A Case Study of Environmental, Health and Safety Issues - Chemical Management and Usage

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A Case Study of Environmental, Health and Safety Issues Involving the

Burlington, Massachusetts Public School System

Chemical Management and Usage

I. The issue:

Proper chemical management is critical to preventing and/or controlling a

variety of Environmental, Health and Safety (EHS) issues within any

facility. The first step towards initiating proper chemical management is

the creation of an accurate chemical inventory along with a copy of the

material safety data sheet (MSDS) for each item listed on the inventory. An

MSDS is an informational document prepared by the chemical manufacturer or

distributor which describes chemical, environmental, and health and safety

information available for a particular compound. Understanding the materials

present at the school will enable you to understand the issues associated

with these substances. Properly recognizing and controlling the hazards

inherent to these materials will enhance your ability to create a safe

school with minimal environmental liabilities. Failure to properly manage

your materials can create a myriad of difficult and interrelated EHS issues.

II. The approach taken:

My effort began with a request for an accurate chemical inventory from all

sections of the school department and a review of their chemical handling

practices. This action was prompted by a history of chemical incidents

occurring in the high school. In the 1970's, the chairman of the high school

science department discarded ammonium phosphide, a water reactive material,

via the sanitary sewer which resulted in the destruction of a portion of the

sanitary sewer when the material detonated. The indoor air quality of the

school was also compromised during this event by the generation of phosgene

gas (a basic chemical warfare agent). In 1991, a fire in the facilities

maintenance warehouse at the high school became a serious hazardous

materials incident when pallets of bleach, ammonia and sulfuric acid based

drain cleaner stored adjacent to each other ruptured and created an acid

vapor cloud and chlorine and phosgene gas. The total cost of this event was

approximately $500,000.

In order to initiate a hazard analysis of the school system, it was

imperative to identify the number, type, volume, and location of the

hazardous materials present throughout the school system. The preparation of

the chemical inventories provided this basic information. Using this

information, I was then able to identify and prioritize the hazards present

throughout the school system as a means to most effectively respond to the

problems detected.

III. Observations made:

This was a difficult and time consuming task. It took nearly four years to

acquire a complete and accurate inventory from all departments within the

school system. The staff and administration did not realize initially how

decentralized the purchasing, storage and usage of chemicals had become.

Chemicals were found to be stored throughout all areas of the high school.

The middle school and elementary schools were better able to locate and

identify their chemical inventories, but this was primarily due to the

reduced size of their inventories and its limited use within certain areas

of the school. The presence of the facilities maintenance department, and an

active arts and science departments acted to significantly increase the size

and scope of the chemical inventory at the high school.

The lack of centralized purchasing and storage hindered the ability of the

school department to track and account for the materials in their inventory.

In addition, it was impossible for the school system to ensure its

compliance with the Massachusetts Right to Know law. This law is similar to

the federal Hazard Communication Standard which requires each employer to

maintain a chemical inventory and MSDS database as a means to identify

chemical hazards in the workplace and to train and inform their staff of

these hazards.

Another problem associated with decentralized purchasing was that the

school system tended to purchase an excessive amount of chemicals.

Frequently, staff members were purchasing materials that were already

present somewhere within the school system. This represented an inefficient

use of school funds and created additional regulatory requirements and

safety hazards as the materials accumulated.

A de-centralized approach to chemical management and accounting also

hindered our ability to respond to an accident or to prevent thief or

tampering. This problem was noted during the 1991 fire in the facilities

maintenance warehouse. Confusion over what materials were present in the

warehouse and the inability to locate MSDS's for materials thought to be

present created the need for firefighters to conduct an extremely hazardous

exploratory entry to determine what materials were involved in the fire.

Proper training, equipment and luck prevented this effort from becoming a

tragedy. An increasingly important concern is the need to protect your

chemical inventory from thief and tampering. Many of the chemicals commonly

found in an educational setting could easily be used in a more threatening

manner by a prankster. Furthermore, the school department and individual

teachers can be subject to civil liability if they are found to be negligent

in their storage and control of chemicals. So if, the local juvenile

delinquent walks away with a container of sodium you had stored on a shelf

in your classroom and injures himself, then the teacher and the school

system can be held liable for the injuries and suffering resulting from the

thief. This was a major concern in the high school science area where an

average of approximately 150 chemical containers were found initially stored

in each classroom. These materials were routinely stored on shelves or in

unlocked cabinets or drawers.

Another observation noted was that the school system had a policy of

accepting chemical donations. Many thought this was prudent due the

declining school budget. In actuality, the school became a dumping grounds

for local businesses especially those that were terminating operations or

re-locating. As a result, the high school science department collected a

large volume of chemicals more useful for electroplating than for the

teaching of high school chemistry. The facilities maintenance staff also

suffered from this policy by collecting a large number of product samples or

promotional products. Products found to be ineffective by the maintenance

staff were frequently consigned to a corner of the warehouse and forgotten.

Over time, this resulted in the accumulation of a large volume of flammable

petroleum based cleaning materials.

Finally, no consideration was given during the acquisition process for the

eventual need and cost of disposal of chemicals or the health and safety

issues associated with the material. Furthermore, little awareness existed

of the need to train and advise the staff how to use, store or dispose of

the materials. This lapse in oversight and training resulted in the creation

of numerous safety hazards associated with improper chemical storage as well

as the repeated disposal of hazardous waste via the sanitary sewer.

IV. The problems or concerns noted:

The lack of knowledge regarding what chemicals we had, what hazards were

associated with these materials, and where the material was stored.

The accessibility of the materials, and the risk of accident or thief this

accessibility presented.

The inherent risk created by the massive volume of chemistry maintained by

the school department.

The potential toxicity, flammability or reactivity of the individual

chemicals maintained by the school department.

The lack of functioning protective equipment, and health and safety

practices in the schools.

The inefficient use of funds created by overstocking materials.

The staff's limited understanding of the hazards associated with the

chemicals.

The impact of the acceptance of chemical donations by the school department.

