium phosphate

Drain cleaners (alkaline)
Drain cleaners (acidic)
Potassium hydroxide
Sulfuric acid
Custodial/maintenance
areas
Pesticides (including disinfectants/sterilizers)
Permethrin
Sodium hypochlorite

Paint thinners
Toluene

Solvents (used in paints, paint thinners, adhesives, lacquers,
primers, and other products)
Water treatment chemicals for swimming pools
Xylene
Chlorine tablets
Kitchens/cafeterias
Pesticides (including disinfectants/sterilizers)
Permethrin
Sodium hypochlorite
Refrigerants
Freon
Ammonia

Cleaning supplies/detergents
Ammonium hydroxide
Nurses' offices
Medical equipment
Mercury (thermometers and
blood pressure manometers)

Intensifiers/reducers
Potassium dichromate
Hydrochloric acid
Photography laboratories
Developers
Hydroquinone
Lactic acid

Stop baths and fixer
Acetic acid
Chrome alum (potassium
chromium sulfate)
School grounds/
athletic fields
Pesticides
2,4-D
De-icers
Sodium chloride
Fertilizers
Ammonium nitrate
Administrative offices
Correction fluid
Solvents (used in paints, inks, paint thinners, adhesives,
lacquers, primers, and other products)
Ethylene glycol
Trichloroethane
Methyl ethyl ketone
Petroleum distillates

Printer/copier toners
Carbon black
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7

