Managing Schools’ Hazardous Materials Risk

The $12,000 fine and administrative penalties levied in January against a Los Angeles County school district highlights a common problem—mishandling of chemical storage and disposal can lead to dangerous and costly consequences for schools.

Improper Chemical Management Consequences

Chemicals used in scientific laboratories; shop classes; art and photography classes; pool and healthcare facilities; and maintenance and landscaping departments all require special management. But school district’s de-centralized supply ordering, limited knowledge of complex regulations, and absence of a chemical/compliance manager can cause problems including:

  • Lack of a hazardous materials business plan (HMBP)
  • Improper waste disposal and wastewater discharge
  • Improper universal waste management
  • Incompatible chemical storage

“The consequences of these problems are significant,” said Nicole Peacock, Dudek’s hazardous materials specialist and a professional engineer. Peacock said improper chemical storage, use, management, and reporting can result in:

  1. Explosions, fires, or toxic fumes due to mixing incompatible chemicals.
  2. School closures and costly cleanups. A spill of 250 milliliters of mercury obtained from a science laboratory lead to a $1.5M cleanup, closure of the school for 35 days, and displacement of 16 families from their homes for a month.
  3. Fines from regulatory agencies. The Los Angeles County school district was fined for improper chemical storage and failure to submit an HMBP, and the district was required to hire a full time compliance manager. In 2013, a San Diego County school district was penalized $315,000 for hazardous waste storage and HMBP violations.

Chemical Inventory and Compliance Audit

“The first step toward environmental compliance is a chemical inventory and compliance audit,” Peacock said. The recommended approach is for a hazardous materials specialist to visit the school to inventory the chemicals and identify the permitting, storage, and waste management changes required for compliance with federal, state, and local regulations.

Peacock said the chemical inventory can be used for a number of purposes, including:

  • Determining the need for and completing an HMBP
  • As a first step in source reduction
  • Determining purchasing needs and evaluating potential greener alternatives
  • Planning waste disposal
  • Identifying incompatible chemical storage

Lean Chemical Management

She said the chemical inventory should be updated annually, coinciding with the required annual HMBP update. Ongoing management should include regular inspections; proper labeling; proper waste disposal; continued removal of outdated, degraded, and unneeded/excessive quantities of chemicals; training; and spill cleanup.

Peacock recommends school districts and other industries follow the 6S concept from lean manufacturing. Lean manufacturing is a business model that focuses on limiting waste while operating cost effectively and with greater efficiency. The 6 S’s are:

  1. Safety: safe handling and storage of chemicals should always be the highest priority
  2. Sort: get rid of what isn’t necessary (source reduction)
  3. Set in order: label and organize chemicals to prevent mixing of incompatible substances
  4. Shine: keep the workspace clean
  5. Standardize: develop standard labeling and waste management procedures
  6. Sustain – continue proper chemical handling through use of checklists, regular inspections, and annual reviews

Nicole Peacock, PE is an environmental engineer and geologist in Dudek’s hazardous materials group. For more information, contact her at npeacock@dudek.com.