Evaluation of Results from 

EPA’s Schools Chemical 

Cleanout Campaign 

An Examination of Approaches and Factors 

that Impacted the Results of Programs 

Funded by EPA’s RCC Schools Chemical 

Cleanout Campaign in FY2004 

January 2007 
Acknowledgements 

This evaluation was primarily performed by Indtai, Inc. under contract with 

Industrial Economics, Incorporated (IEc) for EPA’s Office of Environmental 

Policy Innovation, under Contract EP-W-04-023 between EPA and IEc. The 

Indtai evaluation team included Shelley Rappaport, Rob Brotzman, and Tim 

Brulle. Kristina Meson and Ken Adams of EPA’s Office of Solid Waste and 

Emergency Response, and John Heffelfinger of EPA’s Office of Environmental 

Policy Innovation played technical advisory roles. This evaluation could not have 

been a success without the thoughtful insights and feedback from the state/local 

SC3 program implementers and EPA personnel in each of the ten EPA Regions. 

This report was developed under the Program Evaluation Competition, cosponsored by EPA’s Office of Policy, Economics and Innovation and the Office 

of the Chief Financial Officer. To access copies of this or other EPA program 

evaluations, please go to EPA’s Evaluation Support Division website at 

http://www.epa.gov/evaluate. 
TABLE OF CONTENTS

Executive Summary E-1 

I. Introduction 1 

II. Methodology 2 

III. Results 6 

III.A. Evaluation Question #1: Did the SC3 grantees achieve their goals? 7 

III.B. Evaluation Question #2: What factors contributed to achieving or not 

achieving results? 

15 

IV. Discussion and Conclusions 23 

IV.A. Evaluation Question #3: How can the results of these grants be used to 

inform development or improvement of SC3 programs? 

23 

IV.B. Evaluation Question #4: In the future, what can EPA do to improve 

achievement of intended results? 

33 

Exhibits 

 1: Programs Receiving SC3 Funding in 2004 1 

 2: SC3 Logic Model 3 

 3: Sample Action Items and Information Collection Approaches 4 

 4: Summary Highlights of Results from the Programs Receiving 2004 SC3 

Funding 

6 

 5: Summary of Types of Chemicals Removed from 10 SC3 Programs 10 

 6: Breakout of Results from 10 SC3 Programs 12 

 7: Stakeholder Relationships in School Chemical Cleanout Programs 27 

Acronyms 37 

Appendix 

A-1: 2004 SC3-Funded Grant Program Summaries 

A-2: Evaluation Methodology for the Evaluation of FY 2004 RCC Schools 

Chemical Cleanout Campaign Results 

A-3: SC3 Results Evaluation Interview Guide 

A-4: SC3 Results Evaluation Interviewees 
 E-1 

EXECUTIVE SUMMARY

EPA’s Schools Chemical Cleanout Campaign (SC3), a high visibility initiative operating 

as part of EPA’s Resource Conservation Challenge (RCC), strives to remove accumulations of 

potentially dangerous chemicals from K-12 schools; prevent future accumulations through 

improved chemical management; and raise national awareness of the issue. In 2004, EPA 

provided $250,000 in funding to separate and distinct state/local SC3 programs in each of the 10 

EPA Regions. Each state/local SC3 program addressed responsible chemical management, 

raising awareness, and chemical cleanout with various approaches and techniques. 

In May 2005, EPA sponsored a “Formative Evaluation” of both EPA funded and nonEPA funded SC3 programs across the country to help EPA design and implement its own 

responsible chemical management efforts. The Formative Evaluation provided information to 

improve EPA’s understanding of the processes, operations, functions, and structure that would 

best enable EPA and its partners to meet the goals for the program. 

In a separate effort in September 2005, EPA initiated this “Results Evaluation” of the ten 

SC3 programs selected for EPA funding in 2004. This Results Evaluation focused on answering 

the following primary evaluation questions: 

1. Did the SC3 programs that received EPA funding achieve their goals? 

2. What factors contributed the most to achieving or not achieving results? 

3. How can the results these programs achieved be used to inform development or 

improvement of SC3 programs? 

4. In the future, what can EPA do to improve achievement of intended results?

Indtai developed a logic model of EPA’s role in the SC3 program that presents a picture 

of how the Campaign is expected to work and identifies factors that can affect the ability of the 

SC3 program to achieve desired results. We used the logic model as a framework to guide 

collection of information about the results achieved by the ten SC3 programs. We primarily 

relied on review of documents from the ten SC3 programs and personal interviews with program 

implementers and EPA Regional personnel as data sources. 

This report presents data and analysis as it relates to the above evaluation questions. 

While we do not compare or draw conclusions about the effectiveness of the ten programs 

relative to one another, we do provide data that allows for an improved understanding of the 

effectiveness of different SC3 approaches and techniques. We identify numerous best practices 

in SC3 areas such as chemical disposal, creating partnerships, funding, and training that the 

programs used to achieve results. A discussion of critical success factors, impediments, and 

costs provides insight into factors that impacted results and can be used to inform development 

or refinement of other SC3 programs. 

The results illustrated that all of the ten SC3 programs showed progress in tackling 

chemical mismanagement: more schools are safer; more children are being protected from 

dangerous chemical risks; awareness about responsible chemical management and safety has 

increased; and additional mechanisms are in place to stimulate behavior change. Without the 

EPA funding, the majority of SC3 programs would probably have NOT been able to accomplish 
 E-2 

the aforementioned results and taken steps to rid schools of outdated, excess, and dangerous 

chemicals. Below we present a high-level summary of results. 

Regarding Evaluation Question #1: Did the SC3 programs that received EPA funding 

achieve their goals? The SC3 programs achieved their broad goals and objectives of removing 

dangerous chemicals (approximately 95% of chemicals removed were hazardous), reducing 

risks, and promoting responsible chemical management. A variety of metrics were used to 

measure the results (e.g., quantity and types of chemicals removed, school population affected) 

as well as capture positive unintended results such as additional funding contributions that 

resulted from SC3 achievements. 

Regarding Evaluation Question #2: What factors contributed the most to achieving or not 

achieving results? We identified numerous critical success factors and innovative techniques that 

impacted attaining results. The critical success factors may be useful to mitigate the various 

implementation impediments, such as not having an established baseline assessment of the 

chemical management problem or competing school priorities. We found that disposal costs 

greatly impacted achieving results and represent the greatest cost in SC3 program budgets, but 

there are also a variety of other costs, such as personnel time, to be aware of. 

Regarding Evaluation Question #3: How can the results these programs achieved be used 

to inform development or improvement of SC3 programs? We found that not only the results, but 

also the unique approaches to program implementation and sustainability provide excellent real 

world examples and best practices for other SC3 programs to consider. While not all of the 

approaches are a good fit for every SC3 program, the report provides a myriad of methods to 

support the various programmatic elements of SC3 programs such as chemical inventorying and 

long-term responsible chemical management. 

Regarding Evaluation Question #4: In the future, what can EPA do to improve 

achievement of intended results? Interviewees identified ways EPA could help, at the national 

level, with the development and refinement of state/tribal/local SC3 programs. Most agree that 

EPA should act as a resource, providing information or clarification on issues ranging from 

RCRA concerns (e.g., generator status) to “how to” guides to developing SC3 programs to 

facilitating partnerships with other federal and state agencies to support SC3 initiatives. 

This document presents our detailed findings of the Results Evaluation, and focuses on 

identifying approaches and other factors that had the greatest impact on the results achieved. We 

conclude by presenting recommended next steps for EPA to consider as they develop a national 

schools chemical cleanout campaign. 

Summary Highlights of Results from the Programs Receiving 2004 SC3 Funding

Schools Cleaned Out About 500 

Population/children affected 585,000+ 

Chemicals Removed 72,000 pounds + 

Personnel Trained (e.g., teachers, administrators, facilities) 1,500 + 

Funding in Addition to EPA SC3 (not including in-kind services) $235,000+ 
 1 

I. INTRODUCTION

In 2004, EPA launched the Schools Chemical Cleanout Campaign (SC3), a high visibility 

initiative operating as part of EPA’s Resource Conservation Challenge (RCC). The Campaign is 

a cooperative effort amongst EPA’s Office of Solid Waste and Emergency Response (OSWER), 

Office of Children’s Health Protection and Environmental Education (OCHPEE), Office of 

Prevention, Pesticides, and Toxic Substances (OPPTS), Office of Air and Radiation (OAR), and 

the Regions, and uses a variety of innovative approaches to achieve its goals: 

(1) Remove accumulations of potentially dangerous chemicals from K-12 schools; 

(2) Prevent future accumulations through improved chemical management; and 

(3) Raise national awareness of the issue. 

In 2004, the RCC funded separate and distinct SC3 programs in each of the 10 EPA 

Regions. Each program received approximately $25,000. These programs were designed and 

implemented to address each of the aforementioned goals. The programs each took unique 

approaches in achieving results. The 2004 funded programs are listed in Exhibit 1. (Please see 

Appendix 1 for detailed program summaries). 

Exhibit 1 

Programs Receiving SC3 Funding in 2004 

EPA Region SC3 Program 

1 Rhode Island Chemical Safe Schools Committee 

2 Rochester City School District (NY) 

3 NW Tri-County Intermediate Unit’s Safer Schools 

Initiative (PA) 

4 Tennessee Department of Environment and 

Conservation’s Safe SC3 Program 

5 Osh Kosh/Green Bay School Chemical Collection 

Program (WI) 

6 Ft. Worth Independent School District’s Clean Out 

Your Chemicals Project (TX) 

7 Rehab the Lab (IA) 

8 Wyoming Department of Education’s Safer Schools 

Initiative 

9 Los Angeles Unified School District Pilot Program for 

Laboratory Chemicals (CA) 

10 Idaho Chemical Roundup 
 2 

Separate from this effort, in May 2005, EPA sponsored a “Formative Evaluation” of both 

EPA funded and non-EPA funded SC3 programs across the country to help EPA design a 

national SC3 program. The Formative Evaluation1 provided information to improve EPA’s 

understanding of the processes, operations, functions, and structure that would best enable EPA 

and its partners to facilitate the goals for the program. 

In September 2005, EPA initiated this “Results Evaluation” of the ten SC3 programs 

selected for EPA funding in 2004. This document summarizes our findings of the Results 

Evaluation, and focuses on identifying approaches and other factors that had the greatest impact 

on the results achieved. Together with the Formative Evaluation, programmatic analyses, and 

other information, EPA plans to use the findings of this evaluation to develop a national SC3. 

This evaluation project also aims to improve future EPA SC3 funding competitions, heighten 

awareness of EPA’s national and regional SC3 efforts, and provide model approaches and best 

practices for jurisdictions initiating their own chemical management programs. 

This Results Evaluation focused on answering the following primary evaluation 

questions: 

1. Did the SC3 programs that received EPA funding achieve their goals? 

2. What factors contributed the most to achieving or not achieving results? 

3. How can the results these programs achieved be used to inform development or 

improvement of SC3 programs? 

4. In the future, what can EPA do to improve achievement of intended results?

The remaining sections of the report present the evaluation methodology, results, and 

conclusions. The results section presents our findings, organized according to evaluation 

questions #1 and #2. The discussion/conclusion section serves dual purposes: it presents 

findings of evaluation questions #3 and #4, and addresses forward-looking aspects of the SC3 

program as well as recommendations and next steps that EPA may consider as it continues to 

develop a national campaign. 

II. METHODOLOGY

To frame the evaluation, Indtai2

 created a logic model that reflects EPA’s current role in 

the SC3 program as well as potential role in a more robust national SC3 effort (see Exhibit 2). 

The logic model presents a picture of how the Campaign is expected to work and identifies 

factors that can affect the ability of the SC3 program to achieve desired results. The logic model 

links programmatic inputs, activities, and outputs to various stakeholder groups or customers. It 

also captures desired outcomes over time (e.g., increased awareness, changed behaviors). EPA 

can use this logic model as a tool to identify factors influencing program effectiveness. Indtai 

used the logic model to ensure we crafted evaluation questions and information objectives that 

best measured the impacts of the 10 SC3 programs that received EPA funding in 2004. 

 

1

 Building Successful Programs to Address Chemical Risks in Schools: Recommendations from an Evaluation of 

Selected School Chemical Cleanout and Prevention Programs. For further information, see http://www.epa.gov/sc3. 2

 Indtai, Inc. was primarily responsible for conducting this evaluation under contract with Industrial Economics, Inc. 
 3 

*Keeping in mind potential geographic (urban vs. rural) and socio-economic considerations 

External Factors: Laws/Regulations 

InexasinInK

School Impacts Inventory 

chemicals 

 Cleanout 

chemicals 

 Implement P2 

activities

Facilitate partner contributions 

Behavior/Process Adopt a “culture” 

of chemical safety in schools 

 Identify a 

“champion” 

 Increase 

communication among relevant school staff 

 Develop 

chemical storage/handling/ disposal/purchasing procedures 

 Provide routine 

training/ education opportunities for staff including 

Working Groups 

Regulatory• State/Local/ 

Tribal environmental and health agencies 

• Fire/Safety/ 

Emergency Response 

Parents 

Increase awareness of problem Understand Risk  Recognize 

hazards 

Increase awareness of potential solutions/options to address chemical mgmt concerns Use in short/long 

term planning 

 Pollution 

prevention 

 Practices/policies  Leveraging 

partners 

 Training 

opportunities 

Identify roles and responsibilities of industry/partners Explore alternative funding sources 

Non-Regulatory• Industry • Membership 

Assoc 

• Advocacy 

Groups 

National Coordination• Priority 

setting 

• Identification 

of high risk schools 

Guidance on chemical management 

EPA Staff• RCC • Schools 

Advisory Group 

• Other 

Program Offices 

Funding• Federal • State • Local • Private/ 

non-profit 

Organizations with Ties to Schools/ Potential Partners 

Provide SC3 grants for chemical cleanout and prevention 

Existing EPA Partnerships with Industry 

Outreach and Awareness Form partnerships Provide tools to assist chemical management activities• Best 

Practices 

• Case Studies • Models 

Exhibit 2: EPA Office of Solid Waste: Schools Chemical Cleanout Campaign 

Intermediate 

Resources Activities Outputs Customers Short-term 

Leverage Chemical management knowledge of facility/ maintenance/ground

Results, Data, & Metrics # schools 

cleaned up 

 # schools 

inventoried 

 Amount of 

chemicals removed

Awareness Communication• Brochures • Website • Speaking 

engagements 

• Publicity and 

Recognition 

School/District*• Administrators • School Board • Purchasing 

Agents 

• Teachers • Facilities/ 

Maintenance/ Grounds

Cmliwb•     
 4 

Indtai developed information objectives or “action items” corresponding to each of the 

four aforementioned evaluation questions. The action items corresponded to the type of data we 

anticipated collecting, both quantitative (e.g., number of schools cleaned out or number of 

teachers trained) and qualitative (e.g., critical success factors). For each of the action items, we 

presented our approach to information collection (e.g. see Exhibit 3 for information collection 

approaches used to answer Evaluation Question #1). We used three primary methods throughout 

the information collection process: document review, data mining/analysis, and personal 

interviews. To the greatest extent possible, Indtai leveraged quantitative and qualitative data we 

collected as part of the Formative Evaluation.3

Exhibit 3 

Sample Action Items and Information Collection Approaches 

Evaluation Question #1: Did the SC3 programs that received EPA funding achieve their 

goals? 

Information Action Item Information Collection Approach 

Identify goals and/or targets (e.g., 20 teachers trained 

per year or X amount of chemicals removed)

Document Review, Interview 

Collect demographic and geographic information of 

population served by program (e.g., rural v. urban, 

school size)

Data Collection, Document Review, 

Interview 

Collect results that align with goals/targets (e.g., amount 

of chemicals, # training sessions)

Data Collection, Document Review, 

Interview 

Collect unintended results (e.g., activities beyond 

program scope)

Data Collection (potentially), 

Interview 

Identify performance measures/metrics Document Review, Interview 

Measure the impact of EPA funding on goal 

achievement

Interview 

 

We used the SC3 logic model along with data and knowledge from previous SC3 

program analyses to inform development of the interview guide and questions. The interview 

questions corresponded to the information action items4

. Indtai used a dynamic approach to 

interviewing, allowing us to tailor questions according to the interviewee’s background and 

expertise. For instance, if an EPA Regional SC3 lead was not familiar with the behavior change 

aspects of the program, we reserved those questions for the program leaders at the state/local 

level. 

Indtai coordinated with EPA personnel to identify potential interviewees. We spoke with 

EPA Regional personnel that administered and oversaw the funding. We also spoke with 

state/local SC3 program personnel, which included program partners (hereafter referred to as 

“program implementers”), to gain different perspectives and insights5

. Indtai had spoken with 

 

3

 See Appendix 2 for complete methodology outlining action items for each evaluation question. 

4

 See Appendix 3 for interview guide. 

5

 See Appendix 4 for list of interviewees 
 5 

many of the participants during the Formative Evaluation, so we had already established a 

rapport. 

Indtai spoke or coordinated via email with EPA Regional personnel prior to contacting 

the SC3 program implementers. In all Regions, we contacted EPA personnel. There was one 

instance in which we were unable to get in touch with the primary program implementer, the 

Rhode Island Department of Health (RIDoH), but did talk to a partnering organization (for the 

Rhode Island Chemical Safe Schools Committee (SSC)). Indtai spoke with the RIDoH during the 

Formative Evaluation and used that information for this evaluation. 

Indtai followed the established quality assurance plan while collecting information for 

this evaluation. Personal interviews included two Indtai personnel to ensure we captured 

information accurately. We asked for the most current versions of reports, data, and other 

documents from EPA personnel and the program implementers. We also sent each of the 

program contacts a follow-up email containing the data we captured as part of Exhibit 6 for their 

review and concurrence. 

Once all of the data was collected, Indtai compiled, organized, and prepared the data for 

analysis according to evaluation question. We identified any data quality or completeness issues 

that may impact our analysis and presentation. For example, the data quality surrounding the 

quantities of chemicals removed from schools was highly variable among the programs. We 

worked with the program implementers to try and address those concerns. Wherever necessary 

throughout this report, we note any data quality or completeness issues that may have impacted 

the results. 

We presented quantitative results data in summary tables to illustrate both the “rolled up” 

data on all of the ten programs combined (Exhibit 4) as well as a table that shows a breakdown 

for each program (Exhibit 6). Indtai identified common themes, practices, programmatic 

elements, and other information across the ten grant programs that answered the evaluation 

questions. We also noted unique examples of lessons learned and best practices in the findings. 

We encountered some difficulties in interpretation and attribution of some of the data. 

For SC3 programs that were part of broader or existing efforts or supported simultaneously by 

multiple funding sources, it was often difficult to attribute the specific “results” data to the 2004 

EPA SC3 funding. This was especially true in Iowa where prior efforts and the 2004-funded 

efforts blended together. There were also issues with data completeness and quality that 

stemmed from the types of data collected and methods used to track or measure. For additional 

information on data quality, please see the Metrics subsection of this report under Section III – 

Results. 

Each SC3 program and approach is reflective of highly individualized and unique 

circumstances. While programs may share similar programmatic elements (e.g., chemical 

inventories), that does not equate to comparability. Therefore, Indtai did not attempt to make 

any determinations of the relative success of any of the programs reviewed. For example, it is 

not fair or accurate to compare the amount of chemicals removed by each program since there 

are multiple factors surrounding each program’s approach to cleanout. This report does provide 
 6 

quantitative and qualitative data to help improve understanding of effectiveness of particular SC3 

approaches and techniques as well as identifies best practices. 

III. RESULTS

This section presents the results of our data collection efforts to answer the evaluation 

questions. The findings are organized according to evaluation question. The information is 

primarily a result of insights from interviewees and represents common or recurring themes 

amongst the interviewees. Where appropriate, we provide specific, real-world examples from 

the ten SC3 programs. 

The big picture question this evaluation sought to answer was “Are Schools Safer?” 

Consistently, according to the results, the answer is “Yes.” The SC3 programs resulted in: 

• Removal of dangerous chemicals; 

• Decreased or mitigated risk of chemical accidents or incidents; 

• Improved safety (e.g., better chemical storage, lab safety); 

• Safer learning environments for children; 

• Increased awareness of chemical management issues in schools and organizations 

impacting schools; and 

• Development and implementation of responsible chemical management practices. 

Specifically, Exhibit 4 presents a roll-up summary of the ten SC3 programs6

. Please see 

Exhibit 6 for a breakout of results for each grant program. 

 

6

 This data was compiled from 2004 funded program reports to EPA, websites, articles, and personal interviews. 

Indtai did not independently verify the validity of the data, but it was reviewed and approved by SC3 program 

implementers. In the methodology section we discussed data quality and completeness issues. 

7

 Wyoming and Iowa data was only available by school district therefore we present an estimated range of number 

of schools. 

8

 Due to the complexity of funding sources in Iowa’s program, we had difficulty attributing the portion of Iowa’s 

data to the 2004 EPA funds. Based on data verified by EPA Region 7, we include 20,000 pounds in this table. The 

amount could be as high as 120,000 pounds. 

Exhibit 4 

Summary Highlights of Results from the Programs Receiving 2004 

SC3 Funding

Schools Cleaned Out About 5007

Population/children affected 585,000+ 

Chemicals Removed 72,000+8

Personnel Trained 

(e.g., teachers, administrators, facilities)

1,500 + 

Funding in Addition to EPA SC3 

(not including in-kind services)

$235,000+ 
 7 

With all of these strides, also comes a word of caution from evaluation participants. 

Many are still concerned about “repeat offenders” (i.e., inappropriate chemical acquisition and 

storage after the baseline cleanout). Factors such as lack of compliance mechanisms, staff 

turnover, funding concerns, and inadequate institutionalization of responsible chemical 

management practices, could hinder long-term sustainability of these programs and may result in 

the need for future chemical cleanouts. 

Creating safer schools requires awareness and knowledge of the unique set of 

circumstances surrounding individual schools. There is no “one size fits all” approach to SC3 

programs. While there are common elements that are proven to achieve results, the 

implementation and program sustainability methods and approaches vary. Throughout this 

report and specifically in response to evaluation question #3 (see section IV.A), we present 

demonstrated approaches and practices for consideration by EPA and SC3 program 

implementers. Program implementers should be aware that before considering any of the 

approaches or techniques in this report, a thorough assessment of your individual situation and 

needs is critical (e.g., understanding what regulations are applicable in your state/locality). 

III.A. Evaluation Question #1: Did the SC3 programs that received EPA funding achieve their 

goals? 

 The information below was obtained through interviews and represents the opinions and 

thoughts of EPA Regional personnel and SC3 program implementers. We begin with a 

discussion of common program goals and objectives prior to reporting the results. We then 

present the results from each of the 10 programs that received EPA funding in 2004 (Exhibit 6). 

To facilitate understanding of the results presented in Exhibit 6, we include a discussion on 

common SC3 program metrics—a critical component to documenting achievements. We also 

identify “unintended” results. Lastly, we discuss the role of funding in achieving results. 

Common Program Goals, Objectives, and Targets

 As a condition of the EPA SC3 funding, all programs 

had to address responsible chemical management, raising 

awareness, and chemical cleanout9

. This, however, did not 

mean they all had the same goals or targets or use the same 

approaches to achieve goals10. Generally, the programs’ 

goals and objectives were broad and focused on removing 

dangerous, outdated, or excess quantities of chemicals, risk 

reduction, and prevention. Most programs specified target 

areas such as chemical laboratories, but some did not. See 

the text box for sample goal and objective statements. 

 

 

9

 Most chemical removal was accompanied by a chemical inventory either of the entire school or of the chemicals 

slated for removal and disposal. 

10 Please see Section IV for a discussion on approaches to achieving results. 

Sample SC3 Goals/Objectives

“To enhance processes and 

procedures for the disposal of 

chemicals, hazardous waste, and waste 

reduction, and management.”—Ft. 

Worth Independent School District 

Program 

“To reduce health hazards associated 

with hazardous chemicals in the 

laboratories, and to reduce release of 

hazardous chemicals from the storage 

area into the environment.”—Los 

Angeles Unified School District
 8 

A few programs set a target range of the number of schools they wanted to reach or at 

least estimated the number of schools that would be eligible to participate. In certain cases, 

programs specified geographic areas or economically disadvantaged areas as targets. 

As for training and awareness, all felt it was necessary, but that did not necessarily equate 

to a target or goal. Some funding applications did note venues and opportunities they hoped to 

leverage to provide training or set goals for the number of sessions they hoped to complete 

during the project period. In the Tennessee Department of Environmental and Conservation 

(TDEC) proposal, forums such as teacher in-service workdays, workshops, Tennessee Science 

Teacher Association meetings, and EPA’s Safe School Roundtable were highlighted as events 

and venues to target for training and awareness11. 

Results

Metrics 

Developing metrics to measure the impact of SC3 programs is a critical step in 

determining the program’s impact on the target populations. While all of the ten SC3 programs 

had some type of metrics12, the absence of baseline chemical inventories or assessment of overall 

chemical management issues resulted in the inability to fully determine SC3 program impacts. 

Most programs did capture approximate amounts of chemicals removed and other measurable 

results that positively impacted the targeted school populations. 

Below, we discuss SC3 metrics typically used by the ten programs receiving EPA SC3 

funds in 2004. In certain instances, we also present common difficulties and issues that SC3 

program implementers should be aware of as they develop and implement metrics. The data that 

was captured using these types of metrics, is presented in Exhibit 6 for each of the 10 SC3 

programs that received EPA funding in 2004. 

• Number and Type of Schools/School Districts Served: This captures the number and 

type (e.g., high schools, vocational) of individual schools or the number of districts 

that have participated in the SC3 program. This metric can be further delineated by 

capturing the number of schools that participated in aspects of the program (e.g., 

cleanout only, training). For purposes of this evaluation, this metric primarily 

represents only those schools that conducted chemical cleanout. Where possible, 

in Exhibit 6, we denoted where programs captured more specific data that went 

beyond the number of schools that conducted cleanout. For example, the Osh Kosh, 

Wisconsin SC3 program noted the number of schools that participated in on-site 

audits. In Idaho’s Chemical Roundup, one school received a chemical storage cabinet 

in lieu of cleanout assistance. 

 

11 SC3 EPA 2nd and 3rd Quarterly Report, October 1-2004-June 30, 2005. 12 On July 8, 2004 OSW disseminated a memo to Regional SC3 leads that discussed metrics they should consider 

including in grants. 
 9 

• Quantity of Chemicals Removed: This captures the amount, usually measured by 

volume or mass of chemicals removed from a school. Some programs reported this 

metric in terms of the number of containers of chemicals (e.g., two bottles of sulfuric 

acid) removed from schools. Programs encountered occasional difficulties in 

reporting the true amount of chemicals removed. The most common problem was 

difficulty converting various chemical volumes/weights in order to aggregate amount 

of chemicals removed (e.g., calculations requiring knowledge of chemical densities to 

convert to pounds). Some of the program implementers did not have a chemistry 

background, hindering their ability to summarize data (e.g., convert different 

measurement into a comparable format). Many sought assistance for this task from 

others in their organizations or partners. Also, some used the number of containers 

removed as a proxy for the true amount of each chemical removed, resulting in a less 

exact metric. In a few cases, improved storage or containment practices were also 

noted, such as purchase of a chemical storage cabinet. Please see Exhibit 6 for details 

on each program. The quantities of chemicals removed from each program were 

highly variable due to the unique circumstances and approach to each SC3 program. 

Programs collected this data from a variety of sources. The most common ways were 

chemical inventories, packing lists, and waste manifests. Others supplemented this 

information with written reports and personal conversations to obtain anecdotal 

information. 

• Type of Chemicals Removed: This reports the classification of chemicals removed. 

Classifications used by programs widely varied. Some were very specific, breaking 

down each chemical by name (e.g., potassium chloride or ammonium nitrate). Others 

used broad classifications like hazard classes or categories such as hazardous, toxic, 

flammable, corrosive, explosive. Some SC3 program’s list of chemicals contained 

substances that were not hazardous, but still removed (e.g., olive oil, chalk). Exhibit 

5 presents a summary roll up of data on types of chemicals removed from the ten SC3 

programs. 
 10 

All Regions Chemicals by Mass

Corrosives

15.3%

Toxics and Poisons

23.9%

Ignitables, Reactives, 

Explosives and Oxidizers

23.8%

Carcinogens and Expected 

Carcinogens

4.7%

Not Harmful

2.9%

Other

8.1%

Multiple Hazards

21.3%

• Cost of Cleanout: Expenditures related to chemical cleanout. These can be both 

financial and in terms of personnel/labor hours. Typically, programs captured the 

costs related to chemical inventorying, packaging, and disposal. Disposal represents 

the largest part of cost. Typically, we found most cleanouts range from $2,000-5,000 

per school.13 Some programs also tracked internal labor/personnel hours. These 

hours were not solely related to chemical cleanout, but also may have included 

logistics planning, technical assistance, outreach, and training. 

• Other Chemical Management Costs: Some found it useful to track expenditures 

related to outreach, communications, technical assistance, and training. In addition to 

labor hours, typical costs included stipends or financial incentives (e.g., financial 

incentives for teachers to attend training sessions) and printing and publishing costs. 

 

13 Additional information on potential costs of cleanout can be found beginning on page 21 of this report. 

Exhibit 5: Summary of Types of Chemicals Removed from 10 SC3 Programs 

*Data compiled by SAIC
 11 

• Number of Training Sessions/Number of Personnel Trained: This captures the 

number and type of training sessions provided as part of the SC3 program. It also 

reports the number and type of personnel trained (e.g., teachers, facilities, school 

administrators). 

• Other Funding Contributions: This metric reflects the financial and in-kind 

contributions in addition to EPA’s SC3 funds. Contributions made by program 

partners as well as by individual schools were sometimes reported as part of the total 

funding used to achieve results. For example, the Los Angeles Unified School 

District (LAUSD) broke down the portion of the program costs attributed to the EPA 

funds and monies contributed by LAUSD’s Office of Environmental Health and 

Safety (OEHS). 

One program had a metric that related to SC3 program sustainability at the individual 

school level. Tennessee Department of Environment and Conservation’s (TDEC) program 

developed a metric, “establishment of a long-term program.” Another aspect of sustainability is 

behavioral change. None of the ten programs had a formal metric to measure behavior change or 

awareness, but were able to provide anecdotal information (e.g., greater awareness among 

teachers about green chemistry, implementation of chemical hygiene plans). Most interviewees 

commented that it would be very useful to capture this information, but they feel it was too early 

to be tracking it. 

A few programs took a slightly different approach and also incorporated evaluation 

questions to help assess their performance and results. The NW Tri-County Intermediate Unit 

(IU) used the following to assess results14

: 

• What worked, what didn’t work? 

• What improvements could make a more successful program? 

• What are the lessons learned from this effort? 

• What were the actual costs involved broken out by budget category? 

• How can the program be conducted on a much larger scale? 

 In Exhibit 6 below, we present the results from each of the ten SC3 programs. The 

information was gathered from interviews, program reports, articles, and other SC3 program 

documents. As noted earlier in the methodology section, we encountered some issues with data 

completeness and quality. This table reflects the most current data we were able to get and was 

verified by the primary point of contact (and person we interviewed) for each program. The 

school populations affected was estimated using data from http://www.greatschools.net/.

15 If we 

had individual school names, we looked those up and used their enrollment numbers. If we did 

not have specific school names, we used averages of school size.

 

14 From “Safer Schools Initiative-Summer 2004- The Northwest Tri-County Intermediate Unit and P3ERIE” 15 Great Schools is an independent nonprofit organization founded by a former teacher, that provides information to 

help parents and others make informed decisions that supports their children’s education and improves schools in 

their community. The site contains profiles of over 120,000 schools that contain enrollment data, test scores, and 

other information. 
Key

Φ - State Education Agency 0 - State/Local Environmental Agency K - State/Local Public Health Agency 

) - Business/Industry Ε - Local School District % - Other Community Partnership - US EPA 

12 

Exhibit 6: Breakout of Results from 10 SC3 Programs 

Region 1 - 

RI 

Region 2 - 

NY 

Region 3 - 

PA 

Region 4 - 

TN 

Region 5 – 

WI 

Region 6 - 

TX 

Region 7 - 

IA 

Region 8 - 

WY 

Program Implementer 

RI Department of Health 

Rochester City School District 

NW Tri-County Intermediate Unit 

Tennessee Dept of Environment and Conservation 

EPA Region 5 Fort Worth 

Independent School District 

EPA Region 7/Metro Waste Authority 

Wyoming Department of Education 

# of schools cleaned out 

8 Schools 13 secondary 

schools 

16 schools 69 schools 57 schools with 13 

requesting on site audits 

37 Schools; 15 High ; 22 Middle 

182 of 366 schools reached 

 31 school districts (of 48 in state) 

Quantity of Chemicals Removed16

893 lbs 800 lbs solid 

1,300 gallons liquid 

267 lbs 23,000 lbs 1,982 lbs 15,000 lbs 20,000 lbs17 6,000 lbs 

School population/ children affected (# students) 

4,686 ~6,939 11,469 ~50,00018 40,760 ~21,645 269,345 53,599 

# of school personnel trained 

 Not Measured 50 science 

teachers 

14 School Representatives 

24 workshops Teachers at onsite 

audited schools were trained onsite 

Specific number not measured 

Science educators: 89; Auto/Tech: 38 

N/A 

Funding In Addition to EPA SC3 funds 

RIDEM in kind services 

Monroe County in kind staff time 

EPA Region 3: $5K; PADEP in kind services 

EPA OPPTS grant: $26K; TDEC: in kind staff time; school participation fees 

EPA Region 5: $9K 

FWISD: $55K; Schools paid portion of cost 

IA DNR: $75K 

OPPTS: $27K; Inkind staff time; schools paid portion 

Partners 

Φ 0 K ) % 

Ε % 0 Ε % K Φ 0 ) % Φ Φ 0K Ε % ) Φ 

Existing Chemical Management Regulations 

a a a a 

16 Approximately 95% of the chemicals removed from all of the 10 programs were considered to be hazardous17 Due to the complexity of funding sources in the Iowa program, it was difficult to accurately attribute the exact quantity of chemicals 

funds. EPA Region 7 provided this data. It is possible that up to 120,000 pounds could be attributed to the Iowa chemical managemen

18 This is an estimation based on the average number of students/school since we did not have the names of schools cleaned out
 13 

Unintended Results

Unintended results are those that were not expected as part of what the program is 

designed to do or achieve. These results can be both positive and negative and are important 

considerations when developing and implementing SC3 programs. Please see Section IV for 

recommendations on how to leverage unintended results. 

We asked participants about the types of results they viewed as “unintended.” 

Interviewees most frequently identified positive unintended results. These findings are presented 

below: 

• Increased awareness of school personnel not directly targeted. Programs reported 

anecdotal examples of school staff that were not the primary audience of the program 

efforts, such as facilities and maintenance, inquiring about chemical disposal options 

and showing increased awareness of chemical management. For instance, at the 

Rochester City School District (RCSD) bus garage, awareness of the program led to 

maintenance personnel asking about how to properly dispose of excess or used garage 

chemicals. For the NW Tri-County IU, the SC3 program actually opened their eyes 

to how significant this problem is not only in labs, but also in other areas of the 

school. In the future, they anticipate involving others, such as maintenance/facilities 

personnel that also have a role in chemical management.

• Created new partnerships. The SC3 programs have provided opportunities for 

organizations that do not typically work together, but have relationships to schools, to 

join forces to address responsible chemical management. The RCSD sought the 

assistance of the Monroe County household hazardous waste facility in chemical 

disposal. The relationship grew into a more formalized partnership agreement and 

ultimately resulted in lower disposal fees for school chemicals.

• Generated interest from additional areas/schools. The success of SC3 programs and 

awareness of services (and funding) offered serve as a catalyst to attracting new 

program participants. In Idaho, the scope of the program was originally focused on 

the northern region of the state, but upon hearing about the program, enough interest 

was generated that the Idaho Department of Environmental Quality (IDEQ) expanded 

the program statewide. In Tennessee, the success of initial program efforts resulted in 

private schools inquiring about participation. Also, the TDEC SC3 program serves as 

a model that has generated interest from other states in EPA Region 4 to develop 

programs. In Wyoming, the SC3 program resulted in 3-4 additional schools to do 

chemical cleanout using their own funds. 

• Gained support of upper management. SC3 program achievements have gained the 

attention and support of management with state agencies, school districts, and even 

raised awareness of state legislatures on the issue. In Idaho, the results of the efforts 

by the IDEQ Chemical Roundup project manager resulted in management support 

and a contribution of $20,000 in additional funds to expand the program statewide.
 14 

• Improved lab safety among teachers. Teachers became more diligent about overall 

lab safety, not just chemical management. There was increased awareness and 

concerted efforts to maintain equipment properly (e.g., eye wash stations, ventilation 

hoods) to create a safe lab environment for students. The Fort Worth Independent 

School District (FWISD) witnessed this behavior change by many of the teachers that 

experienced the lab chemical cleanout. While teachers in the FWISD did not directly 

assist with cleanout, they did receive education and training.

• Sparked interest from local community. In Iowa, the chemical removal and 

management efforts in schools have impacted the local community. Awareness of the 

program has been spread throughout communities by school children, parents, and 

others. As a result, the local business community has approached the Metro Waste 

Authority (MWA) to get information about chemical removal services for businesses. 

In Idaho, chemical disposal contractors that have been involved in SC3 efforts have 

begun their own chemical removal marketing efforts targeting schools. 

• Generated interest in waste minimizing and safer chemistry experiments. While 

promotion of techniques and practices such as green or micro-scale chemistry that 

serve to reduce the amount of dangerous chemicals used in laboratories were not the 

primary objectives of the majority of the SC3 programs, interviewees noticed an 

increased awareness and interest in using these techniques for lab experiments. In 

some situations, newer teachers that are more aware of these techniques are helping to 

advocate these practices in conjunction with overall chemical management efforts. In 

addition, several of the SC3 programs incorporated information about green and 

micro-scale chemistry into training and information sessions, which has spurred 

additional interest in putting these techniques into practice in the classroom.

• Resulted in development of chemical management training resources. Many of the 

SC3 programs have developed training resources and tools for teachers, 

administrators, facilities, and others. These resources are frequently available online 

and are being shared by numerous SC3 programs. Several interviewees mentioned 

other program websites that they often go to for information on training and other 

resources. For example, IDEQ’s Chemical Roundup website provides multiple fact 

sheets to assist with chemical management. 

• Increased use of existing chemical removal services. School districts or state agencies 

may provide some type of chemical removal or technical assistance service to 

interested schools. Awareness of these services has increased in some areas due to 

SC3 program efforts. In Texas, the FWISD has seen an increase in the number of 

inquiries to assist with removal of chemicals, illustrating increased interest in getting 

rid of dangerous chemicals as well as awareness of existing removal options.
 15 

Impact of EPA Funding on Achieving Results

 The majority of program implementers agreed that results would not have been achieved 

without financial support from EPA. Some programs were so dependent on the SC3 funding, 

that unless they receive future funding, they claim that they will no longer be able to assist with 

chemical cleanout. On the other hand, other programs were able to leverage the EPA funding to 

attract financial support from other organizations. The additional funding allowed programs to 

cleanout more schools, conduct more comprehensive cleanouts, and train additional staff on 

responsible chemical management. This project did not evaluate whether or not those leveraged 

funds will assist in long-term sustainability. More information on other funding sources can be 

found in section IV.A. 

III.B. Evaluation Question #2: What factors contributed to achieving or not achieving results? 

 

 This section presents critical success factors as well as factors that contributed to program 

implementation difficulties. We also highlight innovative approaches that, according to 

interviewees, positively impacted program results. Lastly, we discuss how program costs can 

impact an SC3 program’s ability to achieve results. 

Critical Success Factors

 Based on information gathered during interviews, 

we present the following factors that were most 

commonly mentioned as contributing to program 

success. This is not meant to be an exhaustive list, but 

represents the factors referred to most frequently by 

interviewees. 

• Have a program champion: A program champion 

advocates, promotes, and educates others about the 

positive benefits of SC3 programs (as well as the 

consequences of not addressing school chemical 

problems). The champion often makes the cause a 

personal one and is dedicated to ensuring successful 

program implementation. Interviewees, representing six out of ten programs, mentioned that 

the results could not have been achieved without a program champion. For instance in 

Region 7, a staff person at the Metro Waste Authority provided a significant portion of her 

time to promoting the advantages of chemical management both in Iowa and to others around 

the country. Her knowledge and enthusiasm for the cause was motivational to individual 

schools and SC3 programs. 

• Ease of program participation: Making it easy for schools to participate in SC3 programs is 

key to success. A simple program structure, minimal bureaucracy and paperwork, providing 

sufficient instruction, and emphasizing the importance of responsible chemical management 

were all noted as ways to make SC3 programs attractive to participants. The Wyoming 

SC3 Program 

Critical Success Factors

• Have a program champion 

• Ease of program participation 

• Create partnerships 

• EPA funding 

• Leverage other funding sources 

• Raise awareness of the problem 

and risks 

• Identify qualified disposal 

contractors 

• Build relationships with EPA 

Regional personnel
 16 

Department of Education (WDE) credited the simplicity of its approach as critical to 

achieving results.

• Create partnerships: The majority of the SC3 programs developed new or leveraged existing 

relationships to achieve results.19 These partnerships created roles and responsibilities for the 

partners that aligned with their areas of expertise. For example, the TDEC SC3 program 

worked with a university to develop a green chemistry manual. In Rhode Island, the 

Department of Environmental Management (RIDEM) coordinated with the Department of 

Labor to utilize existing inspection programs to assess chemical management problems. 

Also in Rhode Island, the Safe School Committee (SSC) was formed to support SC3 efforts. 

The SSC was comprised of numerous partners, including state/local agencies and 

universities, each with defined roles and responsibilities. In many instances, partners 

provided in-kind services such as personnel time. The NW Tri-County IU in Pennsylvania 

partnered with the Department of Environmental Protection to review chemical inventories.

• EPA funding: As previously stated, interviewees mentioned that they could not have 

achieved success in the absence of EPA funding. In some cases, they also could not have 

leveraged other funding without that from EPA. For instance, FWISD said that the EPA 

funding was a “catalyst” for getting their school board to contribute $55,000.

• Leverage other funding sources: Many of the programs were able to use the SC3 program 

results to secure funding from other sources. Interviewees credited the ability to reach out to 

additional schools and expand the program scope to this additional funding. Programs used a 

variety of creative ways to leverage additional funding sources.20 Idaho used the initial 

results and interest generated from their mini-grant approach to SC3. This approach offered 

schools a limited amount of funding as an incentive for the schools to cover the remaining 

cost of chemical management activities. 

• Raise awareness of the problem and risks: Efforts to educate people about the risks of 

improper chemical management is integral to attaining results. A lack of awareness can 

hinder progress, especially, if responsible chemical management is not viewed as a priority. 

The SC3 programs took steps to raise awareness among stakeholders critical to their 

programs. These included teachers, science department chairs, 

facilities/grounds/maintenance, school administrators, state environmental, agriculture, 

health, and labor agencies, and membership organizations. Methods ranged from publishing 

articles about SC3 program success to participating in conferences and events to training 

sessions. For instance, the IDEQ advertised, sent letters to chemical schoolteachers and 

principals, developed press releases, and posted notices on listservs. 

• Identify qualified disposal contractors: Identifying a knowledgeable contractor that the 

schools can trust is very important. Since schools are not typically in the business of 

chemical removal, they often need assistance in this area and rely on contractors to 

effectively and safely remove the chemicals for proper disposal. Many programs provided 

 

19 LAUSD and FWISD did not have partners aside from EPA. 

20 See section IV for more information on alternative funding sources. 
 17 

schools with lists of disposal contractors in their areas, allowing the schools to personally 

contact and develop a relationship with the contractors. In Wyoming, this was cited as one of 

the critical success factors, not only because it helped to develop trust, but also gave the 

school ownership of their role in chemical removal. 

• Build relationships with EPA Regional personnel: Having a relationship with EPA Regional 

personnel or being connected to networks that interact with EPA was helpful in raising 

awareness about funding opportunities. Program implementers in EPA Regions 2, 3, and 10 

mentioned that routine interactions with EPA personnel and awareness of SC3 happenings at 

the Regional level were critical to awareness about funding opportunities. In Region 4, the 

relationship between the grantee and Region is also assisting other state and local SC3 

programs. EPA Region 4 frequently touts the success of the TDEC SC3 program and refers 

other states, tribes, and localities to TDEC personnel for information. 

Factors Contributing to Implementation 

Difficulties

Based on information gathered during 

interviews, we present various factors that 

hindered program implementation. This is not 

meant to be an exhaustive list, but represents 

the factors most commonly highlighted by 

interviewees and derived from analysis. 

• No established baseline or scope of 

chemical management problem: Without a 

baseline, or sense of the extent of the 

problem, it is often difficult to develop and 

implement a program that is responsive to 

the individual school needs. It is also 

difficult to measure results without a 

baseline for comparison.21 A baseline does 

not just refer to the type and quantity of 

chemicals, but also to location, 

accessibility, and storage of chemicals. 

This presents somewhat of a “chicken-andegg” problem in that the effort to identify 

school risks is not a small undertaking, and 

involves time and money. A broader 

program challenge is to identify methods 

for cost-effectively identifying (and prioritizing) schools with the most urgent need, short of 

performing a complete inventory.