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Policies and Actions
The following sections provide guidance on
recommended chemical management policies.
These policies relate to: pollution prevention
and green chemistry (concepts that minimize
the potential for hazardous chemical use in the
first place); the general management of
chemicals and products already present in
schools; chemical inventories; the purchasing
and tracking of chemicals; the storage and
handling of hazardous chemicals; personnel
training and hazard communication; and
chemical spills, cleanup, and disposal. To
properly implement these suggested policies,
schools should establish a leadership team and
confirm the availability of budget and
resources.
III.A. Leadership and
Resources
To institute good chemical management
policies, school administrators need to set the
tone that chemical management is important
by assigning roles and responsibilities for
implementing proper safety and chemical
hygiene practices. Guidelines are provided
below that policymakers at the district level
and school administrators should implement
in order to initiate responsible chemical
management practices in their schools.
Training and Teamwork Approach
to Safety and Chemical Hygiene
"Northshore School District, in Washington State,
has adopted the training and teamwork approach to
Safety and Chemical Hygiene in the past 2 years.
As a result, last year our insurance pool lowered our
annual insurance premium by $30,000 for our efforts.
In enacting these programs our Director of Curriculum,
Director of Risk Management, and the Chemical Hygiene
Officers saved money for the district."
John Schmied,
Northshore School District
Chemical Hygiene Officer
•	Establish or confirm that your district
has committed budget and staff
resources for chemical management.
When schools consider their costs for
chemicals, they generally consider only the
purchase price. Each stage of chemical
and product management, however, has
associated costs of labor (e.g., training
chemical hygiene officer and other staff),
materials, equipment, and disposal, as well
as costs of storage space and potential
liability when responsible chemical
management is not practiced.
•	Design and communicate a chemical
management policy. School district
administrators and principals need to
establish an overall policy stating a strong
commitment to responsible chemical
management, including implementation of
the policies and actions defined in this
document. The policy should be
communicated to all by the highest level of
management. Strong support from the
administration, combined with adequate
resources, will enable responsible chemical
management. Active involvement by the
full school community is an important
element of success, as well.
•	Appoint a chemical hygiene officer.
The chemical hygiene officer is someone
who is qualified by training and experience
to provide technical guidance and
leadership in the development and
implementation of the provisions of the
chemical hygiene plan. T he position
description or job classification of a
chemical hygiene officer will vary across
school districts; however, in all cases, they
should be trained to provide chemical
management leadership to the school.
•	Designate a team to oversee the
chemical management program at your
school. This team should consist of
teachers, janitorial staff, and maintenance
personnel to comply with the chemical
hygiene plan and help oversee the chemical
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management program at your school
described in the sections that follow.
Team members should be trained by the
chemical hygiene officer (and reinforced
at least annually). At a minimum, team
members should understand physical/
chemical properties and potential
health effects of chemicals, chemical
compatibility, applicable environmental
regulations and compliance issues, and
waste management procedures of the
school. You may also consider involving
students (as applicable) as part of the
process.
• Disseminate information. Share
experiences and lessons learned with other
school districts and administrators.
Maintain a proactive program of informing
parents, guardians, teachers, and other staff
about chemical and product management
activities ongoing at your school.
III.B. Pollution Prevention and
Greener Alternatives
A key aspect of responsible chemical
management is identifying opportunities
to minimize chemical use through the
implementation of pollution prevention
and green chemistry principles.
Pollution prevention (sometimes referred to
as 'T2") is defined as preventing or reducing
pollution at the source, whenever feasible,
and other practices that replace or eliminate
the creation of pollutants. An example of
pollution prevention would be using smaller
quantities of (or environmentally benign
substitutes for) chemical products used for
grounds maintenance or cleaning.
A related concept, green chemistry, focuses
on science laboratories by reducing the levels
of toxicity and amount of chemicals used in
experiments, promoting safety, pollution
prevention, and waste minimization. Similar
concepts, microscale chemistry and small-
scale chemistry, involve scaling down the
quantities of chemicals required for science
experiments resulting in improved laboratory
safety. Exploring and adopting pollution
prevention and green chemistry concepts in
a school system results in many direct
environmental benefits and often results in
cost savings for schools.
The following guidelines can be used to
reduce or eliminate the generation of
chemical pollutants and wastes.
• Establish a policy that makes pollution
prevention the preferred form of waste
management and strives to eliminate the
purchase and use of most, if not all,
hazardous chemicals. If elimination of the
particular chemicals is not possible, other
options include, in order of preference,
reuse or recycling of chemicals and
products; treatment of chemicals to reduce
toxicity; and disposal of chemicals in an
environmentally safe manner.
Check It Out
While treatment may be a useful activity, it should be cautioned that the treatment of hazardous waste may require
a permit or be subject to regulation. You should consider discussing any treatment options with state or local
regulatory agencies before you implement them in your laboratory. Neutralization of acids and bases, permitted
under federal law, is probably the most commonly used treatment method in educational institutions; however,
states may have more stringent standards regulating the disposal of acids and bases. To learn more about
treatment methods, see Battelle Seattle Research Center's "In-Laboratory Treatment of Wastes," available on the
P2 Pays website at http://www.p2pays.org/ref/01/text/00779/ch13.htm.
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•	Contact your state pollution prevention
department for assistance in conducting
a pollution prevention opportunity
assessment, or contact your EPA Regional
Office at http://www.epa.gov/p2/pubs/
local.htm to find programs available in
your area as well as the issues affecting
your part of the country. Each EPA
Regional Office supports pollution
prevention activities that reduce or
eliminate the sources of waste and
pollutants through work with voluntary
programs, partnerships with business
and industry, state and local governments,
citizens groups and other federal agencies.
•	Establish a pollution prevention program
to help your school minimize the amount
of chemical waste generated throughout
your school. The program may consist of
developing school-wide and departmental
annual waste reduction goals. The
program may also include pollution
prevention education sessions for teachers,
maintenance staff, and students
emphasizing the importance of substituting
hazardous chemicals with chemicals that
are less hazardous and scaling down the
volume of chemicals used in classroom
experiments and maintenance applications.
• Minimize the use of pesticides, a term that
refers not only to insecticides but also to
herbicides, fungicides, and various other
substances used to control pests. Children
may be especially sensitive to the health
risks posed by pesticides because their
bodies are growing and developing; they
may also have greater exposure to
pesticides because of their increased hand-
to-mouth behaviors. A form of pollution
prevention, integrated pest management
(TPM), is an effective and environmentally
sensitive approach to pest control that
relies on common sense strategies to
disrupt the life cycles of pests.
The following resources provide technical background information to help schools implement their
own pollution prevention/waste minimization programs:
•	Ohio EPA, Laboratory Pollution Prevention fact sheet, http://www.epa.state.oh.us/opp/Fact16_web.pdf
and P2 checklist of lab opportunities, http://www.epa.state.oh.us/ocapp/p2/labp2checklist.pdf
•	Battelle Seattle Research Center, Laboratory Waste Minimization and Pollution Prevention: A Guide for
Teachers, http://www.p2pays.org/ref/01/00779.htm, and Chapter 8, Scaling Down Experiments,
http://www.p2pays.org/ref/01/text/00779/ch08.htm
•	EPA, Pollution Prevention: Definitions, http://www.epa.gov/opptintr/p2home/p2policy/definitions.htm
•	EPA, 12 Principles of Green Chemistry, http://www.epa.gov/greenchemistry/principles.html and Teachers,
http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/teachers.htm
•	EPA, state P2 Programs, http://www.epa.gov/opptintr/p2home/resources/statep2.htm
•	EPA, Integrated Pest Management (IPM) in Schools, http://www.epa.gov/pesticides/ipm/
•	EPA's Schools Chemical Cleanout Campaign (SC3), http://www.epa.gov/sc3/
•	Great Lakes Regional Pollution Prevention Roundtable, Topic Hub™ for Pollution Prevention for Arts Education,
http://www.glrppr.org/hubs/toc.cfm?hub=509&subsec=7&nav=7
•	Green Cleaning Pollution Prevention Calculator, http://www.ofee.gov/janitor/index.asp
•	Colorado State University, National Small-Scale Chemistry Center, http://www.smallscalechemistry.colostate.edu
•	Merrimack College, National Microscale Chemistry Center, http://www.microscale.org/
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ill.C. Chemical and Product
Management
Responsible chemical management is critical
to controlling a variety of environmental,
health, and safety issues within any school.
Knowing what materials are present in your
school and how they are used, stored, and
discarded will enable you to understand the
issues associated with these substances.
Properly recognizing and controlling the
hazards inherent to these materials, wherever
they are found in your schools, will enhance
your ability to create a safe school with
minimal environmental liabilities/lawsuits.
EPA's Schools Chemical Cleanout Campaign
Resources such as EPA's SC3 program (see
http://www.epa.gov/sc3il are designed to facilitate chemical
and product management. The purpose of SC3 is to
reduce chemical exposures and improve chemical
management in K-12 schools. By achieving these
environmental goals, the SC3 will contribute to the broader
goals of fewer lost schools days and healthier students,
faculty, and staff.
In addition to EPA's SC3, states have developed their own
SC3 programs:
•	Florida Department of Environmental Protection, School
Chemical Cleanout Campaign (SC3),
http://www.dep.state.fl.us/waste/categories/hazardous/p
ages/schoolchemicals.htm; and
•	Tennessee Department of Environment and
Conservation, School Lab Chemical Cleanout Campaign
(SC3), http://www.state.tn.us/environment/sc3/.
Guidelines are provided below that
schools and administrators should implement
to initiate responsible chemical management
practices in their school.
• Establish an environmentally preferable
chemical management policy considering
the entire chemical and product lifecycle,
which begins with chemical purchasing and
includes identification, labeling, storage,
inventory maintenance, and the activities
associated with the use and disposal of
chemicals and wastes generated from (heir
use, including training, spill control
procedures, and record-keeping
requirements.
Chemicals that are not correctly and clearly
labeled, as shown in the photos above,
should be disposed of properly. Products
used in schools should have an MSDS, be
stored in their original containers, and be
correctly and clearly labeled.
Photo Credit: Rehab the Lab Program,
Local Hazardous Waste Management
King County, Washington
•	Establish a district-level chemical
purchasing policy, chemical products
evaluation process, and a district-approved
chemicals and products list (see Section
111.1 . For example, the Los Angeles
Unified School District's Chemical
Hygiene Program (http://www.lausd-
oehs.org/chemical-hygiene.asp) allows only
approved chemicals to be used in school
laboratories. Controlling what chemicals
are used within your schools is essential to
ensuring that only products that have been
reviewed and approved for use are brought
into the school environment.
•	Create a written chemical hygiene plan that
describes procedures and practices for the
protection of students and school
employees from the health hazards
presented by hazardous chemicals and
products that are found in school
laboratories. The chemical hygiene plan is
a critical element of chemical management
and should contain specific requirements
and guidelines for chemical handling,
inventory, storage, spills, and disposal.
The plan should be updated annually and
whenever necessary. The Appendix
contains excerpts and references to several
examples, of chemical hygiene plans
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currently in use by school districts
nationwide.
• Contact state or local health departments
or environmental agencies for more
information. Many chemical management
practices are often regulated at the federal,
state, and/or local level.
HID. Chemical Inventory
Existing accumulations of outdated,
unknown, poorly labeled, improperly stored,
degraded, and excessive quantities of
hazardous chemicals are present in many
schools. These chemicals pose safety and
health risks to students and school personnel.
Properly identifying and removing these
chemicals is a key step in preventing
accidents. An important part of responsible
chemical management is the creation of an
accurate chemical inventory. ,A chemical
inventory identifies the quantities and
physical locations of, as well as the potential
hazards associated with, all of the chemicals
used and stored in a school. It also serves
as a reference for school and emergency
personnel (e.g., local fire department) in
the event of an emergency. Furthermore,
a chemical inventory, when used to guide
necessary purchases, can reduce the costs and
management needs associated with excess
chemicals.
Guidelines are provided below that
schools and administrators should follow in
order to conduct an inventory at their school.
Some guidelines refer to other documents
(e.g., chemical hygiene plans); information
about these documents is discussed in later
sections.
Chemical Inventory Safety Tips
The process of assessing existing chemical hazards can be
dangerous. The following guidelines are recommended:
•	Contact a trained professional to conduct a walk-through
inspection of the school to pre-screen for potential
hazards. Certain lypes of chemicals pose an imminent
hazard (e.g., shock-sensitive materials) and must be
handled only by qualified emergency personnel or
hazardous waste professionals.
•	If the pre-screening establishes that it is safe to conduct
an inventory, ensure that the inventory team is properly
equipped with personal protective equipment and
emergency response supplies as well as chemical
management and safety knowledge.
•	Ensure that chemical storage areas are properly
ventilated and that potential sources of ignition are
turned off.
•	Conduct pre-screening, inventory and removal while
students are NOT in school
•	When complete, provide your local fire department a
copy of the chemical inventor/.
Appendix 2 of the Massachusetts School Chemical
Management Program (available at http://www.mass.gov/
dep/service/schlchem.pdf) includes a step-by-step guide to
conducting chemical inventories.
A chemical inventory identifies the amount and location
of all of the chemicals stored on-site, covering all
sections of the school including maintenance areas.
A thorough inventory would identify inappropriate
chemical storage practices, such as the one shown in
this photo. Chemicals such as ammonia and bleach
are commonly found in schools. Despite their useful
purposes, these chemicals are incompatible and
should not be stored near each other, especially in
maintenance storage areas or in hot boiler rooms where
the bottles may bulge or break. Mixing of these two
chemicals would create a chlorine gas cloud.
Photo Credit: Marina Brock, Barnstable County
(Massachusetts) Department of Health and
Environment
Conduct an inventory of all of the
chemicals and products containing
chemicals (e.g., mercury thermometers)
stored on-site, covering all sections of the
school including maintenance rooms and
closets, storage sheds, greenhouses, and all
¦og
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classrooms. Engage all school staff who
will either be involved in conducting the
inventory, or will be having their chemicals
inventoried. Pre-packaged science
experiments or demonstration kits should
be included in the chemical inventory.
Establish a policy that chemical inventories
be conducted and updated annually, unless
state or local regulations require a more
frequent schedule. Contact your local state
agency, college or university, industry
partner, or chemical supplier, or identify
a responsible person within the school
who has training in hazardous chemical
management to assist with the inventory.
Review other documents you may have in
schools in your district, such as a chemical
hygiene plan or hazard communication plan, to
ensure that chemicals are consistently
being managed, stored, handled, and
disposed of properly. Review your approved
chemicals and products list (see Section HIE).
Chemicals and products not on this list
should be removed and properly disposed
of or recycled according to applicable
federal, state, and local laws. Update the
inventory when new chemicals or products
are added to the list and when chemicals or
products are used or disposed.
Conduct periodic cleanouts by identifying
and removing unnecessary hazardous
materials and expired chemicals through
appropriate recycling and/or disposal
methods. Chemical inventories should be
conducted prior to cleaning out chemicals
from schools. Contact your local state
agency, college or university, industry
partner, or chemical supplier, or someone
with technical qualifications to identify
potentially dangerous situations (i.e., school
staff should not move very old chemicals
because of the extreme hazard they may
present) and properly handle the chemicals
during a chemical cleanout.
m,
Check It Out
The following resources provide information to
help schools conduct their own chemical
inventories, including a suggested chemical
inventory list. You may also wish to check with
your own state's environmental and educational
agencies.
•	Colorado Department of Public Health
and Environment, Guidance on
Chemical Management in Schools,
http://www.cdphe.state.co.us/cp/lnstitutions/
Schools/ChemslnSchools/ChemMgmt.html
•	Montana Department of Environmental
Quality, Montana School Labs,
http://www.mdeqschoollabs.com/
III.E. Purchasing
Chemicals enter school systems through
a variety of avenues such as regular purchases
(including purchase orders, purchasing cards,
and personal purchases) by teachers and
facility maintenance personnel, as well as
donations from local industries and chemical
suppliers.
Chemicals have varying hazard levels; thus,
the determination to purchase should factor
in need, use, safety, environmental factors,
and chemical/product management lifecycle
costs. Remember, just because a chemical
can be purchased at your local hardware or
grocery store does not mean it is safe if
improperly used or stored.
To create a chemically safer school
environment, school administrators should
implement measures to reduce the amount
and hazardous nature of chemicals entering
their schools. Perform small-scale or
microscale chemistry experiments or seek
environmentally preferred products or
services "that have a lesser or reduced effect
on human health and the environment when
compared with competing products or
services that serve the same purpose."6
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Here are some suggestions of best
management practices to create a
chemically safer school environment:
•	Establish a purchasing policy that
addresses how chemicals and products
containing chemicals are entering a school,
who is using them, why they are being
used, and how they will need to be
disposed. Involve all teachers,
maintenance and custodial personnel, and
other staff to ensure that the chemical
purchasing policy meets educational and
