Administrators Chemical Hygiene Training
A brief introduction to administration responsibilities
The following was developed as an
in-district experiment to determine if reasonable training of Sequim school administrators might be conducted via the internet. A discussion among state Chemical Hygiene experts suggested that current federal and state statute essential requires the training of administrators [as well as science teachers and maintainance staff] to assure compliance.
The following explains why schools have hazardous chemicals, and what responsibilities administrators have for these materials and their use.
As the institution responsible for preparing people for adult lives, it is critical that schools teach about the most common hazards and prepare people to safely deal with those hazards. Humans are made of chemical substances, we must consume chemical substances to grow and survive, and the world in which we must live and work is composed of chemical substances. While hazards differ, every chemical substances is somewhat hazardous. Consider oxygen,
continuously needed for our survival: it is one of the most corrosive substances known. It is involved in most fires resulting in countless damage and loss of life. Even breathing pure oxygen may cause lung damage. And water, the major component of our bodies, contributes to many drownings each year. Occasionally it has been reported that people have drank sufficient quantities of water to cause death. There are a wide diversity of substances that we deal with
daily that have other hazards. People need to learn about the hazards and how to safely work with the substances.
Like any skill, working safely with hazardous materials is most effectively learned by practice. Just as sports teams do not learn skills exclusively by textbook, schools need to provide students with
hands on experiences with hazardous materials.
Schools are governed by the same federal and state statutes that apply to industries that work with hazardous materials. The Superintendent is named as responsible for assuring that all employees receive adequate and appropriate training for dealing with any chemical hazard they may encounter as an employee. That responsibility is partly delegated to other administrators and to a Chemical Hygiene Officer who is an expert hired to advise and assist the
Superintendent. As an administrator, you are obligated to insure that every employee you supervise receives adequate, appropriate training upon hiring, that they receive at least annual training updates and reviews, and that they follow safe and appropriate procedures at all times.
While federal and state laws specify training and protection for employees, they are generally silent about students. But it is generally assumed that legal liability will be extended by lawsuit and court rulings to include training and protecting students as well as employees.
Because schools and other laboratories deal with smaller quantities of hazardous materials than most industries, and because schools often work with a much wider variety of hazardous materials than each particular industry, a special section of statute allows and requires commercial and industrial laboratories, colleges, and K-12 school systems to develop, adopt, and enforce their own Chemical Hygiene Plan consistent with all statutes. There are
large fines for even minor omissions and failures to comply that have been widely enforced on industry, but only recently enforced on universities. As time permits, it can be anticipated that K-12 schools will be inspected and fined as appropriate. Traditionally the large fines are reduced, but not eliminated, if all deficiencies are corrected within HOURS. Because fines are large compared to school operating budgets, it would be prudent to assure compliance with statute
All Sequim secondary science teachers have been asked to complete annual surveys as required by law to assess deficiencies in their laboratories. Most, but not all science teachers have complied. On the 60 item checklist, every teacher responding found multiple deficiencies, most of which will require action by administrators and or maintenance staff. A summary report has been sent to the Superintendent.
Annual inventories of all hazardous laboratory chemicals has been requested of each school as required by law. Only the high school has provided inventories to the CHO. Presumably copies of school chemical inventories are simultaneously provided to the school principal.
All secondary science teachers have been provided Chemical Hygiene/Laboratory Safety training via e-mail. Each lesson included testing to assure completion of the assignment and adequacy of the training. Most teachers have responded to most assignments, but some have not. A summary report has been sent to the Superintendent. Training files are kept for each employee as required by law.
The Chemical Hygiene Officer has no enforcement authority. Because District and presumably School funds are at risk, it is crucial that administrators in each school insure that their staff and facilities are in full compliance with statute. Timely and 100% effective mechanisms need to be established to solve compliance problems identified by employees but beyond that employee's authority to fix. It is inappropriate to find employees finding the
same deficiency on successive annual surveys when statute is generally interpreted by inspectors as requiring deficiencies be eliminated within hours of identification.
As elementary grades begin to implement
hands on science it becomes necessary to insure adequate training for all elementary teachers using any potentially hazardous material (i.e., every teacher of science), and insure compliance of procedures and facilities with all applicable statutes. If a school decides that no hazardous materials will be used in that school, it may be prudent to ask why the materials used for teaching are thought to have no hazards!
(E.g., are paper and textbooks not flammable?) Presumably hazards will be much less at the elementary grades that in secondary schools so less training will be needed, but it is probably FALSE to assume that NO HAZARD EXISTS. If science is to be taught in each classroom, appropriate locked storage, eye goggles, eye washes, and emergency showers may be needed depending on each grade's curriculum.
As a minimum, each administrator should have read, be familiar with, and insure compliance with the District Chemical Hygiene Plan. It is available at SequimScience.com
Under separate statute the District is also required to develop and implement plans for dealing with hazardous wastes and accidents. Administrators need to be sure of District and building compliance with those statutes as well.
The following questions are designed to verify the effectiveness of your training and your preparedness to meet hazard responsibilities. Please e-mail your answers to
Your answers will be placed in a file as required by law to document training you have received. You may amend your responses later if desired. (Suggestion: Highlight all questions below, then select to COPY. Click on the e-mail link above to open an e-mail window, PASTE in the questions, then add answers before SENDING.)
- Why have hazardous materials at your school?
- What is at risk if your school does not comply with all Hazardous Material regulations?
- What procedure guarantees that if a deficiency is identified by a student or employee in your school, that the deficiency will be promptly fixed?
- From the CHP: When must students and employees wear eye protection goggles?
- What happens in your school if a student or employee does not wear eye protection when required by law?
- What procedure is followed if a flammable liquid is accidentally spilled on a classroom floor? Is the procedure the same for all quantities from a drop to a quart?
- What assurance do you have that students and employees know and will follow the above school procedures?