 

21 Not establishing a baseline is also a problem on a larger scale, at the national level. Without quantifying the 

extent of problem, it is hard to determine the magnitude of the risk and to develop programs that adequately address 

those risks. Through the assistance of the 2004 EPA funds, these 10 SC3 programs have taken the first step toward 

establishing a baseline. 

Factors Contributing to SC3 Implementation 

Difficulties

• No established baseline or scope of 

chemical management problem 

• Incomplete or inaccurate chemical 

inventories 

• Lack of awareness of school chemical 

management policies and regulations 

• Inexperience of SC3 program 

implementers in developing requests for 

proposals for waste management contracts 

• Lack of staff time and personnel to 

implement SC3 program 

• Lack of qualified staff to conduct 

inventory and assist with chemical 

removal 

• Difficulty identifying and disposing of 

certain chemicals 

• “Non compliance” or resistance from 

teachers 

• Competing school priorities 

• Unwilling program participants

• Lack of enforcement mechanism and 

follow-up assistance
 18 

A few programs noted that additional locations with chemicals were found after cleanout. 

Accessibility to chemical storage areas was commonly mentioned as an impediment to 

assessing the baseline or extent of chemical management problems. The FWISD encountered 

a variety of accessibility issues such as nobody having the key to chemical storage areas, as 

did the NW Tri-County IU. 

• Incomplete or inaccurate chemical inventories: Lacking a comprehensive and complete 

inventory can cause a variety of problems in the short and long-term for schools. Proper 

inventories are required to accurately gauge the extent of individual schools’ chemical 

management problems as well as estimate disposal costs. An initial accurate inventory is 

also critical to effectively and efficiently managing future chemical and equipment 

purchases, storage considerations, and sustaining long-term chemical management practices. 

• Lack of awareness of school chemical management policies and regulations: Interviewees 

found that (mainly newer) teachers were unaware or unfamiliar with school or school district 

policies and procedures. This is illustrative of a larger problem with institutionalizing 

responsible chemical management policies and procedures. Schools have to deal with 

teacher and administrative turnover and must find ways to mitigate the loss of institutional 

knowledge. To remedy this problem on the FWISD system, polices were re-emphasized at 

meetings with science and secondary education directors. 

• Inexperience of SC3 program implementers in developing requests for proposals for 

hazardous waste contractors: The NW Tri-County IU in particular had difficulty with this 

aspect of their program. As they attempted to develop a request for proposal or “bid 

package” for hazardous waste disposal contractors, the School Board continually rejected it 

for being inadequate and not properly addressing issues such as liability. This resulted in 

development of multiple versions of the bid package before receiving Board approval. The 

NW Tri-County IU sought and received assistance from Regional EPA personnel on this 

issue. Even with that assistance, the revisions slowed down the process of contracting with a 

hazardous waste company significantly. In fact in a couple of instances, schools became 

“tired of waiting” and decided not to participate in the program. The NW Tri-County IU 

hopes EPA could provide additional assistance on this issue in the future. 

• Lack of staff time and personnel to implement SC3 program: It is often the case that SC3 

program implementers have many other responsibilities, of which managing or 

implementing SC3 programs is just one. It is rare to find a program with staff dedicated 

100% to the program. In some cases, programs, such as Idaho, hired interns that were 

primarily working on SC3 efforts, but the time commitment fluctuates with other school 

responsibilities and there is often high turnover. 

• Lack of qualified staff to conduct inventory and assist with chemical removal: The lack of 

qualified staff, both within the SC3 program implementing entity and at the school level, 

caused some difficulties and can ultimately impact disposal costs. Generally speaking, most 

teachers do not have lab safety or chemical management pre-service teacher training and are 

not qualified to conduct inventories or prepare chemicals for disposal without the assistance 

of a trained professional. Likewise, since some of the SC3 program implementers were not 
 19 

entities that typically handle these issues (e.g., school districts or school service 

organizations), more of the inventorying, identifying chemicals for removal, and packing 

work had to be done by disposal contractors (which can increase cost). At FWISD, while 

the primary program manager had a background to conduct inventories and remove 

chemicals, his staff that was available to assist, did not. This resulted in one person having to 

do the majority of the work. 

• Difficulty identifying and disposing of certain chemicals: Due to age and improper storage 

of chemicals, many programs were unable to accurately identify chemicals. Frequently, 

older chemicals were mislabeled, not in their original containers, or just not labeled at all. 

This not only presented a potential risk during chemical removal, but also resulted in 

additional resources to have chemicals tested and identified. Problems also arose when 

dealing with certain types of chemicals such as radioactive, pharmaceuticals, and human 

specimens. These substances require special handling procedures and can impact the cost of 

disposal. In Iowa, MWA experienced difficulty in disposing pharmaceuticals and human 

specimens. After research and searching for organizations to assist, they worked with the 

state Drug Enforcement Agency and funeral homes to help with disposal.

• “Non compliance” or resistance from teachers: SC3 programs encountered teachers that 

were unreceptive, resistant, or unwilling to dispose of all of the dangerous chemicals they 

were aware of. This behavior was most often found in “older” teachers that had been in 

their profession for a number of years. Several interviewees noted teachers that did not 

divulge all of their chemicals (in one instance, these chemicals appeared weeks after the 

cleanout and were removed) or claimed that they may need the chemicals for future 

experiments even though those chemicals had not been used in several years. On the other 

hand, newer teachers were generally, but not always, more aware and interested in ridding 

their classrooms of outdated, excess, and dangerous chemicals (this is especially true of they 

inherited chemicals from a previous teacher). 

• Competing school priorities: With the primary mission of schools being to educate children, 

chemical management is not always viewed as a top priority, even though it impacts a safe 

learning environment. Schools also have various mandates they need to address such as No 

Child Left Behind, that often rank higher on the priority list. Especially in a time of budget 

constraints, schools often have difficulty justifying the cost (actual or presumed) of chemical 

cleanout and responsible chemical management. 

• Unwilling program participants: There are schools that opt not to participate, which result 

in an incomplete “picture” of the extent of schools’ chemical management problems and 

risks that are unknown and unable to be addressed. While some interviewees did not know 

why schools chose to not participate, others cited reasons such as: schools said they had 

already done their own cleanout, they did not have a chemical management problem, or 

were concerned about the cost. Interviewees acknowledged that they still seek ways to get 

to these schools, but it is often difficult. Many said they would tackle these “hard to reach” 

schools after they addressed the willing participants. 
 20 

• Lack of enforcement mechanism and follow-up assistance: For a variety of reasons, 

including lack of resources (staff time and financial) and jurisdictional/authority issues, 

compliance with aspects of SC3 programs are difficult to verify or enforce. Most SC3 

programs are voluntary. While many develop requirements for participation, those 

requirements do remain over the long-term. LAUSD mentioned that they have “no control” 

over what chemicals teachers purchase. Some programs have put infrastructure in place that 

can act as an enforcement mechanism. The FWISD is implementing a Material Safety Data 

Sheet (MSDS) inventory system that is district-wide to enforce smart chemical purchasing. 

Many SC3 programs are unable to follow up with schools to offer technical assistance or 

help implementing responsible chemical management and sustainability measures. Many 

interviewees expressed a desire for these components, especially as they attempt to assess 

changes in behavior as a result of their programs. 

Innovative/Particular Approaches that Impacted Results

 We asked interviewees if they felt that any particular approach or aspect of their SC3 

program was more critical to achieving results than others. Not all interviewees had a response 

to this question. The approaches below were identified by interviewees and are not a result of 

analysis. Additional chemical management approaches and techniques are found in section 

IV.A. Here is what interviewees felt to be innovative: 

 

• Mini-grant approach to chemical cleanout: In Idaho, the IDEQ used a mini-grant approach 

that provided $1,000 to schools toward chemical removal/disposal. The schools had to 

cover the costs over that amount. IDEQ felt that this was a great way to make a big impact 

with a small amount of funding. IDEQ estimates that the schools typically contributed about 

$4,000 of their own funds to cover the remaining costs. 

• “Joint ownership” of chemical management: In Wyoming, the WDE advocated joint 

ownership of school chemical management issues. Their message was to let schools know 

they were not alone in handling these issues, while emphasizing the roles and 

responsibilities of the school versus those of WDE. They structured their program so that 

WDE and schools were partners in the effort and felt this approach created trust and 

autonomy to handle chemical management in the most appropriate way for their individual 

school. It should be noted that this was the only program that followed such a “hands off” 

approach regarding approach to local implementation. 

• School TV stations as training mechanism: In Iowa, there is a statewide TV network that 

every school can access. The MWA used this medium to reach out to teachers to train them 

on responsible chemical management. Many programs encounter difficulties in attracting 

teachers to training sessions since training is often after hours, expenses for attending are not 

reimbursed, or the training does not equate to continuing education credits or certification. 

The MWA used an existing resource to their advantage and educated numerous teachers in 

the process.
 21 

• Utilizing inspection reports or the authority of other agencies: This technique was used by 

several grantees as a way to reach out to schools to help with chemical management 

concerns. The RIDEM routinely spoke with personnel in the state Labor agency who had 

the authority to inspect schools. RIDEM educated Labor on the SC3 program and issues so 

as a courtesy, Labor personnel would notify RIDEM of any potential chemical management 

issues they encountered so that RIDEM could follow-up with schools. Similarly, the NW 

Tri-County IU reviewed school inspection reports completed by the County Health 

Department to identify schools with violations that may need assistance with chemical 

management. LAUSD also has a comprehensive inspection program that covers 14 different 

areas (e.g., health, environment, indoor air quality) and results in scorecards for each school. 

They also have an inspection database22. 

Typical SC3 Program Costs

The following are typical costs associated with implementation of SC3 programs. It is 

possible for any one of these costs to impact the magnitude of results achieved or the ability of 

an in implementing organization to effectively and efficiently run their program. We did not 

attempt to analyze each program’s costs relative the results achieved (e.g., cost-effectiveness). 

We should also note that the programs did not actually track some of these costs listed below, but 

mentioned them anecdotally. Below we present typical SC3 program costs, highlighting a few 

examples we have from interviewees: 

• Personnel time/cost of implementing organization and/or funding organization (e.g., grant 

administration or EPA regional technical assistance); 

• Administrative costs of implementing organization and/or funding organization (e.g., grant 

administration or EPA regional technical assistance); 

• School staff time and incentives for school staff participation (depending on how SC3 

program is structured this can include teachers, department chairs, administrators, purchasing 

officials, facilities/maintenance/grounds); 

• Preparing chemicals for disposal; 

• Removal/disposal; 

• Training; 

• Production of outreach and collateral materials (e.g., brochures, articles); and 

• Prevention related (e.g., purchase of chemistry kits, new equipment). 

 

22 LAUSD’s efforts served as the model for EPA’s HealthySEAT tool to help school districts evaluate and manage 

their school facilities for key environmental, safety and health issues. 
 22 

There was a wide variation in the way each SC3 program documented many of these 

costs. Additionally, many of the examples, such as personnel or administrative costs, were 

thought about “after the fact” and not formally tracked as part of the SC3 programs. Below we 

present a sampling of how SC3 programs captured personnel costs associated with program 

implementation: 

o LAUSD estimated a “labor cost” of about $5,000 for staff time dedicated to 

the SC3 program which was covered by LAUSD in kind services; 

o LAUSD also tracked how much time staff spent at each school related to 

cleanout: they cleaned out 47 schools and spent 294 hours; 

o $5,000 of RCSD’s budget covered staff time; 

o EPA Region 5 staff dedicated about 5 weeks to the program; 

o FWISD had 5 staff people assisting the SC3 efforts and of the EPA funding, 

about 30% of the budget covered personnel costs (including fringe benefits 

and travel); 

o TDEC’s two primary staff people for the SC3 program spent about one third 

of their time on the program; and 

o EPA Region 7 staff spent “a couple of days a month”. 

Of the aforementioned costs, disposal is the most highly variable and has the greatest 

impact on the results achieved. Typical cleanouts ranged from $2,000-5,000. Depending on the 

situation, some schools may face substantially larger costs. In fact, RIDEM mentioned a school 

that incurred a $25,000 cleanout cost since the local fire department became involved and 

required the school to cleanout a large amount of chemicals. If a large portion of SC3 program 

budgets are needed for disposal costs, it can limit the number of schools that participate, number 

of school personnel trained, and the types of chemicals targeted for removal (e.g., certain 

chemicals may be cost prohibitive to remove or programs only want to focus on certain 

chemicals and provide schools a list of what the funding will and will not cover). There are 

ways programs can lower disposal costs and that is discussed in section IV.A. 

In-kind services, such as personnel labor hours, are not always captured in SC3 program 

budgets. Many programs leverage the expertise of their staff (e.g., state environmental agency 

staff with chemistry backgrounds) as they implement aspects of their programs. The salaries of 

these personnel are often not covered by grant or other types of funding. Therefore, the use of 

personnel for SC3 program can be intermittent or on an “as available” basis since SC3 programs 

are not their primary responsibility. For example, the RCSD has one person, the Environmental, 

Health, and Safety Coordinator, who is responsible for SC3 program implementation as well as 

OSHA training and managing a range of environmental issues and contractors dealing with 

issues from asbestos to lead-based paint abatement. In Iowa, the person leading MWA’s effort 

was spending so much time responding to inquiries from schools as well as other states 

interested in their program, that she has been reassigned to focus on chemical management for 

businesses, not schools. 

Another cost which is hard to quantify, but can impact results, is what we refer to as 

intangibles. A good example is the level of expertise, knowledge, or experience that program 

implementers have about chemistry/science, chemical management and safety, and chemical 
 23 

management activities. If there is a significant learning curve that staff must overcome, it can 

lead to implementation difficulties. This is both a time and financial cost to programs. The 

financial cost comes when a lack of knowledge may result in an accident or higher dependence 

on disposal contractors to conduct inventories and cleanouts. When SC3 program staff have 

chemistry knowledge and experience, they are often able to identify chemicals that can safely be 

disposed of, or package similar chemicals to reduce disposal costs. 

 

IV. DISCUSSION AND CONCLUSIONS

 

This section serves to answer the remaining evaluation questions, which look ahead to 

how the findings of this evaluation can be used both by state and local chemical management 

programs and EPA to improve achievement of results. We answer the questions in the context 

of the goals of this evaluation as well as provide information to inform the ultimate goals (and 

ways of attaining those goals) of the current and future SC3 program, as outlined in the logic 

model (please refer back to Exhibit 2). 

First, we answer evaluation question #3, by identifying various “best practices” that 

resulted in SC3 program or results achievement. Second, we answer the final evaluation 

question with a discussion of how EPA can use these results to improve achievement of results. 

IV.A. Evaluation Question #3: How can the results these programs achieved be used to 

inform development or improvement of SC3 programs? 

 As mentioned in earlier sections of this report, individual school chemical management 

problems and needs are unique. Based on our assessment of each of the ten SC3 programs and 

the variations within each program, recommending any particular approach that will result in 

success in all instances could not be supported by the data at this time. It is important for each 

program or any area considering developing a program, to take a holistic assessment of the 

situation and create a SC3 program that best suits those needs.23 

 We also cannot generalize as to the characteristics that define the type of school that most 

likely will have chemical management problems. As these SC3 programs illustrate, there is 

more than one “model” of poor chemical management. Interviewees noted problems in all types 

of schools from elementary to high schools to more specialized schools (e.g., vocational). It is 

fair to say the majority of problems do occur in high schools, but elementary schools are also a 

concern, especially if the building was converted from a previous use (e.g., high schools that are 

converted to elementary or specialized schools). Common sense might say that older school 

buildings may have a bigger problem, but SC3 program implementers saw new buildings with 

issues as well. Location may dictate an approach to disposal (e.g., finding ways to lower the 

transportation costs associated with disposal if schools in rural areas are spread out), but similar 

chemical management issues are found in rural and urban; public and private; and, socioeconomically advantaged and disadvantaged areas. 