facility maintenance needs while reducing
the quantities and toxicity of chemicals.
The Appendix provides resources to
chemical purchasing examples in schools.
•	Investigate pollution prevention and green
chemistry options (see Section III.B) to
determine whether certain chemicals can
be reduced in quantity or eliminated
entirely from science and art classes.
Environmentally Preferable Purchasing
EPA's Environmentally Preferable Purchasing (EPP)
program was developed to assist federal agencies in
making environmentally conscious purchasing decisions;
however, businesses and state and local agencies have
also found the program to be of value. The EPP website
(http://www.epa.gov/oppt/epp/pubs/about/faq.htm)
discusses frequently asked questions concerning EPP
and includes a number of tools and links to guidance
documents and case studies that schools can use to
identify products that are less hazardous.
• Establish an environmentally preferable
chemical screening process to ensure that
all chemicals and products containing
chemicals have been screened for
environmental, health, and safety hazards
prior to purchase, thus reducing and/or
eliminating hazardous chemicals.
For example, the Maryland State
Department of Education provides
guidance on responsible chemical
purchasing.7 The MSDS may be useful
in this process.
•	Create an approved chemicals and
products list, based on less toxic or non-
toxic alternatives to make non-toxic
implementation and enforcement easier
in your school. Only allow procurement of
approved chemicals.
•	Purchase chemicals and products
containing chemicals in quantities that will
be used during the current school year or
that can be fully consumed under normal
conditions within the shelf life of the
product. Another concept is "just in time"
purchasing in which chemicals are
purchased as needed throughout the
school year. These purchasing methods
reduce the costs and management needs
associated with excess and expired
chemicals.
•	Use products purchased or approved by
the school. Teachers and other staff
should be strongly discouraged from
bringing in products on their own.
Products used in schools should have
an MSDS, be stored in their original
containers in a secure location, and be
correctly and clearly labeled.
Schools should exercise
EXTREME CAUTION when accepting chemical
donations, product samples, or promotional products
(e.g., do not accept chemicals more useful for
electroplating than for the teaching of high school
chemistry). Schools should not give away chemicals
to avoid the costs of disposal.
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III.F. Storage and Handling
School administrators should be aware
of proper use and storage policies
and procedures, to ensure student and
employee safety. Guidelines are provided
below that schools and administrators can
follow in order to reduce the risk of chemical
accidents and ensure that chemicals and
products in their schools are stored and
handled safely.
•	Establish a chemical storage and handling
policy that addresses how chemicals should
be properly stored, labeled, and secured, as
well as who should have access to these
chemicals and chemical storage locations.
Chemicals should not be stored in areas
that are occupied by or accessible to
students, such as classrooms or restrooms;
they should preferably be stored in a
central, secure location. Hie Appendix
provides resources to guidelines on the
proper labeling of chemicals,
recommended storage methods, and other
considerations for proper storage (e.g.j
examples, of incompatible chemicals and
chemical segregation).
•	Conduct at least annual inspections of
classrooms, janitorial closets, and chemical
storage rooms and cabinets in your school
to ensure the integrity of chemicals and
To avoid a situation like the example shown above,
schools should establish a chemical storage and
handling policy that addresses how chemicals should
be properly stored, labeled, and secured, as well as
who should have access to them.
Photo Credit: Rehab the Lab Program,
Local Hazardous Waste Management,
King County, Washington
storage structures. Spot inspections may
be performed periodically throughout the
school year. Engage maintenance staff in
these inspections if storage shelving or
locks are in need of updates or repair.
Create and maintain an up-to-date map
of the location and storage pattern of
chemical storage rooms and cabinets in
your school.
•	Inspect and test emergency equipment
(e.g., eyewash stations and safety showers):
as well as fume hoods and ventilation
systems/exhaust fans at least on an annual
basis, Engage maintenance staff in these
inspections if safety equipment is in need
of updates or repair. Establish protocols
for the upkeep of emergency equipment
and the associated maintenance records.
•	Work with a local chemical supplier to
ensure you have MSDS information for all
chemicals on site. Hazardous chemicals in
schools should be stored in accordance
with MSDS specifications. Maintaining
a hard copy or secure website access to
MSDS information at the district level
could be a cost-effective approach to
ensuring that chemical safety information
is available across all schools. At a
minimum, MSDS information should be
located in all chemical storage rooms and
cabinets and in a central place within the
school (away from the chemicals), as well
as a central location for the school district.
A few school districts have developed their own chemical
hygiene plans that provide step-by-step procedures, as well
as checklists for the safe handling and storage of
chemicals.
•	Northshore School District Chemical Hygiene Plan,
http://schoolcenter.nsd.org/education/components/scrapb
ook/defaultphp?cms_mode=view§iondetailid=58540
&sc_id=1161987494
*	Lake Havasu Unified School District, Arizona District
Chemical Hygiene Plan, http://www.havaB.K12.
az.us/support/warehouse/chempoiicy.him!
« LAUSD, School Laboratory Chemical Hygiene and Safety
Plan (Appendix F), http://mvw.lausd-oehs.org/docs/
CSC/Chemical%20Hygiene°/o20Plan.pdf
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III.G. Training
Proper training of staff and students on
die handling of chemicals and products
containing chemicals will help prevent
accidents, thus reducing exposure to harmful
chemicals. Training at various levels should
be provided for all school employees and
students on basic chemical hygiene, storage
and handling procedures, and how to
respond in the event of a chemical spill or
accident. Guidelines are provided below that
schools and administrators should follow on
training.
• Establish a hazardous chemicals
management and safety training program
that addresses how school employees (and
students, as applicable) are to be properly
trained to handle certain chemicals and
products and how to respond to a chemical
spill or release, to understand the hazards
of these materials, and to understand the
types of liability associated with accidents
involving chemical usage in schools.
Targeted employees should include school
management, custodial and maintenance
personnel, and appropriate teaching staff.
The training program should include a
review of the chemical hygiene plan,
hazard communication plan, and approved
products listing. Training sessions should
be documented in a log for each employee
and repeated periodically (e.g., on an
annual basis) to serve as a refresher for
existing personnel. Training also should
be conducted for new hires.
• Contact a local health department,
environmental management agency,
hazardous waste agency, or chemical
supplier to provide a training session
with school employees that raises their
awareness of using less toxic alternatives
to certain chemicals, chemical
substitutions, green purchasing, and
performing small-scale experiments.
m
Check It Out
The following resources provide useful additional information on training:
LAUSD, School Laboratory Chemical Hygiene and Safety Plan (Section III), http://www.lausd-
oehs.org/docs/CSC/Chemical%20Hygiene%20Plan.pdf
OSHA, Training Curriculum Guidelines - (Non-mandatory) -1910.120 App E,
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9770
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III.H. Hazard Communication
Environmental Planning and Community Right-to-
Know Act
The Environmental Planning and Community Right-to-
Know Act (EPCRA) was passed in response to concerns
regarding the environmental and safety hazards
associated with toxic chemicals. EPCRA establishes
emergency planning and chemical reporting
("Community Right-to-Know") requirements for Federal,
state, and local governments; Indian Tribes; and
industry. The reporting provisions help increase the
public's knowledge and access to information on
chemicals at individual facilities (such as schools), their
uses, and accidental releases into the environment. The
EPA sponsors various programs that pertain to chemical
management.
For more information see: EPA, EPCRA Information,
http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/
EPCfRA.htm?OpenDocument
Hazard communication planning is an
important element in chemical and product
management. Dissemination of information
on the quantity and hazards of hazardous
chemicals and products creates awareness
about the range of chemicals and products
used and fosters proper use and disposal of
these chemicals and products.
Guidelines are listed that schools and
administrators should follow in order to
create a safer school environment for
students and school employees.
•	Create a written hazard communication plan
that communicates how chemicals should
be properly managed, stored, handled, and
disposed. The plan should consist of an
updated chemicals and products list,
chemical labeling requirements, MSDS
information, a disposal log, and instructions
on employee training programs regarding
hazards of chemicals and protective
measures. The Appendix offers examples of
hazard communication programs that have
been implemented for various school
districts across the country.
•	Work with your local chemical supplier to
help identify specific concerns. Depending
on your location, state and/or federal
hazard communication requirements
specify your responsibility to identify and
address the hazards associated with the
chemicals and products used in your
school facility.
III.I. Spills, Cleanup, and
Disposal
Failing to take necessary safety precautions
may put your school at increased risk of fire,
explosions, and spills that may result
in chemical exposure to students and school
