The well being of thousands of students, staff and visitors in our public schools depends on a well organized and consistent EHS compliance program. This is not news to District Facility Managers that deal with a multitude of regulations and problems every day. It’s a tough job and only the strong survive! But the best Facility Managers know that they can’t do it alone. They need cooperation and support throughout the District, starting with the Board of Education, and including administrators, teachers and even parents. Since many regulations are highly technical, EHS Consultants often play an important role.
When do Facility Managers get involved in science labs?
- Spills and other emergencies.
- Repair and/or upgrade of safety equipment and engineering controls, i.e. lab fume hoods.
- Planning for lab renovations, building repairs.
- Routine maintenance and cleaning.
- Planning for hazardous chemical or waste disposal.
GSE’s compliance practice has taken us to Districts throughout the State of New Jersey. We have found that while there are many very good programs in place, we commonly observe problems in laboratory safety that could lead to regulatory issues or worse, health and safety risks to students and staff.
Here are some of the most common problems discovered in science labs during recent GSE compliance audits:
- The OSHA Chemical Hygiene/Laboratory standard (29 CFR 1910.1450) is often overlooked or not updated since it is out of the direct control of many Facility Managers. (Some Science teachers have taken the lead, but are not always engaged and commonly there is no coordination with the Facilities Manager or accountability for compliance.)
- There is no system in place to verify that the lab safety equipment is being properly maintained and operational. For example, we find many lab fume hoods that are not regularly tested and certified.
- Hazardous chemicals, particularly flammables, corrosives, oxidizers and other reactive substances are frequently handled improperly or not accounted for properly.
In recent months, GSE has been asked by an increasing number of Districts to evaluate and assist in their Laboratory Safety Programs. This trend has led us to focus on laboratory safety in this ADVISOR. We will address many of the other common areas of concern in future ADVISORS.
WHY THE RENEWED CONCERN ABOUT LABORATORY SAFETY?
Hazardous chemicals present potential physical and/or health threats to teachers, students and other District staff. While typically school laboratories use small quantities of chemicals, the wide range of chemicals includes cancer causing (carcinogenic) agents and toxins, as well as chemicals with corrosive, flammable and other hazardous properties. Importantly, these chemicals are directly handled on a regular basis by students and teachers.
These hazards are addressed in the following OSHA standard:
Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.145).
This OSHA regulation has been adopted for application to NJ public employees by the NJ Public Employees Safety and Health (NJ-PEOSH) program of the NJ Department of Health.
Overall GOALS of a Laboratory Safety Program:
- Minimize potential exposures to hazardous chemicals
- Establish a system for handling hazardous chemicals and waste safely
- Train all employees to recognize and control hazardous exposures
- Provide an administrative system to ensure proper implementation and oversight
- Provide accurate and complete recordkeeping
Key Components of a Laboratory Safety Program:
- Develop a comprehensive written Chemical Hygiene Plan (CHP) that includes:
- Standard operating procedures for each potentially hazardous laboratory activity
- Criteria for determining and implementing control measures to reduce exposures
- Programs to monitor proper functioning of fume hoods and other protective equipment
- Training of lab personnel regarding the regulation, risks of chemical used, signs and symptoms of chemical exposures, and safety related operating procedures
- Designation of a Chemical Hygiene Officer (CHO) and a Chemical Hygiene Committee (CHC)
- Provision of medical evaluations as needed regarding possible chemical exposures
- Emergency response responsibilities and procedures
- Provision of appropriate personal protective equipment and supplies
- The types and locations of each of the laboratories
- Faculty and support staff for each laboratory
- Types and quantities of hazardous substances used in the laboratories, with an emphasis on storage, use and disposal practices
- Engineering controls (i.e. laboratory fumes hoods, fans, gas shut off valves, etc.)
- Safety and personal protective equipment (i.e. emergency eye washes and showers, etc.)
- Air and medical monitoring data
- Records related to laboratory operations and handling of hazardous materials
- Establish an administrative system including ongoing (at least semi-annual) CHC meetings to implement, oversee and document the CHP.
- Annually review the CHP for updates and modifications based on changes in the regulations, program, curricula, and/or staff.
How De We get Started in Evaluating or Updating Our Lab Safety Program?
An important first step is a comprehensive review of laboratory operations. Many Districts hire outside EHS consultants/experts to conduct an internal compliance survey. Such a survey would review all laboratory operations and related records. This would involve site visits to the each laboratory and interviews with selected science teachers to fully understand how the laboratories operate.
Upon completion of the laboratory site visits, the consultant would provide a report that identifies any deficiencies and makes recommendations for corrective actions.
Examples of common recommendations include:
- Updating the CHP
- Training of laboratory faculty and staff
- Establishment of a CHP and regular CHC meetings
- Changes in how chemicals are used, stored and disposed
- Adjustments in how experiments are done to reduce risk of exposures
- Improved recordkeeping
- Testing of fume hoods and other safety equipment to document effective functioning
GSE is qualified and experienced in laboratory safety and would be pleased to assist in this important process. Please contact us for more information at 201-652-1119.
Additional Sources of Information: