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Chemical Hygiene Management Plan Review and Update Report

Program review and changes are documented below. Documented reviews indicate that the plan continues to meet the needs of the District, or has been modified to do so more effectively.

 
Emergency Contact Information

Chemical Hygiene Officer:

Christine Johnson 320-370-8731 Apollo, North

Dena Connors-Millard 320-370-6790 Technical High School, South Junior High, Mckinley
 

Director of Buildings & Grounds:

320-370-8147

EPA Hazardous Waste Generator License Numbers:

Apollo High School - MND982615049
Technical High School - MND980990758
North Junior High School - MND980990766
South Junior High School - MND980990808
 

Chemical Inventory
Chemical Inventory is available in the office of Buildings and Grounds Department.

Emergency Response Numbers:

Emergency Response: 9-911
MN Poison Control Center: 1-800-222-1222
St. Cloud Hospital: 320-251-2700
Apollo HS Building Engineer: Gerald Horsch, 320-370-8650, x-8672
Tech HS Building Engineer: Billy Fritz, 320-370-8350, x-8391
South Jr. HS Building Engineer: Kelly Henry, 320-370-7000, x-7249
North Jr. HS Building Engineer: Kelly Henry 320-370-7000, x-7249

 
Administrative Procedure 820.1A

Safety: Chemical Hygiene

It is the policy of St. Cloud Area School District 742 to provide a safe learning environment for students, staff and the public. Accordingly, the School Board, through its Superintendent or designee, will monitor the facilities used by students, staff and public in school buildings and on school sites. If unsafe conditions or materials are found to exist, the School District will attempt to eliminate the problem or to minimize exposure by students, staff and the public to such conditions.

Accordingly, the School Board directs the Superintendent/Administration to implement and monitor the Chemical Hygiene Plan dated March 2009. This Plan provides for the appointment of two Chemical Hygiene Officers to provide oversight for science laboratory operations in District buildings. The Chemical Hygiene Officers have the responsibility to monitor experiments conducted in the science laboratories, oversee the handling and storage of chemicals, monitor the purchase of chemicals for classroom activities, ensure science teachers are properly trained in the safe use of chemicals, and work closely with the Environmental Health and Safety Supervisor in the updating and annual review of the Plan.

In addition, this Plan:

Requires exposure monitoring for students and teachers when working with hazardous materials, especially formaldehyde-based products.
Requires an annual review of each science laboratory or classroom by the science teachers using the Comprehensive Laboratory Inspection Checklist and requires this checklist to be maintained by the Environmental Health and Safety Supervisor as required by the State Fire Marshal.
Prohibits the purchase, storage or use of High Risk Chemicals in facilities used by students, staff and the public as found in Tables 2 & 3 of the State Fire Marshal Comprehensive Laboratory Inspection Checklist.

St. Cloud Area School District 742
1201 2nd St S
Waite Park, MN 56387

Administrative Procedures
April 8, 2009 

Introduction

This Plan has been developed to place St. Cloud Public Schools in compliance with the Occupational Safety and Health Administration's (OSHA) Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450), also commonly referred to as the Chemical Hygiene Program. The chemical laboratories within the following school buildings are required to comply with this standard: Apollo High School; Technical High School; North Junior High School; and South Junior High School.

This Plan is site-specific and will be modified to adapt to specific conditions and policies within each building. Review and updating will be completed at least annually at each site.  Two Chemical Hygiene Officer appointed by St. Cloud Public Schools will be actively involved in the review and updating processes.

Overview of Standard

The Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450) became effective on May 1, 1990. This standard covers all laboratories engaged in the laboratory use of hazardous chemicals. However, the standard does not cover laboratory use of hazardous chemicals which present no potential for employee exposures (e.g. chemically impregnated test strips). If the chemical composition of a substance is produced exclusively for the laboratory's own use, St. Cloud Public Schools shall assume it to be hazardous. If the chemical is produced for another user outside of the laboratory, St. Cloud Public Schools must comply with the OSHA Federal Hazard Communication Standard (29 CFR 1910.1200).

Note: Laboratories in compliance with 29 CFR 1910.1450 are exempt from the Minnesota Employee Right-to-Know Act requirements.

Definitions

"Action Level" is the eight-hour time-weighted average concentration for a substance which, if exceeded, requires various activities such as medical surveillance and exposure monitoring be initiated. The Action Level is often times one-half the OSHA Permissible Exposure Limit for the substance.

"Chemical Hygiene Officer" means an employee who is designated by the employer, and who is qualified by training or experience, to provide technical guidance in the development and implementation of the provisions of the Chemical Hygiene Plan. This definition is not intended to place limitations on the position description or job classification that the designated individual shall hold within the employer's organizational structure

"Combustible Liquid" is a liquid having a flashpoint at or above 100EF (37.8EC), but below 200EF (93.3EC). It also includes any mixture having components with flashpoints above 200EF (93.3EC) and the volume makes up 99 percent or more of the total volume.

"Flammable Gas" is any gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of 13 percent by volume or less or a gas that at ambient temperature and pressure forms a range of flammable mixtures with air wider than 12 percent by volume regardless of the lower limit.

"Flammable Liquid" is any liquid with a flashpoint below 100EF (37.8EC) or a mixture having components with flashpoints of greater than 100EF (37.8EC) and the volume makes up 99 percent or more of the total volume.

"Flashpoint" is the minimum temperature at which a liquid gives off enough vapor to ignite.

"Hazardous Chemical" includes any chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes chemicals that are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosive, sensitizers, hepatoxins, nephpotoxins, neurotoxins, agents which act on the hematopoietic system and agents that damage the lungs, skin, eyes or mucous membranes.

"Laboratory Scale" means work with substances in containers or other handling requirements which is easily performed by one person.

"Laboratory Use" is the use of chemicals when all of the following conditions are met.

• Use is carried out on a "laboratory scale"
• Multiple chemical procedures or chemicals are used
• The procedures are not part of a production process
• Protective lab practices and equipment are available and used to minimize employee exposures.

"Oxidizer" is any chemical that initiates or promotes combustion in other materials.

"Reactive" is any unstable chemical which will polymerize, decompose, condense or become self-reactive under conditions of shock, pressure or temperature.

"Permissible Exposure Limit (PEL)" is the maximum 8-hour time-weighted average concentration of a substance which an employee can be exposed to as established by OSHA.

Chemical Hygiene Plan

The purpose of the written Chemical Hygiene Plan is to protect employees from health hazards associated with hazardous chemicals in the laboratory. The Master Plan is available in the office of the Environmental Health and Safety Supervisor as well in the science area of each building making it readily available to all laboratory personnel.

A. Laboratory Personnel

St. Cloud Public Schools is responsible for developing and supporting a broadbased chemical hygiene program that will protect its staff and students from the health effects associated with exposure to hazardous chemicals. This means promoting a positive safety attitude among all employees and providing the necessary resources to fully implement and maintain the program.

The two chemical hygiene officers have overall responsibility for chemical hygiene in their respectively assigned laboratories as well as being a resource for handling hazardous chemicals in the district. They are also responsible for reviewing chemical experiments in their respective school assignments and for the control of the chemical inventory including ordering of chemicals. Routine inspections will be completed regularly by the EOH & S Supervisor and the respective Chemical Hygiene Officer to evaluate the overall effectiveness of the program.

Laboratory staff are responsible for performing all activities in accordance with the established chemical hygiene procedures.

B. Employee Exposure Determination

If an exposure to any regulated substance is reported, St. Cloud Public Schools will conduct air sampling if there is reason to believe the exposure exceeds the permissible exposure level or PEL. Currently exposure sampling will be conducted in all animal science labs where specimens are preserved in formalin. If the initial monitoring results indicate an exposure exceeding the PEL, the district will initiate periodic monitoring of formalin.

Written results of all exposure results are available to the employee within 15 days.

C. Procurement

Safety Data Sheets (SDS) are required to be shipped with each chemical order or the policy of St. Cloud Public Schools is that the shipment will be refused. Orders for laboratory chemicals are the responsibility of each Chemical Hygiene Officer and approval must be provided prior to the completion of a purchase order for science lab chemicals for each building. A science teacher will receive, unpack, date each chemical and properly place in the chemical storage room.

D. General Lab Practices

In general, laboratory personnel shall minimize all exposures to hazardous chemicals and never underestimate the risk involved. Any unknown chemicals or mixtures should be assumed toxic. In addition to existing standard operating procedures and practices within the laboratories, the following are considered good practices to follow:

• Promote housekeeping within the laboratory by cleaning up work benches and returning chemicals to designated storage areas on a daily basis.
• All chemical containers will be properly labeled at all times.
• Minimize the use of flammable or combustible liquids near any open flame or other ignition source.
• Identify any special activities or procedures or extremely hazardous chemicals which require preliminary approval. Factors to consider include quantities used, chemical and physical properties of the chemical, toxicity of the chemical and the potential for exposure.
• Designate special areas, fume hoods, or glove boxes for working with extremely hazardous chemicals (i.e. carcinogens, acute toxins).
• Discourage wearing of contact lenses in the laboratory.
• Conduct frequent inspections within the laboratory to identify any unsafe work practices or conditions.
• Prohibit any eating, drinking or smoking in the laboratory.
• Prohibit any mouth piping.
• Protect against broken glass or glassware implosions.
• Avoid working alone in the laboratory.

Note: An excellent reference manual to establish safe general work practices is "Prudent Practices for Handling Hazardous Chemicals in Laboratories, "published in 1981 by the National Research Council.

E. Control Measures

St. Cloud Public Schools provides appropriate control measures where employees are routinely exposed to a substance above its respective action level or PEL. These include any one or combination of the following: engineering controls, personal protective equipment and administrative controls. SFM tables 2 & 3, Attachment 5 list chemicals not to be used in school labs. See Appendix C.

Engineering Controls. Engineering controls are the first measure implemented since they act to remove or control the exposure at the source. One of the most effective engineering control measures in the lab is ventilation.

The laboratory fume hood is the major protective device for laboratory personnel. It is designed to capture chemicals that escape from their containers or apparatus and to remove them from the laboratory environment before they can be inhaled. Chemical characteristics to be considered in requiring fume hood use are physical state, volatility, toxicity, flammability, eye and skin irritation, odor, and the potential for producing aerosols. A fume hood should be used if a proposed chemical procedure exhibits any one of these characteristics to a degree that:

• airborne concentrations might approach the action level (or permissible exposure limit),
• flammable vapors might approach one tenth of the lower explosion limit,
• materials of unknown toxicity are used or generated, or
• the odor produced is annoying to laboratory occupants and adjacent units.

Procedures that can generally be carried out safely outside the fume hood include those involving

• water-based solutions of salts, dilute acids, bases, or other reagents,
• very low volatility liquids or solids,
• closed systems that do not allow significant escape to the laboratory environment, and
• extremely small quantities of otherwise problematic chemicals. The procedure itself must be evaluated for its potential to increase volatility or produce aerosols.

In general, 2.5 linear feet of hood space should be provided for every two workers. Fume hoods should be monitored and maintained to ensure proper operation. Fume hoods should also have a continuous reading monitoring device (i.e. pressure gauge) to verify air movement. Fume hoods should be operating at a face-velocity range of 80 to 120 linear feet per minute at the designated sash (door) opening. The face velocity should be measured at least semi-annually with a velometer or thermo-anemometer. Laboratory staff should minimize any unnecessary air turbulence near the hood opening. When working with highly toxic substances or carcinogens, an enclosed glove box is used in place of the traditional fume hood.

Adequate general ventilation is required within the lab space. Ideally, there should be at least six fresh air changes (relative to overall room volume) per hour. Sufficient levels of make-up air should be provided for when lab fume hoods are present. In addition, special attention to locations of fresh air intakes relative to exhaust stacks/grills is necessary to avoid the re-entering of contaminants.

Personal Protective Equipment. Personal protective equipment (PPE) acts as a barrier preventing or minimizing chemical exposure to the employee.

The sliding sash of a fume hood, are appropriate when working with highly concentrated acids, bases, oxidizers or reducing agents, all of which have the potential for causing sudden splattering or release of material, as do Reactions carried out at non-ambient pressures (vacuum or high pressure) and reactions that are carried out for the first time or are significantly scaled up from normal operating conditions.

Eye protection is required for all personnel and any visitors whose eyes may be exposed to chemical or physical hazards. Chemical splash goggles with indirect vents shall be used at all times when conducting experiments or working with chemicals in class. Safety glasses shall not be used. Chemicals can be concentrated under contact lenses and contact lenses will interfere with eye flushing in case of an emergency.