personnel, harm to the environment, and
considerable clean-up costs to the school
district. Hazardous wastes must be disposed
of in accordance with RCRA and other
applicable state and local requirements.
Such requirements generally prohibit any
drain disposal of hazardous chemicals or
"treatment" of hazardous wastes beyond pH
adjustment, and may be far more stringent
than the disposal suggestions provided by
chemical suppliers.
Refer to these resources as recommended guidance for creating your hazard communication plan:
•	OSHA Hazard Communication Standard, Title 29 Code of Federal Regulations 1910.1200,
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099
Reminder: Federal OSHA does not have jurisdiction over state and local government employees, including
those in public schools.
•	Section III, Summary and Explanation of the Issues and the Provisions of the Final Rule,
http://www.osha.gov/pls/oshaweb/owadisp.
•	LAUSD OEHS Hazard Communication training presentation, http://www.lausd-oehs.org/docs/CSC/
HazComPresentation.ppt
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Proper chemical disposal can reduce the
costs and management burdens associated
with excess chemicals, including disposal
costs of expired chemicals and the time
required for inventory and storage of excess
and unwanted chemicals, as well as costs of
penalties due to enforcement actions that
may result from improper chemical
management.
Guidelines are provided below that
schools and administrators can follow
in order to reduce the risk of chemical
accidents, improve spill response procedures,
and ensure that chemicals and products in
their schools are safely discarded.
• Create a written emergency response and
spill clean-up and response plan for all
chemicals and products. This plan should
describe what to do and who to contact in
the event of a spill or release, as well as the
location of spill management supplies and
equipment (e.g., spill kits, spill control
materials, fire extinguishers) within the
school. The clean-up and response plan
should include a process for
communicating with students, parents,
teachers, and other staff about the incident,
as well as methods for preventing accidents
and exposures.
Chemical Safety Day Program in Minnesota
The Chemical Safety Day Program (CSDP) is a cost-
effective waste management program available to
educational institutions and non-profit organizations
throughout the state of Minnesota. The CSDP has
helped hundreds of high schools, colleges, and
nonprofit organizations in disposing of hazardous
material/waste at a reasonable cost and in an
environmentally responsible way. More information
about the program can be found on the CSDP website
at http://www.dehs. umn.edu/csdp/.
As shown in the photo above, existing stocks of
outdated, unknown, degraded, and excessive
quantities of hazardous chemicals are present in
many schools posing safety and health risks to
students and school personnel. Identifying and
removing these chemicals is a key step in preventing
accidents. Establish a chemical disposal policy that
addresses how unused and outdated chemicals and
products containing chemicals should be properly
removed from schools.
Photo Credit: Rehab the Lab Program,
Local Hazardous Waste Management,
King County, Washington
Develop a budget for chemical
management and disposal. Initial costs
may involve hiring a chemical expert and
disposing of accumulated chemicals and
products. A longer-term waste disposal
budget should account for the staff time
necessary to develop and maintain disposal
procedures, the purchase of special
equipment and supplies, the upkeep of
safety equipment (e.g., fume hoods), and
annual hazardous chemical disposal and
staff training.
Establish a chemical disposal policy that
addresses how unused and outdated
chemicals and products containing
chemicals should be properly removed
from schools, including materials generated
from the cleanup of spills.
18
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Check It Out
The following resources may provide useful additional information in order to reduce the risk of chemical accidents,
improve spill response procedures, and ensure chemicals and products in their schools are safely discarded:
•	EPA, Hazardous Waste & Your School, www.epa.gov/ne/assistance/schools/pdfs/mefact.pdf
•	King County, Washington, Laboratory Waste Management Guide, Final Report,
http://www.govlink.org/hazwaste/publications/LabGuidelinesRevAugust06.pdf
•	Nebraska Department of Environmental Quality, Guidance Documents: School Chemicals and Disposal,
http://www.deq. state.ne.us/Publica.nsf/0/d9583aaae76ad49c8625690b007378a3?OpenDocument
•	Massachusetts Department of Environmental Protection, Massachusetts School Chemical Management
Program, Working Draft, http://www.mass.gov/dep/service/schlchem.pdf
•	Council of State Science Supervisors, Science and Safety: Making the Connection, http://www.csss-
science.org/downloads/scisafe.pdf
The U.S. National Library of Medicine's on-line Wireless Information System for Emergency Responders
(WISER) provides assistance in identifying hazardous substances, as well as spill containment advice.
See http://webwiser.nlm.nih.gov for more information.
Disposal Guidelines for School Facilities
Schools must comply with regulations regarding the management, transport, and disposal of hazardous waste.
Schools are required to track the amount of hazardous waste they generate and ensure that all wastes are properly
disposed of according to federal, state, and local requirements. These requirements can affect the way chemicals
and chemical wastes are managed in schools. Subtitle C of RCRA regulates hazardous waste generators.
According to RCRA (40 CFR Part 261), there are three categories of hazardous waste generators (large, small,
and conditionally exempt), based upon the quantity of waste they produce per month. Most schools fall into the
Conditionally Exempt Small Quantity Generator (CESQG) category. A CESQG generates 100 kilograms
(220 pounds) or less per month of hazardous waste, or 1 kilogram (2.2 pounds) or less per month of acutely
hazardous waste. EPA provides definitions of each generator category and its specific requirements at
http://www.epa.gov/epaoswer/osw/gen_trans/generate.htm; however, states may have additional requirements for
generators. Refer to these waste management and disposal resources as recommended guidance for your school:
•	EPA, Hazardous Waste Management for School Laboratories and Classrooms,
http://www.epa.gov/region8/humanhealth/children/2HWManagementToolKit.pdf
•	Idaho Department of Environmental Quality, Idaho Chemical Roundup Waste Management and Disposal at
Schools, http://www.deq.state.id.us/waste/educ_tools/chemical_roundup_waste_disposal_fs.pdf
•	Nebraska Department of Environmental Quality, School Chemicals and Disposal,
http://www.deq. state.ne.us/Publica.nsf/0/d9583aaae76ad49c8625690b007378a3?OpenDocument
•	Florida Department of Environmental Protection, Disposal Guidelines for School Facilities,
http://www.dep.state.fl.us/waste/quick_topics/publications/shw/hazardous/SC/DisposalMemoFinal.pdf
Chemical Management Resource Guide for School Administrators
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IV. Special Cases
Certain chemicals are worthy of special
consideration due to their presence in
schools and their negative impacts upon
human health and the environment. It is
important to identify potential sources of
exposure to these chemicals in schools and
to follow procedures for minimizing the risk
of such exposures. Although this section is
not all-inclusive, several examples of
chemicals that pose special risks to children
(arsenic, asbestos, lead, and mercury) are
discussed.
IV.A. Arsenic
Arsenic is a toxic heavy metal used in
products such as wood preservatives and
pesticides. Exposure to arsenic is associated
with an increased risk of bladder and lung
cancers, among other serious health effects.8
Children may be exposed to arsenic on
school grounds through contact with
materials containing arsenic compounds,
such as chromated copper arsenate (CCA).
CCA is a preservative and pesticide that was
historically used to pressure-treat lumber for
outdoor products, including playground
equipment. Children can be exposed to
arsenic by playing on CCA-treated
recreational equipment. Arsenic-
contaminated soil from playground areas
containing CCA-treated wood also can be
tracked into classrooms on shoes or
clothing.9
The likelihood that wooden playground
equipment at existing schools has been
treated with CCA is high. Though its use
was discontinued in 2003, existing stocks
of CCA-treated wood may have been sold
through mid-2004. If there is any question
as to whether wooden playsets have been
treated with CCA, it should be assumed that
Check It Out
they have.10 Exposure to CCA-treated wood
can be minimized. Children should wash
their hands thoroughly with soap and water-
immediately after outdoor play. Children
also should be discouraged from eating near
CCA-treated wood.11
O
If your school is planning to replace its
playground equipment, alternatives to CCA are
available. These alternatives include several
arsenic-free wood pressure treatments and building
material alternatives to pressure-treated wood.
EPA provides information on alternatives to CCA at
the Chromated Copper Arsenate (CCA) homepage,
http://www.epa.gov/oppad001/reregistration/cca/
index.htm#alternatives.
IV.B. Asbestos
Asbestos is a naturally occurring mineral that
was once widely used in products for its heat
resistant properties, though its uses have
diminished substantially. Exposure to
asbestos, particularly for long periods of
time, can lead to diseases such as asbestosis,
lung cancer, and mesothelioma.12 Intact,
undisturbed asbestos-containing materials
(ACMs) generally do not pose a health risk.
These materials may become hazardous if
they are damaged, disturbed, or allowed to
deteriorate and thus release asbestos fibers
into building air.
Though its use has been discontinued in
many products, ACM can be found in most
of the nation's primary, secondary, and
charter schools. Asbestos is most commonly
found in insulation and building materials
such as floor and ceiling tile, cement asbestos
pipe, corrugated paper pipe wrap, acoustical
The EPA provides links to detailed information on Chromated Copper Arsenate (CCA), its uses, and its potential
health effects on the CCA homepage, http://www.epa.gov/oppad001/reregistration/cca/.
20	Chemical Management Resource Guide for School Administrators