V. Actions taken:

High School Science Department

A. EHS evaluation of the chemical inventory.

In 1993, I reviewed chemical inventory maintained by the high school

science department for EHS issues. As a result, I determined that 40% of the

inventory were human carcinogens, teratogens (capable of causing birth

defects), and mutagens (capable of causing genetic damage). I also noted

that the chemistry curriculum was heavily involved with the use of organic

solvents such as benzene (volatile, flammable and carcinogenic), carbon

tetrachloride (volatile and carcinogenic) and carbon disulfide (volatile,

flammable, narcotic poison). During my review, I also noted the presence of

a number of acutely toxic materials (e.g. cyanide salts and bromine gas),

radioactive materials (e.g. thorium nitrate and uranium tetrachloride), and

potentially explosive materials (e.g. ethyl ether and cumene). In addition,

many of the components of the science department inventory posed lesser

hazards due to their individual corrosivity, toxicity or reactivity.

One major problem I noted during this evaluation was that the material

safety data sheets (MSDS) provided by firms specializing in supplying

chemicals to schools were frequently inadequate in terms of quality and

detail. All reviewers should beware of MSDS's that frequently contain

omissions within the body of the document or repeatedly list 'not

applicable' especially for common materials. I also recommend that you

notify your supplier or the federal Occupation Safety and Health

Administration if you notice a repeated trend in poor quality or vague

MSDS's. Remember depending on your setting, state and/or federal hazard

communication requirements specify your responsibility to identify and

address the hazards associated with the materials you use. If the

manufacturer does not properly identify these concerns, then you may be

required to research it more thoroughly. The bottom line is to demand better

service and information from your supplier or find a new supplier.

Once the size, scope and location of the chemical inventory had been

established, we were now in a position to proceed with addressing the EHS

concerns created by the material.

B. Terminated chemical donations.

One of the first steps taken to prevent the continued acquisition of

extremely toxic and hazardous materials with limited educational value was

to ban the acceptance of chemical donations. A more than twenty year

practice of accepting chemical donations had resulted in the accumulation of

a large volume of material better suited for metal plating and the

manufacture of electronics than the instruction of high school chemistry. In

an effort to enhance their inventory without impacting their budget, the

science department had willingly accepted material from local industry. The

staff accepted the good with the bad, frequently without reviewing what

exactly they had received. The net result was the creation of a huge and

extremely hazardous chemical inventory. The size and scope of this inventory

also made it impossible for the science department to comply with the

Massachusetts worker right to know requirements.

The termination of this practice signaled the first effort to control the

influx of new materials. This was an extremely important step because the

cost of chemical disposal alone is frequently two to three times the cost of

purchasing the materials. The possession of certain chemicals may also

trigger additional regulatory requirements or unique storage issues. I

encourage all school systems to adopt a similar policy to prevent your

schools from becoming a chemical disposal option for local industry and to

prevent a right to know compliance nightmare.

C. Established a centralized chemical storage policy.

After identifying the major hazards associated with the chemical inventory,

our next step was to implement a centralized chemical storage policy in

order to enhance chemical control and accountability, and to remove the

chemical hazards from the classroom. Even though a centrally located,

secured and ventilated chemical storage room equipped with a carbon dioxide

fire suppression system had been constructed within the science area, the

staff had opted to store the bulk of their inventory in their classrooms for

convenience. During a comprehensive inspection, we found unsecured materials

stored in the closets, cabinets, desks, and on shelves in each classroom and

preparation area. The majority of the materials were readily accessible. In

most cases, these materials were stored in an random manner.

The historic chemical storage practices of the department posed a major

obstacle to our effort to comply with state right to know requirements and

to prevent the theft of materials. This method of storage also increased the

likelihood of a serious hazardous materials incident occurring in the

classroom due to the storage of chemicals in areas not designed or equipped

to provide additional protection in the event of a fire. This risk was

compounded further by the common practice of the storing the materials

without regard to chemical compatibility or reactivity.

We resolved these problems by re-locating the entire inventory to the

chemical storage room originally designed and constructed for this purpose.

During this process, we used the chemical storage protocol outlined by Flinn

Scientific as our guide to ensure that the materials were stored properly

with regard to chemical compatibility and reactivity concerns. This task

allowed us to immediately identify the true size of the chemical inventory

and prompted a major disposal effort when we realized our inventory vastly

exceeded our storage capacity.

D. Established a chemical disposal policy and conducted a massive chemical

removal.

After reviewing the hazards associated with inventory, and the laboratory

facilities at the school as well as the history of accidents and near misses

at the school, the Burlington Board of Health ordered the science department

to dispose of all confirmed carcinogens, teratogens, mutagens and acutely

toxic materials. The Board of Health also recommended that the department

dispose of all materials no longer used by the staff, contaminated or

degraded materials, and where possible to reduce the volume of overstocked

items. As a result, 65 drums and containers of hazardous waste were disposed

of during a one time clean out conducted in September 1993. The following is

a sampling of materials disposed of at this time:

0.5 lbs of chloral hydrate, a controlled barbiturate

3.5 lbs of unsealed radioactive materials including thorium nitrate and

uranium tetrachloride

42 one liter glass cylinders containing bromine gas

12 containers of various potentially explosive peroxide forming materials

(e.g. ethyl ether, dioxane, formic acid, cumene, furan, tetrahydrofuran,

sodium peroxide, barium peroxide, and potassium metal)

7 lbs of water reactive metals: sodium, lithium and potassium

5.5 lbs of cyanide salts

gallons of benzene, carbon tetrachloride, chloroform, aniline, and

formaldehyde

10 lbs of elemental mercury, and 3 lbs of mercuric compounds

5 lbs of explosive white phosphorus

5 lbs of potentially explosive potassium chlorate

1 lb of polychlorinated biphenyl's (PCB's)

3 lbs of powdered cadmium

1 lb of powdered arsenic

2 lbs of powdered antimony

1 gallon of o-toluidine

approximately 100 lbs of potentially explosive oxidizers

At this time, we also adopted a five year review plan for each chemical.

Using a five color coding system, we labeled all materials to indicate their

approximate date of purchase. The color coding system is designed to quickly

identify the date of purchase and age of each container in the inventory. It

is now the responsibility of the chairman of the science department to

review each chemical container on the fifth year of its purchase to

determine if the material should be retained or discarded. This evaluation

is based on the EHS issues associated with the material, whether the

material is still being used by the department, and the integrity or quality

of the material. We hope that this approach will aid our efforts to prevent

the chemical overstocking observed in the past.

E. Provided staff with training.

Another key component to addressing our chemical hygiene problems was to

provide the staff with basic training in chemical hygiene and EHS awareness.

A main component of this effort was to review how to read and understand an

MSDS as well as learning to interpret the quality of an MSDS. This was

extremely critical because I found that the majority of the staff had no

formal training or knowledge in this area. This was compounded by the staff

reliance on textbooks or chemical supply catalogs which did not mention EHS

issues or provided erroneous recommendations. Habit was also a significant

barrier to change and improvement. Much of the staff was resistant to change

even after the health and safety issues of certain activities had been

reviewed in detail. As a result, I have modified the training regimen to

include a discussion of the types of liability associated with accidents

involving chemical usage in schools.

F. Established centralized chemical purchasing.

We also established a centralized chemical purchasing system where the

chairman of the science department became responsible for reviewing chemical

purchases. The intent of this plan is to ensure that chemicals are reviewed

for the following parameters prior to purchasing: 1) hazards associated with

the material, 2) potential impact on air quality, 3) generation of hazardous

waste, and 4) the availability of less toxic alternatives. This initiative

is designed to prevent over stocking and the acquisition of inappropriate

materials. The effort has also enhanced our ability to maintain an accurate

chemical inventory and MSDS database as required by the Massachusetts Right

to Know law.

G. Banned the disposal of regulated chemicals via the sanitary sewer.

During routine inspections, I noted that the staff repeatedly disposed of

state and federally regulated hazardous waste via the sanitary sewer. Our

first attempt to address this problem was to advise and train the staff with

regard to the discharge requirements established by the local sewer

authority. This effort met with limited success. As a result, the Board of

Health adopted the position that it would issue citations and fines to

individual teachers if they were caught discharging materials. The publicity

associated with this position and the concern over incurring a $200 fine

provided the motivation to reduce the discharge of hazardous waste via the

sanitary sewer.

H. Established a hazardous waste management plan.

A hazardous waste management plan was also developed as a means to promote

the identification, collection and proper disposal of all hazardous waste

generated by the staff. The staff were instructed to review their procedures

to determine what wastes were generated and how these materials had to be

managed (acceptable for disposal via the sanitary sewer versus manifested

disposal as a hazardous waste). In addition, a satellite hazardous waste

storage area was also established in an isolated and secured portion of the

science area. The staff was also instructed to ensure that all waste

containers were to be kept sealed and labeled at all times. Depending upon

the rate of generation, this waste material is re-located to the school's

central hazardous waste storage area on a bi-weekly or monthly basis pending

proper disposal.

I. Assessed classroom setting and availability of protective equipment.

Our safety evaluation also included a review of how the classrooms were

equipped and the safety practices utilized by the staff. During this

assessment, I found that the majority of the classrooms were not equipped

with emergency eyewash units or chemical fume hoods. In addition, I also

noted that the units available appeared to be either unused or unmaintained.

We also noted a significant shortage in terms of safety glasses, protective

gloves and aprons. During training sessions, we reviewed the need to use and

maintain various safety equipment. We also reminded the staff of the

Massachusetts state law requiring the use of protective eyewear when

chemicals are used in an educational setting. As a result of this review,

new safety supplies were purchased so that each classroom was equipped with

an emergency eyewash and an adequate amount of protective equipment.

Unfortunately, the staff use of safety equipment continues to be spotty and

not fully compliant with state requirements.

J. Investigation of the chemical fume hoods.

During my survey, I noted that the staff rarely used the chemical fume

hoods in the science area. Upon closer examination, it became obvious that

many of the units were in a state of disrepair. Our efforts to investigate

and repair the fume hoods provides evidence of the need to hire a trained

and competent professional to evaluate and maintain these units. During this

review, we initially found that the exhaust fan had been removed from the

majority of the units, presumably for energy savings. The remaining units

were found to be equipped with improperly sized and balanced intake and

exhaust fans. In addition, when tested with smoke, approximately half the

units or associated ductwork were found to leak contaminants into the

building. A final and fatal flaw was also detected for all chemical fume

hoods. All hoods were found to be constructed with the exhaust located

adjacent to the intake for each unit, consequently even if functional, the

hoods could not remove contaminants from the classrooms and laboratories

without re-introducing the materials to the building.

We have worked with an architect and certified industrial hygienist to

correct and resolve these deficiencies. We have also provided the staff with

additional training regarding the safe and proper use of the hoods. In

addition, each hood has been labeled to indicate the safe work area within

the hood as well as the proper sash height for safe operation.

An inexpensive tip for screening the function of a chemical fume hood is to

test the unit using a 60 to 90 colored smoke bomb. If the unit is

functioning properly it should easily evacuate the smoke to the outdoors.

Common problems you may observe would be the failure of the smoke to exit

the unit, smoke leaking from the hood or ductwork, and smoke re-entering the

intake or the building ventilation system. One word of caution would be to

coordinate all smoke tests with your fire department to ensure that all area

smoke detectors have been disabled prior to testing. This graphic and

inexpensive demonstration can be a useful indicator of whether a serious

problem may exist. This test does not replace the need to have the units

tested and re-calibrated on annual basis by a competent professional. Also,

all units found to display improper air flow should be removed from service

until inspected and repaired.

K. Investigation of curriculum changes as a means to promote pollution

prevention and improve air quality and classroom safety.