Lab coats, aprons or other similar clothing protectors are required to be worn when working with chemicals.

Gloves made of appropriate material as required by the manufacturer and SDS sheets are required to protect the hands and arms from thermal burns, cuts, or chemical exposure that may result in absorption through the skin or reaction on the surface of the skin. Gloves are also required when working with particularly hazardous substances where possible transfer from hand to mouth must be avoided. In addition, gloves are required for work involving pure or concentrated solutions of select carcinogens, reproductive toxins, substances which have a high degree of acute toxicity, strong acids and bases, and any substance on the OSHA PEL list carrying a "skin" notation.

Respiratory protection is generally not necessary in the laboratory setting and must not be used as a substitute for adequate engineering controls. If requested, St. Cloud Public Schools will provide single strap particulate masks for students or staff. Any other respiratory device will not be used unless required as the result of a PPE assessment for a specific chemical risk conducted by the Environmental Health and Safety Supervisor.

Laboratory safety showers and eye wash stations are available in each laboratory. They are inspected and flushed weekly by custodial staff.

Administrative Controls. In addition to establishing good lab practices, St. Cloud Public Schools has adopted other administrative control policies to minimize exposures. These include:

• Prohibition against wearing of jewelry on the hands.
• Sandals or open-toe shoes are not allowed.
• Long hair will be covered or tied up off the shoulders.
• Hands will be washed with soap and water prior to exiting the lab.

F. Chemical Storage

Chemical storage areas and chemical storage cabinets for all flammable, reactive or toxic chemicals have been designated and made available. Only persons trained in chemical hygiene shall have access to the chemical storage room. The chemical storage program is based on the Flinn Chemical Storage System which is posted in each chemical storage area:

• Do not store incompatible chemicals together. Keep oxidizers separate.
• Be sure the chemical container is compatible with the chemical.
• Properly ventilate the chemical storage cabinet and avoid direct heat or sunlight.
• Do not stockpile chemicals, store as little as possible.
• Clean any residual material from outside of container.
• Use a secondary container when transporting a chemical container, for containers with broken seals, or for highly toxic chemicals which is properly labeled.
• Periodically inspect the integrity of the container.
• Store compressed gas cylinders away from any heat sources, cap fastened, and cylinder securely attached to wall or other fixed object.

G. Labeling

St. Cloud Public Schools requires all containers of hazardous and other chemicals to be properly labeled. The label includes the chemical name, hazardous properties and an emergency phone number for further information.

The label is easily cross-referenced back to the appropriate SDS for that chemical. Visible signs identifying the location of safety showers, eye wash stations, first aid kits, emergency exits, fire extinguishers and other safety or control equipment are present.

H. Disposal

The Hazardous Waste Management Plan and Flinn reference materials provide guidance for disposal requirements. The chemical hygiene plan for each laboratory addresses the following minimum requirements:

• Centralized waste collection and storage areas.
• All wastes properly labeled (DOT regulations).
• Verify mixed wastes are compatible with each other.
• Pouring of chemicals down the drain, particularly strong acids/bases or highly toxic substances is prohibited.
• Chemicals are not left inside the fume hood to evaporate.

I. Emergency Plan

St. Cloud Public Schools will follow the emergency plan when responding to any accidents or spills within the laboratory facility. Primary components of this plan include:

• fire alarm system and fire suppression equipment;
• at least one employee trained in first aid present in the laboratory at all times;
• posted emergency contact names and numbers;
• first aid kit available; and
• designated spill response team and spill kit.
• If eye or skin contact with chemical occurs, immediately proceed to flush the contact surface with water for 15 minutes. Remove any contaminated clothing away from skin.

Medical Surveillance Program

Medical consultation is provided to employees exposed during a spill, leak or other occurrence resulting in the likelihood of a hazardous exposure. Medical examination will also be provided under the following circumstances:

• Whenever an employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory.
• Where exposure monitoring reveals an exposure level routinely above the action level (or in the absence of an action level, the PEL) for an OSHA regulated substance for which there are exposure monitoring and medical surveillance requirements, medical surveillance will be established for the affected employee as prescribed by the particular standard.

The Chemical Hygiene Officer will be contacted whenever the need for medical consultation or examination occurs, or when there is uncertainty as to whether any of the above criteria have been met.

All medical examinations and consultations are performed by or under the direct supervision of a licensed physician and will be provided without cost to the employee, without loss of pay and at a reasonable time and place.

The Chemical Hygiene Officer will provide the examining physician with the following information:

• the identity of the hazardous chemical(s) to which the employee may have been exposed;
• a description of the conditions under which the exposure occurred including quantitative exposure data, if available; and
• a description of the signs and symptoms of exposure that the employee is experiencing, if any.

The examining physician will provide St. Cloud Public Schools with a written report including the following information:

• any recommendation for further medical follow-up;
• the results of the medical examination and any associated tests;
• any medical condition which may be revealed in the course of the examination which may place the employee at increased risk as a result of exposure to a hazardous chemical found in the workplace, and
• a statement that the employee has been informed by the physician of the results of the consultation or medical examination and any medical condition that may require further examination or treatment.

The written physician's opinion will not reveal specific findings of diagnoses unrelated to any occupational exposure.

Training Program

All laboratory personnel shall be provided with training to ensure they are apprised of the hazards of chemicals present in their laboratory and to know how to control exposure to such chemicals. Training is provided at the time of initial assignment to a work area where hazardous chemicals are present and prior to any assignments involving new or potential exposure situations. St. Cloud Public Schools provides annual refresher training to all science teachers.

The training program includes at a minimum, the following.

• Review of the OSHA standard (Chemical Hygiene Plan).
• Review of the Chemical Hygiene Plan and its location.
• Toxicity, hazards, routes of exposure, signs and symptoms and health effects of the chemicals.
• Review of action levels, PELS or other appropriate limits for each chemical.
• Review of SDS information available for each chemical (i.e. hazards, handling, storage, and disposal.)
• Methods to detect the presence or release of hazardous chemicals (i.e. air monitoring, odors, visual appearance.)
• Good laboratory practices.
• Control measures.
• Emergency response actions.

Recordkeeping

Training Records

St. Cloud Public Schools shall retain training records for each employee for a period of five years (minimum).

Medical Records

St. Cloud Public Schools shall maintain each employee's medical records for the duration of employment plus 30 years. If an employee has worked less than one year, St. Cloud Public Schools is not required to retain the medical records and should turn them over to the employee at the time of their departure. (Refer to OSHA 29 CFR 1910.20 - Access to Employee and Exposure Medical Records.)

Exposure Records

St. Cloud Public Schools shall retain all employee exposure (monitoring) records for 30 years (minimum).

Safety Data Sheets

Current SDS sheets are maintained in each laboratory. All SDS sheets will be retained by the EH & S Supervisor for a minimum of 30 years. Click here to view St. Cloud Public Schools Online Safety Data Sheet Inventory.

Laboratory Safety Checks

At least annually, beginning with the first week of school, each laboratory or classroom instructor will complete PART 1 - GENERAL SCIENCE SAFETY CONSIDERATIONS - LABORATORY as required by the Office of the State Fire Marshal.

These completed survey forms will be forwarded to the Chemical Hygiene Officer responsible for the individual buildings. Upon review the Chemical Hygiene Officer will forward the completed checklists to the EH & S Supervisor for review and action.

St. Cloud Public Schools will take whatever action is appropriate to correct or remediate issues identified by the Chemical Hygiene Officer to ensure a safe learning environment for students and staff.

These checklists will be retained by the EH & S Supervisor and made available to the State Fire Marshal upon request. A copy of the completed checklists will also be retained by the Chemical Hygiene Officers and made available to all laboratory staff upon request.

Appendix A: Comprehensive Laboratory Inspection Checklist

• Click here to download

Appendix B: Training Log

• Click here to download a copy of the "Chemical Hygiene In Laboratories Training" content
• Click here to download the Training Log Form

Appendix C: Prohibited High Risk Chemicals

• Click here to download

Appendix D: Reducing Risks to Students and Educators

• Click here to download: Reducing Risks to Students and Educators from Hazardous Chemicals in a Secondary School Chemical Inventory (Rev. 2.0 July 2009)