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and decorative insulation, pipe and boiler
insulation, window caulking, spray-applied
fireproofing, and plaster walls in older-
schools. Asbestos has also been used in
laboratory gloves, laboratory hoods, and
chalkboards.13 Some of these products remain on
the market.
Federal requirements for asbestos
management in schools were established by
the Asbestos Hazard Emergency Response
Act (AHERA) of 1986, which requires public
school districts and non-profit private
schools to inspect buildings for asbestos;
develop plans to manage any asbestos found
in these buildings; and carry out management
plans in a timely fashion.14 Damaged ACM
may be managed through repair; various
containment methods; or, in cases where
loose fibers are present, proper removal. It is
important to note that AHERA only applies
to building materials. No regulations govern
the purchase or use of certain asbestos-
containing products, such as laboratory
gloves, in schools.15 EPA recommends that
asbestos-free versions of these products be
purchased for use in schools, along with
proper disposal of existing asbestos-
containing materials.
IV.C. Lead
Lead is a highly toxic metal once widely used
in products like paint, gasoline, solder, pipes,
plumbing, and construction materials. Other
sources of lead in the environment include
lead from industrial emissions. Exposure to
lead occurs when it enters the body through
inhalation or ingestion of lead dust, particles,
or chips. Lead can cause serious damage to
the brain, nervous system, kidneys, and red
blood cells. Young children, especially those
6 years and younger, are at particular risk for
lead exposure because they have frequent
hand-to-mouth activity and absorb lead more
easily than do adults. Even at low levels, lead
can cause children to have learning and
behavior problems, delays in physical growth,
and lower IQs.
In schools, lead is most commonly found in
the paint, dust, soil, and water. Some schools
may have other sources of lead, such as art
and photography supplies, pottery glazes, and
science lab materials. Consider reducing the
use of lead in science experiments and, where
it must be used, only use it in dilute solutions
that are captured and properly disposed.
Lead paint hazards are of special concern in
areas occupied by children. In 1978, the
Consumer Product Safety Commission
banned the use of lead in paint; therefore,
lead-based paint is limited to older school
buildings. These buildings and the
surrounding soil can be contaminated by
flaking paint chips or dust. The only way to
know for sure whether your school has lead-
based paint is to have the paint and soil
tested for lead by a state-certified lead
inspector.
Asbestos in Schools
EPA's The ABCs of Asbestos in Schools (available at
http ://www.epa .gov/asbestos/pubs/abcsfinal .pdf) answers
common questions about asbestos in schools and outlines
the responsibilities of school boards and other school
officials to protect children and employees from exposure
to asbestos.
Lead in Paint, Dust, and Soil:
•	EPA, Rules and Regulations, http://www.epa.gov/lead/pubs/regulation.htm
Lead in Drinking Water in Schools:
•	EPA, 3Ts for Reducing Lead in Drinking Water in Schools, http://www.epa.gov/safewater/schools/pdfs/lead/
toolkit_leadschools_guide_3ts_leadschools.pdf
•	EPA, Guidance and Tools, http://www.epa.gov/safewater/schools/guidance.html
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A Mercury Spill in Washington, D.C.
"On October 2,2003, the Washington, D.C.'s Fire
Department Hazmat Unit responded to an emergency call
unlike any call Ballou High School had ever had to make.
What the D.C.'s Hazmat unit found that afternoon proved to
be the beginning of a long, exhausting search for and clean
up of an elemental mercury spill. By the time the D.C.
Hazmat Team and the D.C. public health officials arrived,
it was too late to contain all the spills; varying amounts of
mercury were found in the classrooms, gymnasium, and
cafeteria. Contamination did not stop there. Students
unknowingly carried mercury through the streets, onto city
and school buses, and into their homes. As a result of the
spill, Ballou High School was closed for 35 days and over
200 homes were tested for mercury contamination."
For additional information, see EPA's Superfund
Featured News Article, http://www.epa.gov/
superfund/news/mercury.htm
Lead can also leach into drinking water from
pipes, solder, or brass plumbing fixtures.
There is no federal law requiring sampling of
drinking water in schools that are served by a
public water system, although schools and
local jurisdictions may establish programs for
testing drinking water lead levels in schools.
EPA and others have issued guidance
designed to help schools develop and
implement a sampling protocol to test for
lead in their drinking water.16'17'18'19
IV.D. Mercury
Mercury is a naturally occurring element used
to make many consumer products. Exposure
to high levels of mercury, as would occur
with the direct inhalation of mercury vapor
released during a mercury spill, is associated
with damage to die brain, heart, kidneys,
lungs, and immune system.20 While the
general public can clean up small mercury
spills no greater than die amount contained
in a single fever diermometer following
proper instructions, larger spills must be
cleaned up by professionals.21 In fact, when
a spill of more dian two tablespoons of
mercury occurs, it is mandatory to call the
National Response Center (800-424-8802).22
Science classrooms and storerooms often
contain elemental mercury or mercury
compounds used as laboratory reagents.
Science classes also may use mercury
diermometers, or odier mercury-containing
laboratory instruments such as barometers
(pressure gauge for measuring die pressure of
die atmosphere). These all create significant
risks of mercury spills, particularly if students
have access to them. There is no need for
science classrooms to use diese chemicals
or devices; there are safe, non-mercury
Schools should not use or store elemental
mercury or mercury compounds. They should
replace all mercury thermometers and manometers
with mercury-free products. Mercury must be
disposed of properly.
replacements for all of them. In addition,
nurses' offices often contain mercury fever
diermometers and sphygmomanometers
(blood pressure measuring devices), which
also pose spill risks because diey are easily
breakable. EPA encourages schools to
prevent spills by removing all elemental
mercury, mercury compounds, and mercury
measurement devices from classrooms and
nurses' offices.
Mercury is also used in many of die types of
items diat are found in all buildings, such as
diermostats, flow meters, boiler controls,
and electrical equipment. Generally, such
equipment poses litde risk of spill because
die mercury is not easily accessible and the
products are not easily broken. However,
such equipment needs to be disposed of
properly at die end of its life, and new
equipment should be mercury free. School
building maintenance staff should inventory
mercury-containing equipment, properly
dispose of it when it comes out of service,
and implement mercury-free purchasing
policies. Maintenance staff should also not
use, and instead properly dispose of, any
remaining stores of old janitorial supplies,
such as latex paints (prior to 1992) and
pesticides (prior to 1994), because diese may
contain mercury.23
22
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Schools should continue to use one category
of mercury-containing product — fluorescent
lamps. There is currently no alternative to
mercury-containing fluorescent lamps that is
as energy efficient and that is appropriate for
general indoor lighting. The energy
efficiency of fluorescent lamps makes them a
good environmental choice because of less
emissions of mercury and other pollutants
from power generation. However, while the
amount of mercury in each lamp is small,
schools use significant numbers of lamps,
and these must be disposed of properly.
Contact your EPA Regional Office, the EPA
RCRA hotline at (800-424-9346), or your
state agency to confirm the most current
rules and information on fluorescent lamp
waste management and disposal in your state.
Chemical Management Resource Guide for School Administrators
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V. Conclusion
Chemicals are used daily in both the
maintenance of schools and the curriculum
taught. They help students to perform
experiments and learn new skills, among
other benefits. They are important to many
aspects of school maintenance. In the
absence of chemicals, schools would lack
certain fundamental tools needed to educate
students. Despite their useful purposes,
chemicals can be dangerous to students and
staff when managed improperly. Some
chemicals that are persistent in the
environment and bioaccumulate through the
food chain can make exposure during
childhood and adolescence especially
dangerous. Ensuring that chemicals are
properly managed will help school
administrators to safeguard the health and
safety of students and school employees;
avoid disposal expenses and school closures
associated with spills and emergency
incidents; maintain a sense of trust between
the district and the surrounding community;
and prevent unintended discharges and spills
which inflict damage upon the environment.
Consistent policies and practices are
recommended in all school systems:
•	Appoint responsible leadership and
institute "team training" regarding best
practices of chemical and product
management.
•	Support chemical management effort with
appropriate budget.
•	Share your experiences with other districts
and administrators.
•	Purchase safer alternatives to hazardous
substances.
•	Adopt policies encouraging proper
purchasing, labeling, storage, and disposal
of chemicals and products.
•	Train faculty and staff (and students, as
applicable) on the potential dangers posed
by chemicals and on alternatives that are
less hazardous that may be available.
•	Disseminate information on reducing the
quantity and hazards of hazardous
chemicals and products.
When implemented effectively, chemical
management promotes awareness about the
range of chemicals and products used in
schools and creates a healthier and safer
atmosphere for school occupants and the
surrounding environment. For additional
information, contact your EPA Regional
Office or consult on-line resources to
understand environmental health issues in
schools, such as EPA's SC3 and EPA's
HealthySEAT. The ultimate purpose of the
SC3 is to reduce chemical exposures and
improve chemical management in K-12
schools, while HealthySEAT can be
customized to assist school districts in the
evaluation and management of all of their
environmental, safety, and health issues,
including all aspects of their chemical
management programs.
Check It Out
EPA Resources for Additional Information
Schools Chemical Cleanout Campaign (SC3), http://www.epa.gov/sc3/
Healthy School Environments Assessment Tool (HealthySEAT), http://epa.gov/schools/healthyseat/
24
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References
1	EPA. 2006. Case Study — Environmental, Health & Safety Issues in One New England Public High
School, Summary 1996. Available at http: / /www.epa.gov/region 1 /assistance /schools /health.html
[Accessed March 24, 2006].
2	University of Wisconsin-Extension. 2004. Why Focus on Mercury in Schools? Available at
http: / /www.mercuryinschools.uwex.edu/schools /why.htm [Last updated July 15, 2004; Accessed
May 23, 2006],
3	EPA. 2006. What is the TSCA Chemical Substance Inventory? Available at
http: / /www.epa.gov/opptintr/newchems /pubs /invntory.htm [Last updated March 3, 2006].
4	National Institutes of Health, National Library of Medicine. 2004. Household Products Database
Frequently Asked Questions. Available at http: //householdproducts.nlm.nih.gov/faq.htm#7 [Accessed
April 26, 2006],
5	Maryland State Department of Education. 1999. Science Safety Manual: Chapter VII. Chemicals:
Managing, Handling and Disposing. Available at http: //www.mdkl2.org/instruction/curriculum/
science /safety /chemicals .html [Accessed April 6, 2006].
6	Executive Order 13101— Greening the Government Through Waste Prevention, Recycling, and Federal
Acquisition. September 14,1998, available at http://www.ofee.gov/eo/ 13101.htm.
7	Maryland State Department of Education, http: / /www.mdkl2.org/instruction /curriculum/science /
safety /chemicals .pdf.
8	U.S. Consumer Product Safety Commission. 2006. Chromated Copper Arsenate (CCA) — Treated
Wood Used in Playground Equipment Fact Sheet. Available at: http: //www.cpsc.gov/phth/ccafact.html
[Accessed April 5, 2006].
9	Shendell, D., C. Barnett, and S. Boese. 2004. Science-based recommendations to prevent or reduce
potential exposures to biological, chemical, and physical agents in schools, Healthy Schools Network, Inc.
[Available at http: /Zwww.healtliyschools.org/documents /HPSchlsWhtPpr.pdf].
10	U.S. Consumer Product Safety Commission. 2006. Chromated Copper Arsenate (CCA) -Treated Wood
Used in Playground Equipment Fact Sheet. Available at: http: ZZwww.cpsc.govZphthZccafact.html
[Accessed April 5, 2006].
11	U.S. Consumer Product Safety Commission. 2006. Chromated Copper Arsenate (CCA) -Treated Wood
Used in Playground Equipment Fact Sheet. Available at: http: ZZwww.cpsc.govZphthZccafact.html
[Accessed April 5, 2006].
12	EPA. 2006. Asbestos and Schools. Available at: http: Z Zwww.epa.govZasbestos Zpubs Z
asbestosinschools.html#5 [Accessed April 5, 2006].
13	EPA. 2006. Where Can Asbestos Be Found? Available at: http: Z Zwww.epa.govZasbestos Zpubs Z
asbuses.pdf [Accessed April 5, 2006].
14	EPA. 2003. The ABC's of Asbestos in Schools. Available at http: Z Zwww.epa.govZasbestos Zpubs Z
abcsfmal.pdf [Revised August 2003; Accessed October 4, 2006].
15	Phil King, U.S. EPA Region Y Asbestos Coordinator. 2006. Personal communication
[February 24, 2006].
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University of California at Berkeley. 2000. Working in a Lead-Safe School, Facts for School
Maintenance Workers. Available at http://ist-socrates.berkeley.edu/~lohp/graphics/pdf/
LEADSAFE.PDF [Accessed May 30, 2006],
EPA. 2006. Lead in Paint, Dust, and Soil. Available at http: //www.epa.gov/lead/index.html
[Accessed May 16, 2006].
EPA. 2006. 3Ts for Reducing Lead in Drinking Water in Schools. Available at http://www.epa.gov/
safewater/schools/pdfs/lead/toolkit leadschools guide 3ts leadschools.pdf [Accessed May 26, 2006].
EPA. 1994. Lead in Drinking Water in Schools and Non-Residential Buildings. Available at
http://www.epa.gov/safewater/consumer/pdf/leadinschools.pdf [Accessed May 30, 2006].
EPA. 2006. Mercury - Basic Information. Available at http: / /www.epa. gov /mercury /
about.htm#sources [Accessed April 5, 2006].
EPA. 2006. Mercury - Spills, Disposal, and Site Cleanup. Available at http://epa.gov/mercury/
dispo sal .htm# SPILLS [Accessed April 5, 2006].
EPA. 2006. Environmental Emergencies. Available at http: //www.epa.gov/epaliome /emergenc.htm
[Accessed November 1, 2006].
University of Wisconsin Extension's Solid and Hazardous Waste Education Center. 2003. Wiere is
Mercury in Schools? Available at http: //www.mercurvinschools.uwex.edu/schools /where.htm
[Accessed April 5, 2006].
LAUSD, OEHS. 2005. LAUSD Approved Chemicals List (Inventory List). Available at
http: / / www.lausd-oehs.org/ docs / CSC / Combined%20Chemical%20Inventory.pdf
[Accessed April 5, 2006].
Californians for Alternatives to Toxics. 2006. Model School IPM Policy. Available at
http: //www.alternatives2toxics.org/pdfs /sampleIPMpolicv.pdf [Accessed April 4, 2006].
LAUSD, OEHS. 2005. School Laboratory Chemical Hygiene & Safety Plan. Available at
http: //www.lausd-oehs.org/docs /CSC/Chemical%20Hygiene%20Plan.pdf [Accessed April 5, 2006].
U.S. Centers for Disease Control and Prevention, Office of Health and Safety. 2000. Chemical Storage
Guidelines. Available at http: //www.cdc.gov/od/ohs /ENVIRONM/khemstore.htm
[Accessed April 28, 2006].
Rhode Island Department of Health and Department of Elementary and Secondary Education. 1964
(as amended, through 2005). Rules and Regulations for School Health Programs. Available at
http: //www.rules.state.ri.us /rules /released/pdf/DOH/DOH 3592.pdf [Accessed April 5, 2006].
Washington Department of Health and Office of Superintendent of Office of Public Instruction.
2003. Healtli and Safety Guide for I-C-12 Schools in Washington, 2nd Edition. Available at
http: / / www.kl2.wa .us /SchFacilities / pubdocs /SafetyManual2002-2003 / CompleteSafety&
HealthManual2002-2003.pdf [Accessed April 27, 2006].
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Appendix
Chemical Hygiene and Management Plans
Responsible chemical management and hazard communication procedures help to minimize the
risk of accidental exposures in schools. Chemical hygiene or management plans provide
guidelines for handling chemicals in schools using tools such as inventory lists (see example below,
extracted from an existing inventory list24).
LAUSD APPROVED CHEMICALS LIST (INVENTORY LIST)
School/Site:		Room No.:
Name: 		Time Spent:
Signature: 		Date:






Total Quantity



Material
Safety




GM=grams,
KG=kilograms,



Data



Total
LB=pounds,

Expired
1 Chemical

Sheet
Compatible
Hazard Health
i!Itl
Number of
OZ=ounce,
Shelf Life
Chemical
| Name
| Manufacturer |
Yes/No
| Storage
Effects
Containers
CC, liter
| (Months)
Yes/No
Gram's Iodine
Stain= Iodine
Solution, Gram


I-2
Poison, Human
mutation data
reported,
Experimental
reproductive effects.
3


1-10

Gypsum
CaSCU.xbhO


I-2
See Hazard Ratinq
(HR)
1


1-10

lodeosin
C20H8I4O5


I-2
Poison, Human
mutation data
reported,
Experimental
reproductive effects.
3


1-10

**** Iodine
(crystals)
(PEL 0.1 ppm)


I-2
Poison, Human
mutation data
reported,
Experimental
reproductive effects.
3


1-10

Iodine Solution


I-2
Poison, Human
mutation data
reported,
Experimental
reproductive effects.
3


1-10

Lithium
Chloride LiCI


I-2
Poison, Human
mutation data
reported,
Questionable
carcinogen,
Experimental
neoplastigenic,
teratogenic and
reproductive effects.
3


1-10

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Check It Out
Examples of school chemical hygiene/management plans and associated resources include:
•	Maine Department of Labor, Sample Chemical Hygiene Plan for Maine Schools,
http://www.safetyworksmaine.com/safe_workplace/sample_programs/school_chemical_hygiene_plan.htm
•	Maine Department of Environmental Protection, Scientific Lab Chemical Inventory spreadsheet,
http://www.maine.gov/dep/mercury/chemical_inventory_list.xls
•	Colorado Department of Public Health and Environment, Guidance on Chemical Management in Schools,
http://www.cdphe.state.co.us/cp/lnstitutions/Schools/Chems%20ln%20Schools/ChemMgmt.html
•	Massachusetts Department of Environmental Protection, Massachusetts School Chemical Management
Program, http://www.mass.gov/dep/service/schlchem.pdf
•	Illinois State Board of Education, Chapter 12 of the Guidebook for Science Safety in Illinois,
http://www.isbe.net/ils/science/pdf/science_safety.pdf
•	EPA, Chemical Management and Usage, http://www.epa.gov/Region7/education_resources/
teachers/ehsstudy/ehsl .htm
Hazard Communication Programs also have been implemented in various school districts:
•	Putnam City Schools (Oklahoma) - Hazard Communication Standard,
http://www.putnamcityschools.org/pageid333.html
•	Penasco Independent School District (New Mexico) - Hazard Communication Program,
http://www.penasco.k12.nm.us/policies/10_12.htm
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Sample Guidelines
In addition to preparing comprehensive management plans, many school districts throughout the
U.S. have implemented other types of guidelines, such as integrated pest management (IPM)
policies, to minimize the use of toxic chemicals. An excerpt adapted from a sample policy
developed for use by California schools is shown below:25
Model School IPM Policy
A.	Policy Statement
The {insert name} School District recognizes that the maintenance of a safe, clean, and healthy environment for
students and staff is essential to learning. It is the goal of the District to provide the safest and lowest risk approach
to control pest problems, while protecting students, staff, the environment, and district property.
The District hereby adopts a Least-Toxic Integrated Pest Management (IPM) policy. This policy shall focus on
long-term pest prevention and give non-chemical methods first consideration when selecting appropriate control
techniques. The full range of alternatives, including taking no action, will be considered first, with chemical controls
used as a last resort. Preference will be given to chemicals and methods of application that pose the least hazards
to people and the environment. The District's long-term goal is the elimination of all chemical pest control methods.
B.	Role of the IPM Coordinator
The IPM coordinator shall be named to coordinate the district's efforts to adopt IPM techniques, and shall be
provided with training on least toxic pest management practices. Specific responsibilities include:
•	Overall program management and providing proposed regulations or procedures and products for use in
managing pest populations
•	Education and training for IPM personnel
•	Formal annual notification to parents, staff, and students of any potential chemical pesticide application
•	Posting of warning signs for all pesticide applications
•	Establishment and maintenance of a registry of parents, staff, and students who have indicated a desire for prior
notification of each pesticide application
•	Advance notification for individual pesticide applications
•	Recordkeeping for any chemical pesticide application
C.	Pesticide Product Selection and Use Approval
Selection of pesticide products will be based on the IPM coordinator's review of the product's contents, precautions,
and adverse health effects. The IPM Coordinator will prioritize the use of the following nontoxic products:
1. Approved Products
Mechanical or Biological Products
•	Caulking agents and crack sealants
•	Physical barriers
•	Electronic products, heat, and lights
Chemical Products
•	Soap-based products
•	Borates, silicates, and diatomaceous earth
•	Insecticide or rodenticide self-contained baits and traps
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Check It Out
For more information on IPM in schools, visit:
•	EPA, Integrated Pest Management (IPM) in Schools, http://www.epa.gov/pesticides/ipm/
•	EPA, Pesticides: Controlling Pests, Storing Pesticides, http://www.epa.gov/pesticides/ipm/brochure/steps6-7.htm
•	California Department of Pesticide Regulation, Model Program Guidebook, 2nd Edition,
http://www.cdpr.ca.gov/cfdocs/apps/schoolipm/managing_pests/guidebook.cfm
•	University of Florida/EPA, National School IPM Information Source, http://schoolipm.ifas.ufl.edu/
•	Texas A&M University/EPA, IPM Resource Center for Schools and Childcare Facilities,
http://schoolipm.tamu.edu/
•	Massachusetts Natural Resources Collaboration, IPM Tools & Resources, http://massnrc.org/ipm/schools-
daycare/ipm-tools-resources.html
•	Minnesota Department of Agriculture, Management of Pesticides, www.mda.state.mn.us/ipm/fspesticides.pdf
•	National Pesticide Information Center, http://npic.orst.edu/
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Checklists
Checklists are often used to clearly identify chemical management actions and to verify that they
have been completed (see basic example below, an excerpt adapted from the Los Angeles Unified
School District "School Laboratory Chemical Hygiene & Safety Plan"26).
LOS ANGELES UNIFIED SCHOOL DISTRICT
MONTHLY CHECKLIST FOR SAFE HANDLING AND STORAGE OF CHEMICALS
	To be completed by C.S.C.	
ACTIVITY

1. All chemicals are correctly and clearly labeled.


2. Unlabeled containers and chemical wastes have been inventories and a disposal request submitted to OEHS.


3. Only chemicals that are being used are continually being stored.


4. Only the amount of chemicals which can be consumed within a year are being stored.


5. CSC is aware of and has trained others on hazards and precautions for protection prior to using any chemical,
and has reviewed the precautionary labels and contents before using any chemical product.


6. All chemicals are stored by compatibility (see CHSP Appendix IV, Table 1: Chemical Shelf Storage
Identification Chart and Table 2: Storage for Compatibility Categories).


7. Chemicals are stored on shelves below eye level.


8. Chemicals are being stored on the floor.


9. Chemicals are being stored in approved storage cabinets.


10. Neutralizing chemicals, absorbent and other spill control materials are readily available.


11. Compressed gas cylinders are upright and secured to the wall with caps in place.


12. Storage cabinets for corrosive chemicals (separated for acids and for bases) are appropriately labeled.


13. Flammable materials are stored in approved storage cabinets.


14. Shelving is equipped with lips to prevent products from rolling off shelves and secured to walls/floor to prevent
tipping of entire sections.


15. Storage areas/cabinets are labeled to identify the hazardous nature of the products stored within.


16. Class ABC fire extinguishers are available in chemical storage areas and are in working order.


17. There are no sources of ignition in the chemical storage area.


18. Chemical storage area has two exits and egress (exiting) area is clear.


19. Used and contaminated reagents are stored and labeled properly.


20. Current and dated inventory lists are posted clearly in each storage room throughout the science department.


21. Chemical storage cabinets are locked when laboratory classes are not in session.


Certification: I hereby certify that I have completed all of the above activities in fulfillment of my responsibilities as the Chemical Safety
Coordinator (CSC) for my school.
Date	School
CSC Signature	CSC Name (print)
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Check It Out
Additional checklists are available at:
•	EPA, HealthySeat Assessment Checklist,
http://www.epa.gov/schools/healthyseat/AssessmentChecklist_Blank.pdf
•	National Institute for Occupational Safety and Health, NIOSH Safety Checklist Program for Schools,
http://www.cdc.gov/niosh/docs/2004-101/default.html
•	Massachusetts Healthy Schools Council, Checklist Concerning Environmental Health & Safety in Schools,
http://mass.gov/Eeohhs2/docs/dph/environmental/iaq/schools_checklist.pdf
•	Washington Department of Health and Office of Superintendent of Office of Public Instruction, Health and Safety
Guide for K-12 Schools in Washington (Part II), http://www.k12.wa.us/SchFacilities/HealthSafetyGuide.aspx
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Chemical Purchasing, Storage, and Design Guidelines
Chemical purchasing, storage, and design guidelines have been developed by many school districts and
state agencies in an effort to eliminate unnecessary purchases of hazardous substances and avoid dangerous
storage scenarios. General chemical storage principles are illustrated in the following example, adapted from
the U.S. Centers for Disease Control and Prevention, Office of Health and Safety's Chemical Storage
Guidelines:27
1 Class of Chemical H Recommended Storaqe Method 1
| Examples |
| Incompatibilities 1
Compressed gases -
Flammable
Store in a cool, dry area, away from oxidizing gases.
Securely strap or chain cylinders to a wall or bench.
Methane, Hydrogen,
Acetylene, Propane
Oxidizing and toxic
compressed gases,
oxidizing solids
Compressed gases -
Oxidizing
Store in a cool, dry area, away from flammable
gases and liquids. Securely strap or chain cylinders
to a wall or bench.
Oxygen, Chlorine,
Bromine
Flammable gases
Compressed gases -
Poisonous
Store in a cool, dry area, away from flammable
gases and liquids. Securely strap or chain cylinders
to a wall or bench.
Carbon monoxide,
Hydrogen sulfide,
Nitrogen dioxide
Flammable and/or
oxidizing gases
Corrosives - Acids
Store separately in acid storage cabinet. Segregate
oxidizing acids (i.e., Chromic, nitric, sulfuric, and
perchloric acids) from organic acids.
Acetic acid, Phenol,
Sulfuric acid,
Chromerge, Nitric acid,
Perchloric acid,
Chromic acid,
Hydrochloric acid
Flammable liquids,
flammable solids,
bases, oxidizers
Corrosives - Bases
Store in separate corrosive storage cabinet. Store
solutions of inorganic hydroxides in labeled
polyethylene containers.
Ammonium hydroxide,
Sodium hydroxide,
Calcium hydroxide
Flammable liquids,
oxidizers, poisons,
acids
Flammable Liquids
Store in flammable storage cabinet and away from
sources of ignition. Store highly volatile flammable
liquids in an explosion-proof refrigerator.
Acetone, Benzene,
Diethyl ether, Methanol,
Ethanol, Toluene,
Glacial acetic acid
Acids, bases,
oxidizers, poisons

Check It Out
Consult the following resources for more information on chemical storage, purchasing, and design:
•	Californian Department of Environmental Health Hazard Assessment, Art Hazards,
http://www.oehha.ca.gov/education/art/index.html
•	King County, Washington, Rehab the Lab, http://www.govlink.org/hazwaste/schoolyouth/rehab/index.htm and
http://www.epa.gov/epaoswer/osw/conserve/2004news/03-labs.htm
•	Iowa Metro Waste Authority, Rehab the Lab (Hazardous Materials), http://www.metro-waste.com/sch_reh.html
•	EPA, Healthy School Environment Resources: Chemical Purchasing,
http://cfpub.epa.gov/schools/top_sub.cfm?t_id=361&s_id=363
•	Massachusetts Department of Environmental Protection, Massachusetts School Chemical Management
Program, http://www.mass.gov/dep/service/schlchem.pdf
•	Commonwealth of Massachusetts, Environmentally Preferable Purchasing Program, Product & Service
Information, http://www.mass.gov/epp/products.htm
•	Illinois EPA and Waste Management Resource Center, Greening Schools homepage,
http://www.greeningschools.org/
•	Maryland State Department of Education, Science Facilities Guidelines, Chapter 5: Design Considerations,
http://www.mdk12.org/instruction/curriculum/hsa/science_facility/chapter5.html
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Use of Chemicals in Schools
Some states have taken regulatory actions to limit the use of chemicals in schools. For example, Rhode
Island28 prohibits the use of listed chemicals in schools (see excerpts from Rhode Island's list below). The
State of Washington's Department of Health and Office of Superintendent of Public Instruction also have
published a tiered list of chemicals: (1) unsuitable for use (see Appendix D, Table 1 of their guide) in K-12
schools due to excessive risk that exceeds their educational utility, and (2) appropriate only for advanced-level
high school science classes due to high risk and limited to small- or micro-scale quantities (see Appendix D,
Table 2 of their guide).29 Furthermore, chemicals that are allowed in schools may vary across districts for
different reasons (e.g., staff experience, training).
¦ Full Chemical Name ¦ CAS # ¦ Reference 1
1 -(2-tert-Butylperoxy isopropyl)-3-isopropenylbenzene
96319-55-0
49CFR173.225
1 -(o-Chlorophenyl)thiourea
5344-82-1
EPA Acutely Toxic (P Listed)
1,1-Di-(tert-amylperoxy)cyclohexane
15667-10-4
49CFR173.225
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane
6731-36-8
49CFR173.225
1,1 -Di-(tert-butylperoxy)cyclohexane
3006-86-8
49CFR173.225
1,1 '-Diazoaminonaphthalene

DOT Forbidden
1,1 -Dimethyl-3-hydroxybutylperoxyneoheptanoate

49CFR173.225
1,2,3-Propanetriol, trinitrate (R)
55-63-0
EPA Acutely Toxic (P Listed)
1,2,4-butanetriol trinitrate

DOT Forbidden
Benzene
71-43-2
Reproductive Toxin, Select Carcinogen
benzene diazonim chloride

DOT Forbidden
Benzene sulphohydrazide
80-17-1
49CFR 173.224
benzene triozonide

DOT Forbidden
Benzene, (chloromethyl)-
100-44-7
EPA Acutely Toxic (P Listed)
carbazole
86-74-8
IARC List of Known and Suspected
Human Carcinogens
Carbonic dichloride
75-15-0
EPA Acutely Toxic (P Listed)
carrageenan
9000-07-1
IARC List of Known and Suspected
Human Carcinogens
chlordane
57-74-9
IARC List of Known and Suspected
Human Carcinogens
dichloromethane
75-09-2
IARC List of Known and Suspected
Human Carcinogens
Dieldrin
60-57-1
EPA Acutely Toxic (P Listed)
guanyl nitrosaminoguanylidene hydrazine

DOT Explosive
hexanitrodiphenylamine
131-73-7
DOT Explosive
Isopropyl Ether
108-20-3
Peroxidizable
Lead and lead compounds
7439-92-1
Reproductive Toxin
Methyl chloromethyl ether
107-30-2
OSHA Listed Chemicals
Methyl ethyl ketone peroxide
1338-23-4
49CFR173.225
Check It Out
Other states that have passed regulations related to chemicals in schools:
Colorado Department of Public Health and Environment, Rules and Regulations Governing Schools in the State
of Colorado, http://www.csmate.colostate.edu/cltw/Colorado_Rules.pdf
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Leadership and Resources
Pollution Prevention and Greener Alternatives
Chemical and Product Management
Chemical Inventory
Purchasing
d Handling
Training
Hazard Communication
Spills, Cleanup, and Disposal
ff q\
I wS
United States Environmental Protection Agemy
Office of Pollution Prevention and Toxics, (7409-M)
Washington DC 20460
Official Business
Penalty for Private Use f 300
EPA 747-R-06-002
December2006

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