In addition to the actions noted, the science department has placed

emphasis on researching and adopting a less toxic curriculum as a means to

promote pollution prevention, and health and safety. This effort has focused

on the elimination of the most toxic reagents as well as the implementation

of microscale experiments as a means to reduce the volume of materials used

or generated. This process has been supported by the adoption of a chemical

use review policy which requires the staff to review each procedure with

regard to: a) hazards associated with the activity, potential impact of

air quality, c) protective equipment required, and d) the generation of

hazardous waste. The School Committee has adopted a formal review policy

which prohibits student use of any materials or the generation of any

reaction byproducts which have a National Fire Protection Association (NFPA)

hazard ranking of 4 or carcinogens. (The NFPA is a technical advisory group

conducting research for fire prevention and hazardous materials mitigation.

The NFPA has established a 0 to 4 hazard ranking scale for chemicals based

on the flammability, reactivity and the health hazards associated with

material. The level of hazard increases as you move from 0 (no hazard) to 4

(most severe hazard).) In addition, each teacher is now required to justify

the use or generation of any material that may generate a substance with an

NFPA ranking of 3.

High School Art Department

A. Reviewed issues associated with arts curriculum and chemical inventory.

A review of the art department indicated that the program consisted of the

following activities: photography, computer graphics, painting, and

ceramics.

Photography: Standard fixers and developers were found to be utilized by

the photography lab. In addition, the use of protective equipment was

observed to be a common practice in this area. The primary concerns for this

area were proper ventilation and proper waste management. The common use of

chemicals in a photolab that was not originally designed for this purpose

has raised a number of concerns regarding proper ventilation of this space.

These issues will be discussed in detailed in the section related to indoor

air quality. The waste generated in the photography lab is containerized for

off site disposal. This appears to be the wiser practice because there is no

encouragement to the staff or students to discharge the materials via the

sanitary drains as would be the case if a neutralization system or silver

recovery system were in place. By using off site disposal, we also avoid the

need for acquiring a discharge permit from the local sewer authority and

conducting compliance testing routinely required by discharge permits. The

wastes are now managed as part of the hazardous waste management program

adopted by the school system.

Computer graphics: The major hazards associated with the computer graphics

laboratory are associated with electrical safety and potential impact on

indoor air quality. The computer graphics lab has grown and expanded as

society's use of the computer has grown. The concern for electrical safety

is based on the constantly increasing accumulation and use of electrical

equipment in an area not originally designed for this purpose. The presence

of a large number of power cords and cables poses a serious fall hazard.

There also exists the risk of toppling equipment should the cords or cables

become caught on a moving object. The most serious electrical concern is the

risk of creating a fire hazard by over loading an electrical circuit. These

conditions are most appropriately reviewed by a licensed electrician.

Indoor air quality concerns also existed in the computer graphics lab. The

accumulation and use of a large volume of electronic equipment in an area

not originally designed for this activity resulted in degradation of the air

quality in this area. We had three areas of concern: the generation of

volatile organic contaminants evolving from the toners and inks used, the

generation of ozone by the equipment, and the decline in the humidity in

this area. The standardization of the toner and ink chemistry limits our

ability to reduce the generation of the emissions from these materials. As a

result, we hope to reduce the potential impact of these materials by

increasing the rate of fresh air exchange in this area as a means to dilute

and remove the contaminants. On a number of occasions, I have monitored the

computer lab and measured temperatures ranging between 85 to 90 degrees

Fahrenheit with humidity at 15% to 25%. The heat given off by the equipment

combined with inadequate air exchange acts to heat the room and lower the

humidity. As a result, this promotes the generation of hazardous ozone.

Ozone is a significant respiratory irritant. The decline in humidity also

increases the generation of static electricity in the area which can be

detrimental to the equipment and annoying to the occupants. Also, a lower

humidity level tends to cause soft tissues such as mucous membranes and the

eyes to dry and become irritated. The generation of harmful ozone can be

mitigated by lowering the temperature and increasing the humidity in the

laboratory. This approach will also improve the comfort level for the

occupants. We hope that by lowering the room temperature, increasing the

ventilation rate, and increasing the humidity level that we will be able to

address the three air quality concerns we have identified.

Painting: The bulk of the painting done by the department involves the use

of water based materials, however, acrylics and aerosols are used. The only

concern noted involving the use of water based materials is that some of

these products have been found to contain heavy metals. Consumption or

accidental ingestion of these materials is not consider a high risk by high

school students but may be a greater concern for younger students. I also

noted that it is difficult to review the health and safety of these products

because many of the MSDS's generated for these products are frequently of

low quality and lacking in detail. When ordering supplies, you should

confirm that the product complies with ASTM D4236, an art safety standard

adopted by the federal Consumer Product Safety Council. In order to bear

this seal, the product must undergo toxicity testing to confirm that it is

safe for use by children. A sampling of this labeling can be found on most

Crayola® products.

The use of acrylics and aerosols occasionally has resulted in the

degradation of the air quality of the art studio and adjacent classrooms. We

have provided the staff with right to know training and discussed the need

to locate more benign products or to use the materials in a better

ventilated area. This approach has met with limited success. In addition, we

are also planning repairs and modifications to the existing ventilation

system.

Ceramics: The high school has a very active ceramics program. As part of

this curriculum, the students have been instructed in the art of mixing

different types of clays and glazes using dry powdered components. This

practice has created numerous significant respiratory hazards.

The most significant hazard is the generation of free silica dust. Free

silica is a chemical cousin to asbestos with regard to physical qualities

and health and safety effects. A review of the clay powders used by the

department indicated that the products in their inventory typically

contained between 20% to 90% free silica, and in some cases asbestos. The

storage, handling and mixing of these powdered materials resulted in the

airborne release of large quantities of free silica which has contaminated

the ceramics studio, the ventilation system in the ceramics studio and

adjacent class rooms. By converting to the use of pre-mixed wetted clays, we

were able to significantly reduce the generation of free silica in the

ceramics studio. Unfortunately, free silica will continue to be produced

when ever a dry piece of ceramics is sanded or sculpted. The school

department has attempted to address this hazard by conducting these

activities in a chemical fume hood. The size of the free silica particles

decreases the likelihood that this approach will be effective at controlling

or removing the free silica from the classroom. Aside from eliminating these

activities or conducting them outdoors, the most effective means for

controlling the free silica hazard is to implement a rigorous daily cleaning

regimen which involves the damp mopping or HEPA vacuuming of all surfaces in

the work area. A HEPA vacuum is a high efficiency particulate vacuum used to

remove extremely small particles while also filtering its exhaust so that

fine materials are not released. Warning - Do not use standard household

type vacuums to collect free silica because these units are not capable of

collecting and retaining the silica and will act to transport the problem

throughout the building.

The mixing of glazes and englobes also resulted in exposing students to a

number of severe respiratory hazards associated with the use of toxic heavy

metals. The students and staff used a variety of powdered metals (e.g.

chromium, cobalt, nickel, and titanium) to prepare various colorants. These

actions exposed the user to a variety of potential carcinogens, mutagens,

and teratogens. This activity also resulted in the release of the materials

to the classroom and the ventilation system. We resolved this issue by

training and informing the staff and administration of the hazards created

by this activity and by using pre-mixed manufactured glazes and englobes

with limited heavy metal content.

In addition, all extremely hazardous metallic powders and dry powder clays

have been removed from use in the classroom and disposed of in accordance to

state and federal requirements. During this effort, we disposed of several

hundred pounds of clay powders and approximately 100 pounds of various heavy

metal powders.

B. Inspection of the kilns used by the ceramics program.

The high school art department maintains two kilns which area located in an

interior room lacking a window. Proper venting of the kilns is critical due

to the degradation of indoor air quality caused by the generation of carbon

monoxide, volatile organic compounds, and metallic vapors. Initially, the

kiln room was vented to the outdoors via a manually operated ceiling mounted

exhaust fan which was ducted thirty feet to the outdoors. The discharge for

this ductwork was 10 feet below the roof line within a partially enclosed

area and adjacent to the discharge was an inoperative louver fan for the

ceramics studio. The following problems existed with this design. First, the

kiln exhaust was not ducted to the exhaust fan but allowed to passively be

drawn to the fan. This approach allowed the kiln emissions to escape the

kiln room via two door ways or via the building heating and ventilation

system which also serviced the kiln room. In addition, the operation of the

exhaust fan was manually operated by the staff and students and due to its

noisy operation most individuals preferred not to use the fan. Furthermore,

it was questionable that the exhaust fan was capable of transporting

captured emissions the required thirty feet and discharging the material via

the louvered opening. Finally, it is likely that a portion of those

materials that were discharged by the exhaust system probably re-entered the

building via the louvered fan located adjacent to the kiln exhaust

discharge.

We addressed these problems by installing bottom mounted exhaust fans on

both kilns. The kiln exhausts were also ducted directly to the existing

exhaust system which was equipped with two quieter booster fans. The exhaust

system was also modified to discharge above the roof line. The exhaust

system has also been hard wired to operate when the kilns are in operation.

C. Improved chemical storage to prevent tampering or thief.

Efforts have been initiated within the art department to improve chemical

management and control. Several flammable storage cabinets have been

purchased and the bulk of the chemical inventory has been moved from

classrooms to secured storage closets and cabinets.

D. Established a chemical use review policy.

A chemical use review policy has been adopted which requires the art

department chairman to review the materials and procedures involving the use

of chemicals for the following parameters: a) health and safety concerns,

impact on air quality c) need for protective equipment, and d) the

generation of hazardous waste. The materials used by the art department are

also subject to the review and consideration of the School Chemical

Oversight Committee.

E. Established a hazardous waste management plan.

All hazardous wastes generated by the art department are now forwarded to

the care of the facilities maintenance staff which manages the overall

hazardous waste management plan adopted for the school. A satellite

hazardous waste storage area has been established in the photolab for the

waste fixer and developer generated in this area. All other waste is

transferred to the central hazardous waste storage area as it is generated.

F. Provided staff with training.

The staff have been trained with regard to worker right to know, basic

chemical hygiene, and new chemical review and handling procedures. The staff

have also been advised to re-examine their procedures involving the use of

chemicals and to seek less toxic alternatives. The increased training and

awareness has achieved limited success in promoting procedure changes and

chemical substitutions. A resistance to change has been noted in this area.

In addition, the use of chemicals by the staff continues to occasionally

impact the air quality at the school.

Facilities Maintenance

A. Reviewed issues associated with inventory.

A review of the chemical inventory maintained by the facilities maintenance

staff determined that the department did not maintain an accounting of the

materials it possessed. In addition, the department tended to acquire small

batches of related products with similar uses while rarely consuming all the

materials. As a result, the department was overstocked and not in compliance

with the Massachusetts Right to Know record keeping requirements.

Furthermore, their approach to chemical management had resulted also in the

accumulation of a large volume of flammable petroleum based cleaning

products. Another concern noted was that many materials were stored in the

warehouse without regard to chemical compatibility and therefore posed a

significant risk to local emergency responders.

B. Improved oversight of chemical acquisition.

As the result of improved training and guidance, the facilities maintenance

department has reduced its chemical inventory and virtually eliminated its

use of petroleum based products. This reduction was achieved by implementing

chemical purchasing controls, consumption of useful materials, and the

disposal of obsolete or degraded materials. A one time chemical clean out

was also conducted to remove major fire hazards and prohibited items. During

this effort we disposed of 50 pounds of various pesticides and over 350

gallons of methanol duplicating fluid. The department has also decreased its

willingness to accept free samples or test quantities from suppliers.

C. Modified chemical storage with regard to chemical compatibility.

The staff have been trained and advised in the need to store materials with

regard to chemical compatibility. The department is also exploring the

suggestion of constructing or designating storage areas within the warehouse

which are based on general chemical classes and compatibilities.

Unfortunately, the transient nature of the materials moving through the high

school warehouse area and low level of importance given this task by the

staff has made this a difficult issue to resolve.

D. Established a chemical use review policy.

All materials utilized by the facilities maintenance department are subject

to the chemical use review policies adopted for the school system. It is now

the responsibility of the director of the facilities maintenance department

in addition to the School Chemical Oversight Committee to review and monitor

chemical use by the department for the following parameters: a) health and

safety hazards, potential impact on air quality, c) need for protective

equipment, and d) the generation of hazardous waste.

E. Established a hazardous waste management plan.

The facilities maintenance department fulfills a critical function in

supervising the implementation of the school department hazardous waste

management plan. The department is responsible for maintaining the central

hazardous waste storage area and for re-locating departmental wastes to this

location. Several staff members have been provided with 8 hour First

Responder training as defined in 29 CFR 1910.120, the Occupational Safety

and Health Administration HAZWOPER Standard, as well as additional training

to ensure the proper management of hazardous waste. In addition, the

disposal of all hazardous waste generated by the School Department is now

carried out in conjunction with the regular municipal hazardous waste

disposal program at programmed intervals. It is the intent of the town to

insure that the school system maintains the generator status of a very small

quantity generator (or conditionally exempt small quantity generator) at all

times. The incorporation of the school's hazardous waste disposal activities

into the existing town program has significantly enhanced our ability to

promote the safe and proper disposal of hazardous materials.

Middle and elementary schools.

A. Reviewed hazards associated with chemical inventories.

I conducted a chemical hygiene review of the inventories maintained by the

middle and elementary schools. Significantly fewer hazards were found at

these schools primarily due to the decreased size of the chemical

inventories present. The chemical hazards present at the middle school were

associated with the chemical inventories maintained by the science and arts

departments. Fortunately, the smaller inventory combined with the reliance

on more benign household products for chemical experiments and demonstration

lowered the risk factor associated with the inventory. In addition, the arts

department also maintained only a small chemical inventory. Fortunately, the

art instructors had already converted the bulk of their inventory to low

toxicity materials.

The chemical hazards present at the elementary schools were even less due

to the limited amount of chemicals present. Art supplies were the primary

chemical components present at the elementary schools. Again, the staff had

already recognized the potential hazards and converted their materials to

approved low toxicity materials.

Cleaning and maintenance supplies also represented a potential hazard at

these schools. These hazards were controlled and reduced by limiting and

securing the quantities stored on site and by consolidating the bulk storage

of these materials at the high school warehouse.

A significant hazard that was noted at the middle and elementary schools

was the presence of poorly identified hazardous materials in pre-packaged

instructional kits designed for the non-scientist. Concentrated acids,

poisons, and carcinogens were found in educational kits designed for grade

levels K through 8. Often times chemicals solutions were simply labeled:

" Solution A, Do not consume, Poison. " Frequently, these kits provided only a

generalized description of the safety hazards associated with the materials

contained in the kit. This lack of information could seriously hinder

medical aid and emergency response in the event of an accident. Also, the

merit for using some of these materials at the intended age level is

questionable. I urge all instructors to carefully review the contents of

these kits and the hazards associated with the test materials before

purchasing and using the kits.

B. Assessed classroom setting and availability of safety equipment.

Our safety evaluation also included a review of the how the classrooms were

equipped and the safety practices utilized by the staff. During this

assessment, I found that the majority of the classrooms were not equipped

with emergency eyewash units or chemical fume hoods. We also noted a

significant shortage in terms of safety glasses, protective gloves and

aprons. During training sessions, we reviewed the need to use and maintain

various safety equipment. We also reminded the staff of the Massachusetts

state law requiring the use of protective eyewear when chemicals are used in

an educational setting. As a result of this review, new safety supplies were

purchased so that each classroom was equipped with an emergency eyewash and

an adequate amount of protective equipment. Based on the type of

experimentation conducted by the staff, it was determined that the potential

impact on air quality was minimal and as a result the widespread

availability of a chemical fume hood was not considered critical at the

middle school level at this time.

C. Established a chemical use review policy.

All materials utilized within the middle and elementary schools are subject

to the chemical use review policies adopted for the school system. It is now

the responsibility of the instructional team leaders and the School Chemical

Oversight Committee to review and monitor chemical use by these staff

members for the following parameters: a) health and safety hazards,

potential impact on air quality, c) need for protective equipment, and d)

the generation of hazardous waste.

D. Reviewed and improved chemical storage.

In general, the art supplies were found to be stored in one or two

classrooms at each school. The major modification to the storage of these

materials was to re-located these materials to lockable cabinets or closets

and to label these areas for emergency responders. The individual classrooms

at the elementary schools were inspected for educational kits containing

chemistry. The bulk of this chemistry was disposed of as obsolete materials

via the municipal hazardous waste disposal program. The chemical inventory

maintained by the middle school science department was removed from the

classrooms and re-located to a central secured storage closet as a means to

enhance security and control.

E. Other hazard noted - kilns.

While reviewing the art supplies in the middle and elementary school, I

noted that all the kilns located at these schools vented directly into the

schools. As a result, carbon monoxide, volatile organic materials and other

emissions were being released into the schools whenever the units were

fired. This resulted in a degradation of the indoor air quality of these

schools. This problem was addressed by installing the appropriate ductwork

and exhaust fans to vent the units outside.

Systemwide

In addition to establishing departmental chemical review responsibilities,

the School Committee also created a Chemical Oversight Committee. The intent

of this was that the Oversight Committee would assist with the departmental

reviews as needed and to monitor the quality of these reviews. This group

also is available to provide technical assistance and guidance to school

personnel.

Lessons learned:

The following is a summary of significant lessons I noted during the

investigation of environmental, and health and safety issues involving the

Burlington public school system.

1. Be persistent: Change does not come easily and as in our case if

motivation for the changes comes from outside the school system it is likely

that you will encounter greater resistance to change.

2. Inspect and verify: Two heads are better than one. Someone must review

your actions in order to verify the accuracy and completeness of the task.

In addition, the reviewer may have a different perspective and may note

something that was originally overlooked.

3. Provide staff with training and guidance: The staff must be provided

with training and guidance to understand the significance of EHS issues in

the classroom and the potential hazards and liability associated with these

concerns. Training should be conducted during the initial phase of

investigating EHS issues so that the staff can participate with the

investigation and resolution. Annual refresher training should also be

initiated.

4. Establish staff accountability for chemical use and misuse: The school

system should adopt formal policies requiring the staff to review chemicals

and experimental procedures for EHS concerns. The school system should also

adopt chemical storage requirements as a means to control access and prevent

the theft of materials. This system will not prevent all accidents from

occurring but it does provide accountability for overlooking obvious hazards

and sloppy chemical management.

5. Review the text and reference materials used by the staff for

instructions regarding EHS issues: When I reviewed the text and reference

materials used by the staff, I found that most material prepared prior to

1985 did not provide a discussion of the EHS issues associated with chemical

procedures. I also noted that the staff relied heavily on reference

materials and chemical disposal guidance provided by their chemical

supplier. I found the bulk of this information to be insufficient and

frequently illegal. I recommend that every school system acquire text books

and reference materials which describe proper chemical handling and disposal

methods. You should also contact federal, state and local environmental, and

health and safety agencies to determine if any more specific requirements

exist for your area. In general, I would hesitate to dispose of any

chemistry via a sanitary drain or to try to chemically neutralize any

material without first consulting your regional agencies.

Tips and suggestions:

1. Use a smoke bomb to test mechanical ventilation: This simple and

inexpensive test can provide you with a quick and easy qualitative

assessment of the function of a chemical fume hood or kiln exhaust. The use

of brightly colored smoke will enable you to easily determine if exhaust may

be escaping from the test unit, the ductwork associated with the unit, or if

the exhaust is re-entering other portions of your ventilation system. This

is only a quick and dirty analysis designed to check for major problems.

This approach does not replace the need to have a trained professional

inspect, maintain and calibrate these units.

2. Seek assistance from local resources: We are all in this together. Tap

into the assistance that is available from federal, state and local

environmental, and health and safety agencies. Do not overlook local

residents, corporations, and medical facilities. These groups have a vested

interest as parents and tax payers, and are frequently willing to provide

technical expertise and assistance.

3. Consider chemical compatibility when storing your inventory: Do not

store your materials in alphabetical order but by chemical hazard

classification. Failure to consider chemical compatibility prior to storage

could cause reactive materials to be stored together and result in a small

fire becoming a catastrophic hazardous materials incident. Your emergency

responders will appreciate your efforts. For your reference Flinn Scientific

Incorporated of Batavia, Illinois (1-800-452-1261) provides a chemical

storage plan based on chemical compatibility in their supply catalog.

(Please note: EPA does not endorse specific vendors. This information is

provided by the Burlington Board of Health as one potential source of

assistance.)

4. Adopt a microscale curriculum: The microscale concept is to alter your

experimental procedures so that you use approximately 1/10th of the amounts

originally planned for by the author. Conversion to microscale may require

the purchase of new glassware, however the benefits include the development

of better techniques by the staff and students, decreased chemical usage,

lowered exposure to hazardous materials, and a reduction in hazardous waste

generated. For more information describing microscale contact: Dr. Mono M.

Singh, Director, The National Microscale Chemistry Center, 315 Turnpike

Street, Merrimack College, North Andover, Massachusetts 01845, Telephone:

(978)837-5137, Fax: (978)837-5017, or via e-mail at 'msingh@...'.

5. Adopt a less toxic curriculum: As a I mentioned in item 5 of the lessons

learned, you must review the curriculum to determine if safer, less toxic

alternatives can be implemented. I have found that frequently many options

exist for providing the same educational experience, however some motivation

must be provided to prompt the search for a safe alternative. I recommend

that you consult your state pollution prevention agencies for assistance. In

Massachusetts, we are fortunate to have the Office of Technical Assistance

and Surface Cleaning Laboratory. These agencies provide free, non-regulatory

pollution prevention assistance to the public. In Burlington, we have also

adopted a number of procedures presented in " 40 Low-waste, Low Risk

Chemistry Labs " , by Dugan, published by J. Weston Walch of Portland,

Maine (207-772-2846). We have found this text to provide a more detailed

discussion of EHS issues associated with the procedure combined with the use

of less toxic alternatives than normally found in most chemistry text books.

6. Hazardous chemicals: During my travels, I have encountered several lists

of high risk science chemicals. The following is a compilation of these

lists. This list is illustrative and is not an exhaustive list of

potentially hazardous chemicals. Each chemical requires thorough risk

evaluation by a qualified professional prior to use.

Explosive/fire hazard

potassium chlorate benzoyl peroxide carbon disulfide

collodion cyclohexene 1,4-dioxane

ethyl ether isopropyl ether tetrahydrofuran

styrene phosphorus pentoxide yellow/white phosphorus magnesium powder

formic acid (aged) anhydrous aluminum chloride lauryl peroxide

potassium metal nitroglycerin nitrogen trioxide

2,4-dinitrophenol 2,4-dinitrophenolhydrazine perchloric acid

low flash point solvents aged & excessive oxidizers thermit

picric acid leaking gas cylinders sodium metal

lithium metal divinyl acetylene vinylidene chloride

sodium amide acetalmethyl i-butyl ketone ethylene glycol

dimethyl ether (glyme) vinyl ethers dicyclopentadiene

diacetylene methyl acetylene cumene

tetrahydronaphthalene methylcyclopentane t-butyl alcohol

butadiene tetrafluoroethylene vinyl acetylene

vinyl acetate vinyl chloride vinyl pyridine

chlorobutadiene/chloroprene indene furan

all peroxides all isocyanates picramide

isoprene all aliphatic ethers aminoguanidine nitrate

ammonium dichromate calcium carbide cylcohexane

methyl ethyl ketone methyl methacrylate petroleum ether

phosphorus, red potassium chlorate sodium azide

sodium sulfide toluene xylenes

Reactives

bromine hydrofluoric acid titanium tetrachloride

osmium compounds aluminum chloride antimony trichloride

lead nitrate lithium, metal lithium chloride

potassium, metal potassium chlorate sodium, metal

potassium permanganate sodium chlorate sodium chromate tetrahydrate

sodium dichromate sodium nitrite sodium sulfide

stannic chloride nitric acid sulfuric acid

hydrochloric acid uranyl nitrate

Toxic

ammonium metavanadate caffeine colchicine

lead compounds mercury mercury compounds

nicotine sodium azide cyanide salts

thioacetamide thiourea brucine sulfate

unsealed radioactive sources o-toluidine ammonium oxalate

antimony antimony trioxide arsenic trichloride

arsenic trioxide barium chloride calcium fluoride

chloretone chloroform chromium oxide

chromium potassium sulfate cobalt nitrate hexahydrate cylcohexane

p-Dichlorobenzene dichloromethane lead arsenate

lead carbonate lead chloride lead nitrate

lithium nitrate methylene chloride nickel powder

selenium silver nitrate sodium arsenate, dibasic

sodium fluoride sodium oxalate stannic chloride

uranyl acetate uranyl nitrate wood's metal (lead alloy)

thorium nitrate uranium tetrachloride

Carcinogens

arsenic carbon tetrachloride benzene

formaldehyde chloroform aniline

lead acetate acetamide acrylamide

antimony trioxide arsenic and compounds beryllium & compounds

cadmium & compounds calcium chromate carbon black

chromium & compounds cobalt & oxides lead phosphate

mercury alkyl compounds methyl chloride nickel & soluble compounds

thorium & compounds titanium dioxide o-tolidine

o-toluidine trypan blue acrylonitrile

ammonium chromate ammonium dichromate aniline hydrochloride

ethylene dichloride hematoxylin potassium chromate

sodium chromate tetrahydrate sodium dichromate sudan IV

talc tannic acid thioacetamide

7. Encourage chemical suppliers to post MSDS's on internet: In order to

enhance your accessibility to chemical information, I urge you to encourage

your suppliers to post their MSDS databases on the internet. A number of

colleges and universities have begun this effort. Your support and

assistance will further the cause and enhance the ability of emergency

responders and medical personnel to respond to a chemical accident. Under

the heading of internet resources, I have listed several organizations that

maintain MSDS databases on the internet. Most of these groups are willing to

add new information to their existing database. I encourage you to support

their efforts.

Resources

1. Internet resources: The following is a compilation of useful internet

addresses that may assist you when researching EHS or regulatory issues.

Please note that several of these sites maintain accessible MSDS databases

for your use. These providers will also accept any new MSDS's that you or

your supplier may be able to provide.

Address: Site Description:

http://www.osha.gov/oshasoft OSHA regulations & software(fire, asbestos)

http://www.turi.org Mass Toxic Use Reduction Institute

http://www.cleaning.org Mass Surface Cleaning Lab

http://www.cdc.gov NIOSH info & toxicological registry

http://www.access.gpo.gov federal government printing office

http://www.acs.org American Chemical Society

http://www.instantref.com/tox-chem.htm chemical management info

http://chemfinder.camsoft.com searchable chemical database

http://ecologia.nier.org 35 environmental databases

http://es.epa.gov pollution prevention info

http://www.lib.uchicago.edu/~atbrooks/safety chemical safety collection

http://www.aiha.org American Industrial Hygiene Association

http://turva.me.tut.fi/~oshweb index of health & safety resources on net

http://www.artswire.org Center for Safety in the Arts

http://www.iarc.fr International Cancer Registry

http://www.ABIH.org American Board of Industrial Hygiene

http://www.pdc.cornell.edu large MSDS database

http://www.mrg.ab.ca/christie/safe1.htm searchable safety database

http://www.purdue.edu/REM chemical hygiene plan

http://www.chem.uky.edu/resources/msds.html MSDS database

http://www.siri.org EHS bonanza, MSDS's & much more

http://www.princeton.edu/~ehs/h & sguide/ safety auditing guidance

http://www.baqa.org Building air quality alliance

2. Reference books: I found the following books to be useful when evaluating

the chemical hazards present within the Burlington school system.

" Sax's Dangerous Properties of Industrial Materials " , eighth edition, 1992,

J. , Sr. editor, Van Nostrand Reinhold, New York, New York.

" Handbook of Toxic and Hazardous Chemicals and Carcinogens " , third edition,

1991, Marshall Sittig editor, Noyes Publications, Park Ridge, New Jersey.

" Fire Protection Guide to Hazardous Materials " , eleventh edition, 1994,

National Fire Protection Association, One Batterymarch Park, Quincy,

Massachusetts 02269.

Flinn Scientific Supply Catalog, Batavia, Illinois 60510, (800)452-1261 -

Chemical Storage Guidance.

" Pocket Guide to MSDS's and Labels " , and " Pocket Guide to Your Right to

Know " , Business and Legal Reports, Inc., 39 Academy St., Madison, CT 06443,

(800)727-5257.

3. Potential sources for written guidance describing school EHS issues:

The land Department of Education has publish a number of helpful

technical bulletins describing potential EHS issues in schools as well as

potential corrective action.

land Department of Education Office of Administration and Finance

Office of School Facilities 200 West Baltimore Street Baltimore, land

21201 (301)333-2508

The Center for Safety in the Arts monitors and evaluates a broad range of

health and safety concerns involving the arts and theater. This group has

also published a large volume of health and safety guidance.

Center for Safety in the Arts 5 Beekman Street, Suite 820 New York, New

York 10038 (212)227-6220

The National Microscale Center at Merrimack College has prepared guidance

describing the benefits as well as how to initiate a microscale curriculum.

The center also conducts training for those wishing to develop a microscale

program.

Dr. Mono M. Singh, Director The National Microscale Chemistry Center 315

Turnpike Street Merrimack College North Andover, Massachusetts 01845

Telephone: (978)837-5137 Fax: (978)837-5017 e-mail at

'msingh@...'.

prepared by

Todd H. Dresser

Environmental Engineer

Burlington Board of Health

29 Center Street

Burlington, Massachusetts 01803

(781)270-1956

e-mail: tdresser@...