 

23 EPA is currently developing a toolkit, including a model program document and checklists for those looking to 

create SC3 programs as well as those currently implementing programs. 
 24 

 With these points in mind, we do present a sampling of “best practices” from the ten SC3 

programs. Interviewees identified these practices that were used in their programs. They 

represent common techniques and approaches that SC3 implementers use during the various 

stages of program implementation. SC3 implementers should note that not all of these best 

practices would work in every situation, it is important to assess individual program needs 

before implementing any of these practices. 

 

The practices are organized into the following categories: Program Development, 

Awareness, and Implementation Approaches; Partnerships; Funding; Chemical Inventorying; 

Chemical Disposal; Training; Purchasing; and, Prevention and Program Sustainability. All of 

the best practices are aimed at creating safer schools and improving a child’s learning 

environment, protecting the health of school children and staff by reducing risks associated with 

chemical mismanagement, instilling responsible chemical management practices, and protecting 

the environment—the ultimate goals of the SC3 program. 

Program Development, Awareness, and Implementation Approaches

• Research local “dynamics”: It is important for SC3 programs to be mindful of local/state 

politics, laws, and regulations governing chemical management and safety in schools, and 

authority (e.g., enforcement, inspection). All of these could potentially impact design, 

implementation, sustainability, and ultimate success of SC3 programs. For instance, in 

Texas, the FWISD personnel were not authorized overtime which hindered their ability to 

access schools at a time of day that was ideal to remove chemicals (i.e., it is preferred that 

students not be present during this process, but FWISD personnel had to enter schools 

during normal school hours). 

• Give schools ownership via a key role in responsible chemical management: In Wyoming, 

the Department of Education credited a school’s sense of ownership over the fate of 

chemical management and prevention in their schools as strongly contributing to program 

success. 

• Raise awareness about the program and problem: Educating stakeholders about how SC3 

programs address short and long-term chemical management concerns is key to achieving 

and sustaining success. There are a variety of techniques that can be used to raise 

awareness. For instance, the TDEC program used a highly visible press event to kick off 

their SC3 efforts. TDEC staged the press event at a school and involved EPA as well as SC3 

program implementers. TDEC felt this “eye opening” approach helped to “show unity” and 

commitment to the SC3 cause. Other approaches can be as simple as running articles in 

relevant publications aimed at school personnel, including principals and superintendents or 

making presentations at conferences and events. 

• Develop SC3 pilot programs: A number of the programs used the pilot program approach to 

“test the waters” as they developed their SC3 programs. IDEQ, TDEC, and LAUSD 

credited this approach with the success of their programs. The pilots especially helped to 

raise awareness, attract new participants, and increase program scope and reach. 
 25 

• Advocate a stepwise approach: Many programs believed that any progress is better than 

none at all. Therefore, if schools are only capable of tackling one aspect of chemical 

management, such as completing an inventory or removing one chemical such as mercury 

from classrooms, then they should do so and deal with other programmatic aspects later. 

This approach tends not to overwhelm participants and allows them to participate and do 

additional activities as time and money permit. It also allows implementing organizations to 

allow for impacts of a “learning curve” or unanticipated hurdles in executing parts of their 

program. For instance, Rochester City School District (RCSD) is using a phased approach to 

incorporating an Environmental Management System to assist with responsible chemical 

management.24A stepwise approach is cost-effective when third-party chemical removal 

contractors are not involved, as mobilization (fixed) costs are higher when they visit a school 

many times instead of just one time (e.g., to do a mass inventory and removal effort). 

 

Partnerships

 There are numerous existing stakeholder groups that have natural interactions with 

schools. These range from state, tribal, and local agencies to membership organizations to 

school boards. Exhibit 7 provides a graphical illustration of typical stakeholders that could be 

leveraged as partners in SC3 programs. Below are a few examples of partnerships from the ten 

programs. 

• Colleges and Universities: These higher education institutions are a great source of 

knowledge, expertise, and potential labor (e.g., internships) that is often readily available and 

accessible. Both the RCSD and IDEQ used graduate students to assist in implementation of 

their programs. The graduate students provided administrative and technical assistance to the 

SC3 programs while receiving valuable real world experience of an internship. 

TDEC partnered with Union University to develop a Green Chemistry Manual for teachers 

and students. The manual is also available online for others to access. Green chemistry 

training is also under development and professors from Union University have offered to 

participate. 

Colleges and universities are also a potential resource to assist with chemical inventorying 

and removal. In addition to providing technical assistance with inventories, college science 

departments may be able to use chemicals that schools no longer need for classroom 

activities. 

• State and Local Agencies/Organizations: As previously mentioned, various state agencies 

have different roles that impact schools. Labor, health, and fire departments often have 

inspection authority and can provide a second set of “eyes and ears” in schools. In Rhode 

Island, the labor department provided this function to the RIDEM. While schools may not 

see a natural relationship to state environmental agencies, they do pay great attention to 

 

24 See program summaries in Appendix 1 for more information. 
 26 

messages coming from state or local education agencies. Education agencies can potentially 

send powerful messages that command the attention (and response) of schools.25

• School Staff: There is a variety of school staff that are highly knowledgeable and “up to 

speed” on current chemical management issues and initiatives. Maintenance and facilities 

personnel are often aware of the various regulations and policies governing storage, use, and 

disposal of chemicals. SC3 programs should reach out to these personnel and open lines of 

communications and information sharing. 

Some schools have teachers that serve as Chemical Hygiene Officers (CHO) who are 

responsible for proper chemical management and often prevention in their schools. CHO’s 

often are required to be trained in chemical management and have responsibilities that are 

spelled out in school policy. 

Science department chairs are also a great resource, especially since they often oversee 

multiple schools or departments and can coordinate initiatives across programs. Several SC3 

programs specifically target these school staff. It is also a cost-effective way to get the 

program message out by educating one person who has daily interactions with multiple 

teachers and school administrators. 

Funding

It is important for SC3 programs to explore a variety of funding options and, if possible, 

not solely depend on one source of funding. Diversity of funding can help increase the longterm viability of SC3 programs. Here we highlight a few examples of funding sources.26 Also, 

please see Exhibit 7 for additional examples of stakeholders that may be able to provide funding. 

Funding approaches, such as the mini-grant approach, have also been highlighted throughout this 

report. 

• Federal Agencies: Various EPA program offices and Regions have grant funding available 

for aspects of SC3 programs such as awareness and responsible chemical management. 

Offices including OSWER, Office of Children’s Health Protection and Environmental 

Education, OAR, OPPTS and the Regions have provided funding related to SC3 efforts. 

TDEC was able to secure OPPTS funding and the NW Tri-County IU worked with EPA 

Region 3 for additional funds to support their efforts. Other federal agencies with 

relationships to schools, such as the Department of Education and Centers for Disease 

Control, should also be explored. 

 

25 Education agencies may not see chemical management and prevention as an issue that they have a role in. It is 

important for SC3 programs to educate these agencies on how they can help. 

26 For additional information on funding sources that were used by non-SC3 funded programs, please refer to the 

Formative Evaluation report: Building Successful Programs to Address Chemical Risks in Schools: 

Recommendations from an Evaluation of Selected School Chemical Cleanout and Prevention Programs.
 27 

Exhibit 7: Stakeholder Relationships in School Chemical Cleanout

Programs*

School

y Teachers/Dept Headsy Principalsy Facilities/Maintenancey Business Officials

Local

y Fire Depty LEPCy Board of Healthy Businessy Industryy Colleges/Univ.

State/Tribal

y Environmenty Educationy Labor/Trainingy Healthy Agriculturey Emergency

Mgmt.

y Legislature

School District

y Superintendentsy Business Officialsy Facilities/

Maintenance

School

Board

Parents

y y y y y y 

Associations/Organizations

y Nat'l Science Teachers Assoc.y Council of State Science

Supervisors

y American Association of School

Administrators/Superintendents

y Association of School Business

Officials International

y National Association of School

Principals

y Green Chemistry Institutey State Recycling Councils

Solid Waste

Management

Districts

Private Sector

y Chemical Suppliersy Chemical disposal

companies

y Equipment Providersy Industryy Insurance Companies

State Membership Organizations

y ECOS Children's Enviro Health

Workgroup

y Assoc of State and Territoral

Health Officials

y Assoc of State & Territorial Solid

Waste Mgmt Officials

y Nat'l Assoc of State Boards of

Education

y CDC School Health Coordinatorsy FOSPTAy Department of Education State

Coordinators

Presidential Initiatives

y Taskforce on

Environmental HealthRisks and Safety Risksto Children

y OFEE Schools

Workgroup

Federal Agencies

y Bureau of Indian Affairsy CDC/ATSDR/NIOSHy CPSCy DHSy Educationy EPAy Labory NIH/NIEHSy NSF

*This graphic contains a representative sample of

organizations and is not meant to be exhaustive
 28 

• State/Local Agencies: State and local environmental, education, labor, health and safety, and 

agriculture agencies may have funding available for SC3 programs. Many of the programs 

successfully leveraged federal funding to obtain state funding that resulted in additional 

schools receiving SC3 assistance. The IDEQ leveraged the EPA funding to receive DEQ 

financial support. In Iowa, the state Department of Natural Resources contributed $75,000 of 

grant funding to schools. SC3 programs should engage their management to explore funding 

availability and options. It is possible that there are grant programs, monies from taxes or 

fees, or other sources that are viable. Additionally, state or local agencies may also be 

available to provide in-kind services that can expand the reach and services of SC3 programs. 

• Schools and School Districts: Some SC3 programs require that schools contribute to the 

costs of chemical removal, training, or other activities. Their financial contribution helps to 

ensure responsibility and emphasize the need for long-term responsible chemical 

management. In Wyoming, schools were required to cover 49% of the costs of cleanout. In 

Tennessee, schools paid a fee based on their socioeconomic status (e.g., schools in 

disadvantaged areas paid less than those in wealthier areas). Even though the majority of 

schools may not yet have a line item in their school budget for chemical disposal or 

management, some in fact do, and SC3 programs should assess the viability of this funding 

source. 

• Supplemental Environmental Projects (SEP): A SEP is another funding avenue that could 

potentially be used by SC3 programs. Entities complete SEPs as a form of reparation for 

environmental violation(s). If the conditions of the SEP are applicable to aspects of SC3 

programs, the program could greatly benefit. For example, in Rhode Island, the Safe Schools 

Committee partnered with Brown University (the subject of a SEP) to assist and provide 

technical assistance to their SC3 efforts. The Idaho SC3 program also benefited from a SEP 

with the University of Idaho that provided SC3 assistance to schools and raised awareness of 

SC3 issues. 

Chemical Inventorying

• Provide sample chemical lists as guidance: Asking a teacher to complete an inventory 

without any guidance on the types of chemicals to remove and why those chemicals are 

hazardous can lead to incomplete inventories and risks that remain. Some programs provided 

lists of chemicals or websites with references and information to guide teachers through the 

inventorying process. In Rhode Island, they actually have a mandate that includes a banned 

chemical list27. In Tennessee, TDEC has a chemical inventory spreadsheet, available online, 

that describes the risks and hazards of various chemicals and allows teachers to input their 

quantities into the inventory.

• Involving teachers in chemical management decision-making: In Wyoming, WDE took a 

different approach, depending on teachers to help decide what chemicals to keep around and 

which to dispose of. Wyoming’s approach is based on relationships, trust, and ownership. In 

 

27 According to RIDEM this was the “most difficult but most significant” aspect of their SC3 program. The banned 

chemical list is thought to relieve teachers from having to decide what chemicals to use, but at the same time, 

RIDEM and its partners have not seen a substantial increase in awareness of this list since implemented. 
 29 

fact, they had a chemical list in their school chemical management regulations, but have 

decided to remove it as part of the current revisions.

• Track and maintain inventories: It is important to 

emphasize that chemical inventories are not only 

helpful to decide what to get rid of, but can be used 

as a planning and purchasing tool if properly 

maintained. In Texas, the FWISD has implemented a 

system where teachers must input the MSDS sheets 

into a district-wide system. This helps to prevent 

purchase of excessive quantities and promotes safe 

chemistry practices. They also implemented 

corresponding policy to limit the quantities 

purchased.

• Provide on-site assistance: Providing on-site assistance to teachers or other staff to complete 

inventories not only ensures a more complete and accurate inventory, but also serves to train 

and educate them on various aspects of chemical management, such as safe storage practices. 

EPA Region 5 noticed that when they went out to schools to help, the quantities of chemicals 

slated for removal more than doubled over the amounts listed in pre-visit inventories. 

RIDEM also mentioned that schools appreciated the on-site assistance and personal attention 

they provided. 

• Seek assistance from experienced professionals: Many programs sought assistance from 

those more experienced or with chemical backgrounds to ensure accuracy of inventories as 

well as identify substances that could be disposed of without having to involve a hazardous 

waste contractor. For example, the NW Tri-County IU coordinated with the PA Department 

of Environmental Protection to review inventories submitted by the schools. 

Chemical Disposal

In this section we begin with general best practices and then offer techniques to lower 

disposal costs. It should be noted that SC3 program implementers should identify any federal, 

state, or local requirements that may apply to chemical storage, labeling, removal, transport, or 

disposal before implementing any of these best practices identified by program funding 

recipients. 

• Provide list of disposal contractors: Schools often do not even know where to begin when it 

comes to finding a disposal contractor. While many SC3 implementing organizations, such 

as state agencies, cannot recommend specific contractors, providing a resource list gives 

schools a place to start. The Wyoming program found this technique helpful. It not only 

provided a starting point, but also allowed the schools to speak directly with the contractors 

to build rapport. 

• Disposal technical assistance: Some programs provided schools with points of contact to 

answer any questions regarding chemical removal or to request assistance in chemical 

inventory, packing, and removal. SC3 programs in Texas, Rhode Island, and Wyoming used 

A FWISD policy states... 

“Chemicals shall not be 

ordered by any teacher unless 

pre-approved by the science 

chair in writing. All quantities 

are to be 500 milliliters or less 

and must be justified (be able 

to be consumed during a 

normal school year’s activity.) 
 30 

this approach and found it resulted in schools calling up to ask for help with chemical 

management. 

• Coordinate with household hazardous waste removal events: Piggybacking on existing 

opportunities is a great way to reduce costs, especially for disposal. In Tennessee, the 

TDEC combined their chemical cleanout with the household hazardous waste program, 

allowing for savings in disposal cost. In Wisconsin, household hazardous waste collection 

centers were also utilized. 

• Sort and consolidate chemicals prior to removal: Having a qualified professional help to 

sort and combine like chemicals can result in substantial cost savings. This also allows for 

identification of chemicals or other substances that do not require disposal by a hazardous 

waste contractor and therefore do not need to be packed and removed with the other more 

dangerous (and expensive to remove) chemicals. Since some hazardous waste disposal 

companies charge per container, consolidating chemicals by a qualified professional is also 

an option. Similarly, if each school can safely store all chemicals in one temporary holding 

area for pick-up, it reduces the amount of time contractors need for removal. RIDEM went 

to schools to assist in sorting and categorizing chemicals for disposal. They estimate that at 

the schools they visited, each school’s cleanout was less than $5,000. 

• Negotiate lower rates: In comparison to individual schools, organizations (e.g., school 

districts) are often able to leverage existing contracts or relationships with hazardous waste 

disposal companies to negotiate lower disposal rates. Having completed chemical 

inventories (containing information on type, quantity, containers, and location) prior to 

removal are extremely helpful in estimating and negotiating disposal costs. 

• Create a “temporary” storage facility: Creating a facility to temporarily house chemicals 

from across a school district or a geographic area can reduce the transportation costs 

associated with disposal. Also, if only small amounts of chemicals are removed from 

schools, those can be stored temporarily until it is more cost effective to have a contractor 

removal the chemicals. The FWISD credited such an approach to reducing disposal costs 

from an average cost of $455/drum to $145/drum. To accommodate the chemicals awaiting 

disposal, they retrofit an existing facility (in accordance with applicable regulations) so that 

chemicals were properly stored. 

Training

• Develop training strategy/design: It is important to decide the content of training sessions 

upfront with an eye toward not overwhelming participants with too much information. 

Interviewees agreed that too much information dilutes the effectiveness of training, as does 

information that is not easily comprehensible. In Iowa, the MWA surveyed training 

participants to gauge effectiveness and many commented that the sessions presented too 

much information. The sessions have since been redesigned.

• Specialized training sessions: If programs are targeting various audiences within a school, 

such as facilities/maintenance, teachers, and administrators, it may be better to offer target-
 31 

specific, specialized training sessions. This allows training to offer the most relevant 

material to each specific role and responsibility related to proper chemical management. 

MWA as well as LAUSD used this approach. MWA had trainings for science educators and 

automotive/tech staff. LAUSD had separate trainings for plant managers and chemical safety 

coordinators. 

• Provide incentives to increase participation: Teachers are often reluctant to attend training 

for a variety of reasons including cost and time away from their classrooms. The programs 

used a variety of approaches to provide incentives for teachers. Incentives included 

providing substitute teachers, reimbursing costs associated with time or travel to training 

session (NW Tri-County IU), and providing eligibility for continuing education credits 

(LAUSD).

• Leverage existing venues: A cost-effective approach to training is to research existing 

opportunities and venues, such as conferences, workshops, and teacher in-service days, to 

present training sessions or breakout sessions. 

• Offer training throughout chemical management lifecycle: Having one comprehensive 

training session that covers every topic from “A to Z” is not as effective as spreading the 

training over time and possibly aligning topics of training sessions with the schools’ stage in 

the SC3 program. For example, if schools are only beginning the inventorying phase, 

providing information on how to approach future chemical purchases, may not be as 

appropriate as information on how to properly store their chemicals.

• Provide multiple opportunities for school staff to attend training: Giving teachers and other 

school staff multiple opportunities to attend training will result in increased participation. 

The more limited the training schedule, the less likely the trainings will fit into schedules of 

school staff. 

Purchasing

• Promote centralized or district-level purchasing: Having a centralized system or less people 

with the ability to directly purchase chemicals can help monitor the quantities and types of 

chemicals being purchased. If individual school staff members are allowed to buy whatever 

chemicals they feel they need for classroom activities, schools run the risk of additional 

chemical cleanouts in the future. The FWISD requires all chemical purchases to be 

approved, in writing, by the science director. Additionally, centralized purchasing allows for 

easier tracking and maintenance of accurate chemical inventories. 

• Develop purchasing guidelines: SC3 programs should promote the development of 

purchasing guidelines that outline the types and quantities of chemicals allowed to be 

purchased. These guidelines should make every effort to restrict chemicals purchased to the 

amount necessary to complete near-term classroom activities. Also, guidelines should 

emphasize preventative measures such as micro-scale chemistry. To reinforce guidelines, 

SC3 programs can offer training or other forms of outreach. In California, LAUSD included 

a procurement aspect in their training sessions. 
 32 

Responsible Chemical Management and Program Sustainability

 We combined these two topics because they are intertwined. Properly executed chemical 

management practices will sustain strides made in managing chemicals and prevent the need for 

future cleanout. The other type of sustainability is to ensure that SC3 programs will be available 

if schools demonstrate a need for assistance. 

• Promote “greener” chemistry practices: Green and micro-scale chemistry are approaches 

that generally use techniques that require lesser quantities and toxicity of chemicals, which is 

advantageous to creating safer learning environments and protecting the environment. 

Additionally, many programs promote the use of “lab kits” which include everything 

necessary to conduct an experiment in one package. This decreases the likelihood of 

purchasing bulk or excess quantities of chemicals. It should be noted that micro-scale 

chemistry can be expensive and does not necessarily always use “greener” chemicals. SC3 

programs can also provide teachers with resources to access safer and greener chemistry 

experiments via the Internet. TDEC partnered with a university to develop a green chemistry 

lab manual for teachers that is available online. 

• Require and provide incentives for routine training: Ensuring school staff members are upto-date on responsible chemical management topics, techniques, and procedures will help to 

reinforce these practices in daily classroom activities. SC3 programs could explore 

innovative concepts with schools such as requiring training as part of staff performance 

evaluations, as a way to spur interest in continuing education. Also, SC3 programs can 

consider providing incentives, financial or otherwise, to staff that participate in training. 

• Reward success: TDEC identifies and rewards schools for their achievements. Other SC3 

programs can do the same to provide an incentive for schools to participate. Acknowledging 

accomplishments can also serve as a great outreach and awareness tool. In Idaho and 

Tennessee, the success of program participants attracted other schools to join the effort and 

raised awareness within state agencies. 

• Explore technical assistance and enforcement mechanisms to prevent future cleanouts: SC3 

programs should provide technical assistance or a point of contact at the appropriate agency 

or organization that schools can contact for information or assistance. Just knowing someone 

is out there to help, is often enough to ease the concerns of schools. Programs may also want 

to assess the various authorities of organizations within their state or locality to determine if 

any existing authority can be leveraged to help enforce SC3 program requirements or goals. 

• Institutionalize chemical management policies: SC3 programs can educate schools on the 

importance of developing chemical management, purchasing, and prevention policies and 

procedures. This is critical in the face of staff turnover. It helps to ensure proper practices 

remain and to establish chemical management as priority to schools. SC3 programs can work 

with schools to develop approaches to raising and maintaining awareness about these 

policies, such as disseminating them at the beginning of each school year or having teachers 

sign a pledge that they have read and comply with policies. 
 33 

• Explore funding options: SC3 programs can research alternative funding options as it is 

unlikely that one source of funding will sustain the program over the long-term. SC3 

programs can leverage partner relationships to identify new funding sources or existing 

mechanisms available that provide low or no-cost services, such as utilizing a 

communications network to spread the word about upcoming training sessions. For example, 

TDEC used the statewide superintendents association to help with outreach. 

• Educate schools about creating chemical management line items in their annual budgets: 

While most schools will not need annual chemical cleanouts, individual schools as well as 

school systems or districts should budget for responsible chemical management costs. These 

dollars could cover training and outreach, a chemical inventory tracking system, new storage 

systems, and other items. RCSD mentioned that most schools in their district have an 

existing budget line item, but it may not be sufficient to cover responsible chemical 

management costs. 

IV.B. Evaluation Question #4: In the future, what can EPA do to improve achievement of 

intended results? 

 To answer this question, we present a discussion of recommendations and next steps that 

the national SC3 program can explore to better assist state, tribal, and local SC3 programs to 

achieve results and make schools safer. The recommendations will also provide ideas for EPA to 

consider, as they look at ways to make state, tribal, and local SC3 programs sustainable and selfsufficient. The first set of recommendations represents Indtai’s opinions based upon the findings 

in this evaluation. The second set of recommendations represents the opinions of the 

interviewees on how EPA (at a national level) could assist SC3 programs. 

• Use the results of this evaluation to refine SC3 logic model: EPA should consider reviewing 

this report with an eye toward assessing how future SC3 activities can assist in attaining short 

and long-term goals and objectives. In addition to actual results, the critical success factors, 

impediments, and best practices can inform potential SC3 inputs and activities and ensure the 

needs of the various target audiences are being met. The evaluation results can also identify 

potentially new areas where metrics would be useful in assessing progress toward program 

goals. Interviewees commented that metrics are critical, yet it is currently too early to assess 

progress toward goals, such as behavior change. EPA could use the logic model to help 

develop and implement metrics to measure behavior change in the future.

• Support and promote activities in and across EPA Regions: The EPA Regions are a valuable 

resource for EPA HQ and program implementers to use to learn about SC3 program 

innovations, successes, and challenges from the field. EPA’s SC3 Regional leads are aware 

of what is happening in their states, but could also learn from what is happening in other 

Regions. EPA should look into creating an informal mechanism for sharing information and 

knowledge. For instance, EPA HQ could identify relevant conferences and events and 

present breakout sessions, roundtables, or keynote speakers that address SC3 initiatives in 

their Region. EPA should also consider sponsoring state/tribal/local SC3 program 

implementers to speak at these events. Also, EPA HQ could support and attend Regional 

events that promote SC3 efforts as a way to hear first-hand feedback and establish OSW’s 
 34 

desire to be aware of achievements at the state, tribal, and local levels. For instance, FWISD 

mentioned an EPA regional training event that they found very informative. This may be an 

example of an opportunity to get feedback from those in the field.

• Create ongoing dialogue with state/tribal/local SC3 program leaders: EPA may want to 

consider developing a mechanism that spurs dialogue among SC3 program leaders. This 

would benefit both EPA and state, tribal, and local SC3 programs. Potential mechanisms 

range from the ability to “chat” online about chemical management efforts to periodic 

Regional events that invite local leaders to discuss their programs and exchange information. 

We found an interest on the part of program administrators to hear about what is going on in 

other areas and learn from other programs. For example, the IDEQ was very interested in 

other programs that developed lists of banned or inappropriate chemicals for schools. EPA 

could use this feedback to inform the logic model and objectives and goals of the national 

SC3 program.

• Establish a more robust effort to promote SC3 successes: Promoting SC3 success stories is 

an activity that can help EPA’s SC3 achieve its short and long-term goals, while 

simultaneously stimulating chemical management at the state, tribal, and local levels. 

Rewarding and promoting program achievements is not only a “pat on the back” for the 

specific program, but can also serve to spur competition among programs, raise visibility for 

SC3 programs, and increase participation. EPA should explore ways, such as annual SC3 

“Achievement Awards” at the national and Regional levels. EPA may also want to 

participate or lend support to promoting existing awards programs. SC3 programs in both 

Iowa and Tennessee have already received awards for their efforts. 

• Provide guidance and resources on developing, implementing, and sustaining 

state/tribal/local SC3 programs: EPA is in a position to be the single portal for information 

on creating, implementing, measuring results of, and sustaining SC3 programs. An EPA 

Regional representative stated, “EPA needs to be a SC3 resource.” EPA can leverage existing 

relationships with other federal and state agencies to consolidate or develop new, userfriendly guidance, information, and other tools for SC3 program implementers and others 

interested in responsible chemical management efforts. Interviewees suggested that EPA 

may want to consider providing simple, “step-by-step” guidance to help develop and improve 

existing SC3 programs via EPA’s SC3 website. Guidance could include real-world examples 

of how other programs have implemented approaches and techniques to chemical 

management. In addition, guidance could provide examples of common metrics used to 

measure results and improve program performance. We recommend EPA consider using the 

results of this evaluation to inform development of guidance materials and resources.

• Explore ways to promote and transform positive “unintended results”: The earlier 

“unintended results” portion of this report provides EPA with some insights into how SC3 

programs may transform the positive unintended results into typical intended results. For 

instance, identify ways to leverage SC3 program visibility to increase interest from other 

schools outside the target area, other types of schools such as private or vocational, or other 

areas within the school (e.g., the NW Tri-County IU’s SC3 program raised awareness among 

the facilities/maintenance staff). Or, promote raising awareness about program success 
 35 

within a state agency to gain management support and possibly secure funding. EPA may 

want to consider developing case studies that illustrate these unexpected, positive results.

• Work with federal partners to develop solutions to specific chemical disposal issues: A few 

of the programs we evaluated encountered difficulties in disposing of certain substances, 

such as human specimens in formaldehyde, pharmaceuticals (mentioned in Region 7), and 

radioactive materials. EPA could take the initiative to work with other federal agencies to 

identify potential solutions to these issues. Solutions could include guidance, best practices, 

state/local resources and contacts. EPA could also speak with state/tribal/local SC3 

programs to gain insight into their relationships with federal or similar state partners on these 

issues. For instance, Idaho has worked with local military installations in the past to help 

with chemical disposal.

• Clarify regulatory questions and concerns: Often, questions arise that can hinder successful 

implementation of SC3 programs. EPA could solicit feedback from SC3 Regional leads and 

program implementers as to regulatory issues of concern. For example, interviewees brought 

up issues such as generator status, liability, and classification of certain wastes, about which 

they have sought clarification. An EPA position on these and other issues would help SC3 

programs to determine the most appropriate course of action when in certain situations. 

• Identify resources of other federal and state agencies and state/local SC3 programs to 

bolster EPA’s national campaign: EPA should coordinate with its federal partners to 

identify resources, tools, and information that may already exist and are applicable to 

responsible chemical management. EPA may want to look beyond materials only targeted to 

schools, but also to materials aimed at other stakeholder groups with relationships or interest 

in schools. EPA could also look to state/local SC3 programs that may provide online 

resources or information about their programs. Interviewees mentioned that they often seek 

such information and like to model aspects of their efforts after other successful programs. 

For example, Iowa’s Rehab the Lab program was modeled after King County, Washington’s 

program.

Recommendations Heard from Interviewees

 The following are a sampling of recommendations heard directly from interviewees and 

are suggestions for national level EPA-led efforts. 

Partnerships 

• Work with federal partners to address standardizing or improving consistency of science 

curriculum, particularly textbooks and lesson plans. 

• Involve the US Army Corps of Engineers (e.g., for help with cleanout) and Nuclear 

Regulatory Commission (e.g., to educate on how to safely dispose of radioactive waste) as 

national SC3 program partners. 

• Work with the Bureau of Indian Affairs to address chemical management in tribal schools. 
 36 

• Work with chemical suppliers to allow for return of used quantities of chemicals; do this as 

part of the purchase agreement – strive for full lifecycle solutions with chemical providers. 

Guidance/Information 

• Provide information on aspects of SC3 programs such as funding opportunities, developing 

and implanting metrics, and securing partnerships. 

• Develop “branding” program for chemicals to identify ones that are compliant with safe or 

environmentally friendly chemical management practices. 

• When raising awareness of problems, do not “create the perception that every school is going 

to blow up” – don’t be alarmist, but urge due care and diligence on the issue. 

• Develop a tool to assist SC3 program implementers with calculating amounts of chemicals 

removed (e.g., tools that help convert volume measurements into a comparable format). 

• Address liability issues that schools and SC3 program implementers face when purchasing, 

storing, using, and disposing of chemicals and hazardous materials. 

• Develop a chemical clearinghouse that provides information on chemicals and the 

opportunity to exchange materials (e.g., if one school donates excess quantities of a chemical 

that another school may use). 

• Develop lab safety guides. 

*** 

 As a result of the funding provided to state and local SC3 program in 2004, more schools 

are safer; more children are being protected from dangerous chemical risks; awareness about 

responsible chemical management and safety has increased; and additional mechanisms are in 

place to stimulate behavior change. Without the EPA funding, the majority of SC3 programs 

would probably have NOT been able to accomplish the aforementioned results and taken steps to 

rid schools of outdated, excess, and dangerous chemicals. The results these programs achieved 

provide best practices and real world examples that could be useful to other SC3 programs as 

well as EPA’s national Schools Chemical Cleanout Campaign. 
 37 

Acronyms List 

-CCHO - Chemical Hygiene Officers 

-FFWISD - Fort Worth Independent School District 

-IIDEQ - Idaho Department of Environmental Quality 

-LLAUSD - Los Angles Unified School District 

-MMSDS – Materials Safety Data Sheet 

MWA - Des Moines Metro Waste Authority 

-NNW Tri-County IU: Northwest Tri-County Intermediate Unit 

-OOAR – Office of Air and Radiation 

OPPTS – Office of Prevention, Pesticides, and Toxic Substances 

OSW – Office of Solid Waste 

OSWER – Office of Solid Waste and Emergency Response 

OEHS - Office of Environmental Health and Safety 

-RRCC – Resource Conservation Challenge 

RCSD – Rochester City School District 

RIDEM - Rhode Island Department of Environmental Management 

RIDoH – Rhode Island Department of Health 

-SSC3 – Schools Chemical Cleanout Campaign 

SEP - Supplemental Environmental Projects 

SSC – Safe Schools Committee (RI) 

-TTDEC – Tennessee Department of Environment and Conservation 

-W - 

WDE - Wyoming Department of Education 
 38 

APPENDICES

Evaluation of Results from EPA’s Schools Chemical Cleanout 

Campaign 

An Examination of Approaches and Factors that Impacted the Results of 

Programs Funded by EPA’s RCC Schools Chemical Cleanout Campaign in 

FY2004 
 A1-1 

Appendix 1: 2004 SC3-Funded Program Summaries 

 
 A1-2 

Region 1 - Rhode Island

The Safe Schools Committee (SSC) is a public-private partnership working to address chemical 

management issues in schools. The partnership members include the Rhode Island Departments 

of Health, Education, Environmental Management (RIDEM), and Labor and Training; Brown 

University; Community College of Rhode Island; Rhode Island Committee on Occupational 

Health and Safety; Rhode Island Fire Marshall’s Office; and private business. Their goal is to 

support schools and districts in minimizing health risks from chemicals and they reach this goal 

through development of guidance materials, training and professional development opportunities 

and the use of regulatory authority. 

In fact, the Committee successfully worked to incorporate a list of banned chemicals into the 

Rhode Island Rules and Regulations for School Health Programs in 2003. 

The Rhode Island Department of Health, on behalf of the Committee, used EPA SC3 funds to 

assist public and charter high schools with chemical removal. Only schools that have developed 

a Chemical Hygiene Plan were eligible for assistance. The Chemical Hygiene Plan must address 

chemical purchase, storage, disposal, personal protective equipment and contain an inventory. 

Greater consideration is also given to school systems that have a greater community need 

(defined as a percentage of children receiving free or reduced cost lunches). As of 2006, 4,686 

students were impacted by the chemical cleanouts in a total of eight schools. 

Currently, the SSC still works to educate school personnel and others on chemical management 

issues. RIDEM also assists schools by providing technical expertise. RIDEM works with the 

Department of Labor, who has the authority to conduct school inspections, to share information 

on chemical management concerns at schools. 

For more information, please contact Bob Vanderslice at the Department of Health at 

bobv@doh.state.ri.us or Jim Ball at Rhode Island Department of Environmental Management at 

401-222-1360 or james.ball@dem.ri.gov. 

Region 2 - New York

In the last few years, the Rochester City School District has instituted a number of practices to 

improve the management and proper disposal of hazardous materials. The current effort targets 

four program areas: 

• Hazard Communication and safe chemical storage training for science teachers; 

• Disposal of excess chemicals identified by teachers; 

• Improved lab procedure to reduce amounts of chemicals ordered; and 

• Restriction on accepting unnecessary donated chemicals 

This program has been expanded using EPA SC3 funding. The Rochester City School District 

estimates that the SC3 funding allowed the removal of 800 lbs solid hazardous waste and 1,300 

gallons of hazardous liquids from the District chemical storage facility. Thirteen secondary 

schools underwent chemical inventories to identify excess chemicals for removal and disposal. 

The District has also begun a phased approach to implement an Environmental Management 

System (EMS). An EMS is a set of processes and practices that enable an organization to reduce 

its environmental impacts and increase its operating efficiency. The Rochester City School 

District developed a full EMS for the School District in order to educate the students on the 
 A1-3 

District's "greener schools" initiative, educate District employees on how an EMS will result in 

P2 and safer workplace. The EMS will be completed in 2007.The project also supports and 

showcases intergovernmental working relationships between the City of Rochester, Monroe 

County, and the Rochester Institute of Technology. In addition, the relationships developed by 

this effort resulted in lower chemical disposal costs for the District. 

The District continues to support chemical management initiatives in schools. For more 

information, please contact Suzanne Wheatcraft at Suzanne.wheatcraft@rcsdk12.org or 585-262-

8405. 

Region 3 - Pennsylvania

In 2005-2006 The Northwest Tri-County Intermediate Unit, a school service organization, 

implemented the Safer Schools Initiative that focused on conducting chemical inventories, 

cleanout, training and policy development. They used existing information from the local health 

department to identify schools with violations to help determine the extent of the problem in 

schools. A representative from a local pollution prevention organization also educated the 

Intermediate Unit on the problems in schools. 

They leveraged the expertise and resources of the Northwest Regional Office of the PA 

Department of Environmental Protection to assist with reviewing chemical inventories. This 

review also helped to mitigate disposal costs by identifying substances that may not require a 

hazardous waste disposal contractor. The program also included prevention activities such as 

the implementation of an in-service training program (teachers educated about chemical safety 

and green chemistry) and the establishment of stronger relationships between schools and 

businesses to ensure safe chemical management. The program successfully removed 175 

containers of hazardous materials from 16 schools, affecting 11,469 students. 

This program was highly dependent on EPA SC3 funding. Currently, most schools and the 

Intermediate Unit do not have budgets that include chemical disposal. The Intermediate Unit 

will continue to provide technical assistance and training as needed. For more information on 

this program, please contact Lacey Maze at 814-734-8460 or lacey_maze@iu5.org. 

Region 4 - Tennessee

Beginning in the fall 2004, selected schools in Tennessee participated in the School Chemical 

Cleanout Campaign. The SC3 program was an expansion of a previous pilot program facilitated 

by the Tennessee Department of Environment and Conservation (TDEC)/ Division of 

Community Assistance’s Green Schools Program. The Green Schools Programs stems from a 

partnership among TDEC, the Tennessee Science Teachers Association, the Tennessee Valley 

Association (TVA), Onyx Environmental and the Tennessee Department of Agriculture. 

TDEC’s SC3 programs seek to reduce waste, eliminate outdated, unknown and unusable 

chemicals from schools, encourage environmentally sound use of chemicals in classrooms, bring 

cost savings to schools through pollution prevention, and promote SC3 success state-wide. 

TDEC’s programmatic components included lab chemical inventories, disposal, and teacher 

training. TDEC staff conducted numerous trainings and also partnered with a local university to 

develop a green chemistry handbook for teachers. 
 A1-4 

TDEC has been successful in reaching their goals and has even assisted school districts in other 

states with their SC3 programs. In total, 69 schools were cleaned out with 23,000 lbs of 

hazardous chemicals removed. TDEC leveraged various EPA grant-funding sources by 

requiring schools to contribute funds based on their socio-economic status. 

Contact Ken Nafe at ken.nafe@state.tn.us or 615-532-0281. Also see the following site for more 

information: http://www.tennessee.gov/environment/sc3/

Region 5 – Wisconsin

The U.S. EPA in partnership with the Wisconsin Department of Public Instruction (DPI) targeted 

schools in the Green Bay/Oshkosh area to participate in the School Chemical Collection 

Program. The main focus of the program in Green Bay/Oshkosh was to reduce chemical waste, 

promote the safe management of chemicals, and promote environmentally preferable purchasing 

of laboratory chemicals. A total of 57 schools participated in the Chemical Collection Program 

out of an approximate 233 eligible schools. 

The chemical collection took place at a location provided by the Winnebago County Solid Waste 

Coordinator. Chemicals were received from the 57 schools on the collection day. 

Representatives from the participating schools transported their chemicals to a drive-thru 

maintenance building where the chemicals were segregated and packaged by a waste 

management company for transportation to a U.S. EPA-approved off-site disposal facility. The 

School Chemical Collection Program resulted in the collection/disposal of approximately 1,982 

lbs of various chemicals. 

For more information on this effort, please contact Janet Haff of EPA Region 5 at 

haff.janet@epa.gov . 

Region 6 - Texas

In 2004, EPA awarded the Fort Worth Independent School District (FWISD) a SC3 grant to 

enhance processes and procedures for the disposal of chemicals, hazardous waste, and waste 

reduction and management. FWISD met those objectives through four major strategies: 

1. Inventory system; 

2. Disposal of chemicals; 

3. Prevention program; and 

4. Evaluation design. 

FWISD conducted cleanouts at 15 high schools and 22 middle schools, resulting in the removal 

of 15,000 lbs of hazardous chemicals. A portion of the chemicals may have been collected prior 

to the SC3 grant, however disposal funds were unavailable. District funds were made available 

to cover the cost of disposal for these chemicals and those removed during the grant period once 

the EPA grant was awarded. 

FWISD also implemented a district-wide chemical inventorying system that tracks Material 

Safety Data Sheets on all chemicals purchased. This system will help prevent unnecessary 

purchases both in terms of quantities and types of chemicals. 
 A1-5 

The FWISD SC3 program also had a training component. The training was aimed at the Science 

Director in each school, who is responsible for chemical management. The training encourages 

chemical management and prevention practices such as use of lab kits to minimize risks and 

waste and limiting orders of high volumes of chemicals. 

FWISD continues to support chemical management in schools. Schools can call the District at 

anytime if they have hazardous chemicals that need to be removed and disposed of. 

For more information, please contact George Reid at 817-871-2637. 

Region 7 - Iowa

The EPA Region 7 currently facilitates the Iowa school cleanout effort through onsite 

compliance visits and a partnership with Des Moines Metro Waste Authority (MWA). The 

MWA has been supporting SC3 efforts in Iowa since approximately 2000. As of 2006, 182 

schools of 366 have been reached, with a total of 206,905 lbs of hazardous chemicals removed. 

The Iowa program not only focuses on the removal of excess laboratory chemicals, but also 

waste storage practices, pollution prevention, and education of teachers, administrators, and 

facilities personnel. It should be noted that due to its longer history and the complexity of 

funding sources in the IOWA program, it was difficult to accurately attribute the exact quantity 

of chemicals removed to the SC3 funds provided by EPA in 2004. EPA Region 7 estimated this 

amount at 20,000 pounds, but it is possible that a much larger amount could be attributed to the 

EPA funding. 

The EPA SC3 funding has allowed MWA to reach out to more schools and develop a series of 

training sessions and videos to complement the efforts. MWA has been successful in partnering 

with EMC Insurance Company to expand the program throughout the state and ensure chemical 

management efforts are in place for years to come. EMC works with schools to implement 

chemical management and prevention activities as a requirement of their insurance packages. 

This also results in discounts for chemical disposal and ensures teachers and staff is adequately 

trained. The school staff completes extensive training that focuses on environmental 

compliance awareness, waste stream identification, alternatives, and a review process for on-site 

assessment.

Contact Becky Wehrman with MWA at 515-967-5512 to learn more about their efforts. Also 

Kent Candee of EMC Insurance can provide more information on EMC’s efforts to address 

chemical management in Iowa schools. He can be reached at 

Kent.A.Candee@emcins.com 

Region 8 - Wyoming

The Wyoming Department of Education (WDE), with funding from EPA, has implemented a 

program to assess, remove, dispose and prevent the future accumulation of dangerous chemicals 

in school laboratories. The initiative, which builds on existing WDE partnerships with school 

districts, is part of EPA’s Schools Chemical Cleanout Campaign. WDE’s program requires 

schools to cover 49% of the cost of chemical removal, while WDE covers the remaining costs. 

The cornerstone of WDE’s approach advocates giving schools ownership over chemical 
 A1-6 

management, cleanout, and prevention. The program has been a success and even served as 

catalysts for other school districts that were not participating in the program. Over 6,000 pounds 

of hazardous material collected and properly disposed from 31 school districts. 

 

Wyoming does have guidelines governing chemical management and prevention that are 

currently undergoing a revision and update. WDE has plans underway to coordinate with 

statewide emergency responders to increase awareness on chemical management in schools. 

For more information, please contact Bruce Hayes at 307-777-6198 or 

bhayes1@educ.state.wy.us 

Region 9 - California

In compliance with The California Code of Regulations, Section 5191 that requires school 

districts to reduce and control hazards within school laboratories, Los Angles Unified School 

District (LAUSD) has developed a Chemical Hygiene and Safety Plan (CHSP). EPA SC3 funds 

were combined with $19,000 from the LAUSD (including in kind staff time) to implement the 

CHSP. This effort is part of a larger program targeting school environmental issues. 

The program focuses on disposing unused laboratory chemicals and ensuring stored chemicals 

are placed in proper containers and/or bottles. Several prevention measures, provided by the 

Office of Environmental Health and Safety (OEHS), were taken including offering training and 

guidance for chemical safety coordinators, science teachers and plant managers. Additionally, 

LAUSD used a tracking system that verifies both used and unused chemicals in schools. 

LAUSD has been able to reach 47 schools resulting in the removal of 3,283 lbs of hazardous 

chemicals, affecting 116,802 students. Although the program for laboratory chemicals ended in 

July 2005, OEHS will keep on implementing the above prevention measures at all school sites. 

For more information, contact Soe Aung at soe.aung@lausd.net. 

Region 10 - Idaho

A 2003-2004 Supplemental Environmental Project (SEP) conducted by the University of Idaho 

with assistance from the Idaho Department of Environmental Quality (DEQ) revealed that 

schools in Idaho have accumulated a significant amount of hazardous chemicals and many 

schools lack knowledge of the proper disposal procedures. The DEQ partnered with local waste 

handlers, universities, community leaders, and school officials to develop strategies for removing 

chemical stockpiles from schools. The initial effort focused on schools in the Boise area, but due 

to promotion of the program, the SC3 program was expanded statewide. This success resulted in 

DEQ providing additional funding to support the effort. The combined EPA and DEQ funds 

provided 22 schools with assistance in disposing chemicals as well as identifying and 

categorizing existing chemical stockpiles. DEQ used a “mini-grant” approach that offered 

schools $1,000 toward chemical removal. The Schools were required to provide the remaining 

funds to cover the cleanout. DEQ also leveraged a college-level intern to assist in developing 

educational materials and provide technical assistance to support the program. The program 

resulted in removal of 1,411 lbs of hazardous chemicals. In an effort to prevent future chemical 

management problems, two school personnel training sessions are scheduled to take place in Fall 

2006. DEQ is looking into ways to fund additional cleanouts. 
 A1-7 

For more information, please contact Patti Best at 208-373-0146 or Patti.Best@deq.idaho.gov. 

Also visit http://www.deq.idaho.gov/waste/educ_tools/chemical_roundup.cfm
 A2-1 

 

Appendix 2: Evaluation Methodology for the Evaluation of Results from EPA’s School 

Chemical Cleanout Campaign

Final Draft 

Submitted: 

5 April 2006 
 1 

Introduction

The primary purpose of this project is to evaluate the results achieved by each of the SC3 funded 

programs in the 10 EPA Regions. This “results evaluation” will provide insights into the types 

of activities undertaken by grantees and the corresponding impacts on: 

1. Awareness of risks and proper mitigation steps; 

2. Changes in behaviors that prevent or minimize the recurrence of chemical risks at 

schools; 

3. School business practices related to chemical management; 

4. The environment; and 

5. Children’s health and their learning environment. 

The evaluation will attempt to identify grantee approaches and other factors that had the greatest 

impact on the results achieved. Together with other information and programmatic analyses, 

EPA plans to use the results of this evaluation to develop a national cleanout, prevention, and 

awareness program. This evaluation project also aims to improve future EPA grantee 

competitions, heighten awareness of EPA SC3 grant opportunities, and provide model 

approaches and best practices for jurisdictions considering their own programs. This program 

evaluation will serve to answer the following primary questions: 

5. Did the SC3 grantees achieve their goals? 

6. What factors contributed the most to achieving or not achieving results? 

7. How can the results of these grants be used to inform development or improvement 

of SC3 programs? 

8. In the future, what can EPA do to improve achievement of intended results?

Indtai, Inc. will have the primary responsibility of conducting this evaluation. The evaluation 

methodology described below derives from the programmatic logic model developed under Task 

2-3. This results evaluation will involve the collection of both qualitative and quantitative data to 

identify contributing factors that impacted attainment of SC3 program goals and identify ways to 

improve future achievement of goals. 

Overview of EPA’s SC3 Grant Program

In 2004, EPA launched the School Chemical Cleanout Campaign (SC3), a high visibility 

initiative operating as part of EPA’s Resource Conservation Challenge (RCC). The Campaign is 

a cooperative effort amongst OSWER, OPPTS, OAR and the Regions, and uses a variety of 

innovative approaches to achieve its three goals: (1) removal of outdated and dangerous 

chemicals from K-12 schools; (2) prevention of future stockpiles of chemicals and reduction of 

accidents by establishing prevention activities such as good purchasing and management 

practices; and, (3) raising national awareness of the problem. 

In 2004, the RCC funded separate and distinct SC3 programs in each of the 10 EPA Regions. 

These programs were designed and implemented to address each of the three stated goals. The 

programs each took unique approaches in achieving results. 
 2 

In May 2005, EPA sponsored a “formative evaluation” of both EPA funded and non-EPA funded 

SC3 programs to help EPA design its own Schools Chemical Cleanout Campaign program. The 

evaluation is intended to provide information that improves EPA’s understanding of what 

processes, operations, functions, and structure would best enable EPA and its partners to meet 

the goals for the program. 

To illustrate the various components of the SC3 program, we have developed a draft logic model 

(i.e., a graphical representation of the relationships between program inputs, outputs, and 

intended outcomes), presented below. 

The draft logic model is currently undergoing review by EPA. Indtai realizes the logic model is 

subject to revision pending comments from EPA. In the interim, we used the draft logic model 

to develop and refine the evaluation information objectives. In particular, we examined each 

element in the logic model to make sure that the data collection process addresses all relevant 

aspects of the SC3 program
3 

*Keeping in mind potential geographic (urban vs. rural) and socio-economic considerations 

External Factors: Laws/Regulations 

InexasinInK

School Impacts Inventory 

chemicals 

 Cleanout 

chemicals 

 Implement P2 

activities

Facilitate partner contributions 

Behavior/Process Adopt a “culture” 

of chemical safety in schools 

 Identify a 

“champion” 

 Increase 

communication among relevant school staff 

 Develop 

chemical storage/handling/ disposal/purchasing procedures 

 Provide routine 

training/ education opportunities for staff including 

Working Groups 

Regulatory• State/Local/ 

Tribal environmental and health agencies 

• Fire/Safety/ 

Emergency Response 

Parents 

Increase awareness of problem Understand Risk  Recognize 

hazards 

Increase awareness of potential solutions/options to address chemical mgmt concerns Use in short/long 

term planning 

 Pollution 

prevention 

 Practices/policies  Leveraging 

partners 

 Training 

opportunities 

Identify roles and responsibilities of industry/partners Explore alternative funding sources 

Non-Regulatory• Industry • Membership 

Assoc 

• Advocacy 

Groups 

National Coordination• Priority 

setting 

• Identification 

of high risk schools 

Guidance on chemical management 

EPA Staff• RCC • Schools 

Advisory Group 

• Other 

Program Offices 

Funding• Federal • State • Local • Private/ 

non-profit 

Organizations with Ties to Schools/ Potential Partners 

Provide SC3 grants for chemical cleanout and prevention 

Existing EPA Partnerships with Industry 

Outreach and Awareness Form partnerships Provide tools to assist chemical management activities• Best 

Practices 

• Case Studies • Models 

EPA Office of Solid Waste: Schools Chemical Cleanout Campaign Logic 

Intermediate 

Resources Activities Outputs Customers Short-term 

Leverage Chemical management knowledge of facility/ maintenance/ground

Results, Data,

& Metrics

 # schools 

cleaned up 

 # schools 

inventoried 

 Amount of 

chemicals removed

Awareness Communication• Brochures • Website • Speaking 

engagements 

• Publicity and 

Recognition 

School/District*• Administrators • School Board • Purchasing 

Agents 

• Teachers • Facilities/ 

Maintenance/ Grounds

Cmliwb•     
 4 

Evaluation Design

This evaluation will analyze the “results” of the 10 EPA SC3 grantees. To present a 

comprehensive analysis of the grants, both quantitative and qualitative data are necessary. In 

fact, the most value to EPA may result from insights gained during interviews that describe how

and why results were or were not achieved. Where available, we will bolster findings with 

quantitative data (for more detail on data types see below). 

Portions of this evaluation project will depend on accessing quantitative data that measure 

achievements and degrees of progress made by grantees. We assume that EPA SC3 staff will 

provide us with all grant reports that contain relevant information (e.g., applications and closeout 

reports). If EPA does not have such information, we will contact the state/local program 

administrators. There is also the possibility that we may encounter issues involving data 

completeness, quality, and comparability. We will work with EPA to resolve these issues. If 

any of the information requires an expert for interpretation, we will consult with IEc and EPA to 

address this issue or develop an alternative approach to interpreting and using the data. 

In this section, we first identify the basic information collection components that are applicable 

to the overall evaluation design. Then, we define the information objectives for each evaluation 

questions and outline our approach to answering each question. 

The basic evaluation design components are: 

3⁄4 Collect data from reports (or other relevant sources) and conduct document review. 

Indtai will review all materials provided by the WAM, regional SC3 personnel, and 

points of contact for the ten grantees. We will contact EPA’s SC3 personnel to gather all 

relevant grant reports and information that may contain both quantitative and qualitative 

data on the results of the ten grants. Indtai will also review documents collected during 

its formative evaluation of a national SC3 program. We anticipate that it will be 

necessary to contact grantees directly to gather data or information that may have been 

collected, but not officially reported in any grant reports submitted to EPA. In addition, 

we will conduct a brief review of SC3 program websites to collect additional background 

information. Indtai will keep files on each of the ten grantees, both in hardcopy and 

electronically. A courtesy copy of any files received during the information collection 

process that did not originate from EPA will be transmitted to the WAM and appropriate 

EPA SC3 staff.

3⁄4 Interviews to collect quantitative and qualitative data. Based on the document 

review, initial data collection, and information learned in the formative evaluation, Indtai 

will develop sets of comparable interview questions tailored to various audiences (e.g., 

Regional personnel versus local school district personnel). The questions will be both 

program-specific and general (applicable to a potential national program) in nature. 

Indtai will develop questions, in a dynamic interview format that strives to ask only 

relevant questions of each interviewee (e.g., questions about EPA program management 

would not be posed to a local program manager). Questions may also be revised over the 

course of the interview process based on feedback and insights we get. Indtai will seek 
 5 

input from the EPA WAM on the interview questions and consider doing a “dry run” 

interview to refine questions as appropriate. Please see Attachment 1 for a proposed list 

of interview questions. 

Indtai spoke with many of the potential interviewees during the formative evaluation (see 

below for list of proposed EPA Regional interviewees). We will leverage information and 

insights learned in those interviews wherever possible. Indtai will use personal 

interviews to solicit feedback from those involved with managing and implementing SC3 

programs. This qualitative information will bolster interpretation of the quantitative 

results data and also provide important context and anecdotal information. We intend to 

speak with both EPA Regional SC3 personnel as well as state/local program 

administrators associated with the grantee. We will coordinate with SC3 staff to ensure 

we are speaking with the most appropriate regional personnel. In addition, we will 

contact the EPA Regional personnel prior to directly contacting anyone at the state/local 

level. 

An email, sent from EPA SC3 staff, will be sent to each interviewee introducing Indtai, 

stating the purpose of the call and asking to arrange a convenient time to discuss the 

program (Please see Attachment 2 for a sample introductory email). We anticipate each 

call lasting 60-90 minutes. We will ask EPA personnel for recommendations on who else 

we should contact in order to ensure we are conducting a comprehensive evaluation of 

each program. It also may be the case where the EPA Regional contact does not feel they 

can adequately offer feedback on a specific program (due to not administering the 

program on a daily basis). In this scenario, we will ask for suggestions regarding 

alternate contacts. 

Proposed EPA Regional Interviewees 

Region Name SC3 Program 

1 Joan Jouzaitis RI Chemical Safe Schools Committee 

2 Joseph Bergstein Rochester City School District 

3 Wayne Naylor P3 Erie 

4 Delores Rodgers-Smith TN Pollution Prevention Partnership 

5 Maryann Suero Wisconsin-Osh Kosh 

6 Melissa Gaylon Ft. Worth Independent School District 

7 Edwin Buckner Iowa Rehab the Lab 

8 Matthew Langenfeld Wyoming Dept. of Education 

9 Bill Jones CA LAUSD 

10 Carmen Caldwell Idaho DEQ 

3⁄4 Mine data. Indtai will mine relevant data from the grant reports and other sources 

provided by EPA and the state/local SC3 program administrators. Indtai realizes that 

data may not occur in a form that is readily usable or comparable to other data sets. We 

may need to refine the data and analyze for completeness and quality issues. As 

necessary, we will develop alternative approaches to data mining that mitigate any 

potential issues. For example, we may decide that summarizing the data into broad 
 6 

categories according to chemical type (e.g., corrosive) is just as effective as reporting on 

specific chemical amounts. We will house all data we collect in a central location and 

have it available to electronically transmit to WAM or other SC3 personnel if necessary. 

Quantitatively we will be looking to capture the following types of data (this list may not 

be exhaustive): 

• Amount of chemicals removed from schools; 

• Types of chemicals removed from schools; 

• School characteristics (e.g., elementary/high school, school populations impacted, 

rural/urban); 

• Number of training sessions/Number of people trained; 

• Cost associated with SC3 program; and 

• Number of staff dedicated to program implementation. 

We will also review all of the interview notes to gather additional information to support 

the quantitative data and also provide insights on other aspects of the results achieved by 

the grantees. This information may have been tracked or measured by grantees or may be 

anecdotal. This may include, but is not limited to: 

• Types of pollution prevention and “beyond compliance” activities implemented; 

• Types of training sessions; 

• Activities undertaken to increase awareness of program; and 

• Behavior changes (e.g., new policies developed such as chemical purchasing). 

3⁄4 Analyze data. Indtai will analyze all data gathered during the information collection 

process to formulate draft findings that are responsive to the evaluation questions. 

During the analytical process, we will contact WAM, EPA SC3 staff, or interviewees on 

any issues warranting clarification. To the greatest extent possible, we will attempt to 

convey common or recurring themes across the ten grantees selected for evaluation. 

Indtai will brief WAM and other EPA personnel on these findings. We will consider 

presenting the draft findings to the Schools Advisory Group for input, if necessary. The 

complete analysis will be presented in the evaluation report. 

Evaluation Questions and Information Objectives 

As mentioned above, we outline the evaluation questions and associated information objectives. 

We also include which of the above information collection components will be used to answer 

each question. It is important to keep in mind that while some of these information objectives 

may seem broad, we will focus on more specific aspects during the data collection processes. 

Additionally, each question will include data mining and analysis, so those steps are not 

specifically listed under the information collection approach sections below. 
 7 

1. Did the SC3 grantees achieve their goals?

Information Objective Information Collection Approach 

Identify grantee goals and/or targets (e.g., 20 teachers trained per 

year or X amount of chemicals removed)

Document Review, Interview 

Collect demographic and geographic information of population 

served by program (e.g., rural v. urban, school size)

Data Collection, Document Review, 

Interview 

Collect results that align with goals/targets (e.g., amount of 

chemicals, # training sessions)

Data Collection, Document Review, 

Interview 

Collect unintended results (e.g., activities beyond program scope) Data Collection (potentially), Interview 

Identify performance measures/metrics Document Review, Interview 

Measure the impact of EPA funding on goal achievement Interview 

2. What factors contributed the most to achieving or not achieving results?

Information Objective Information Collection Approach 

Identify critical success factors Interview 

Identify the programmatic elements for which results were easiest

to achieve (e.g., cleanout, inventorying, P2) 

Interview 

Identify the programmatic elements for which results were hardest

to achieve (e.g., cleanout, inventorying, P2) 

Interview 

Identify innovative approaches, such as the use of an EMS, that 

impacted the results achieved 

Document review, Interview 

Identify the costs involved in implementing these programs (i.e., 

total program costs and those specific to grant related activities)? 

Document review, Interview 

Determine impact of cost on achieving results Interview 

3. How can the results of these grants be used to inform development or improvement of 

SC3 programs?

Information Objective Information Collection Approach 

Identify best practices that can contribute to achievement of goals Interview 

Determine if these practices are applicable to different sets of 

circumstances (e.g., a rural school, newly constructed schools) 

Interview 

Identify metrics that are appropriate for evaluating the results of 

various types of state and local SC3 programs 

Document review, Interview 

Determine which of those metrics (or others) can be used to 

compare the effectiveness of different programs 

Interview 
 8 

4. In the future, what can EPA do to improve achievement of intended results?

Information Objective Information Collection Approach 

Identify what is needed to reduce barriers to 

achievement of grant goals (by EPA, states, or others) 

Interview 

Identify what can be done to encourage or discourage 

unintended results (e.g., additional P2 efforts not 

included in original program scope)? 

Interview 

Evaluation Products

1. Plan for compilation, presentation, and analysis. Indtai will review all data collected and 

develop an approach for compiling, analyzing, and presenting the information to EPA WAM 

and SC3 staff. At this time, we will discuss various approaches to presenting the data and 

results that offers the most value to EPA. For instance, we may feel that presenting the 

amounts of types of chemicals (e.g., corrosive, ignitable) removed from schools is more 

valuable than a laundry list of amounts of specific chemicals removed. Or, we may choose to 

highlight how certain innovative approaches resulted in “x” amount of chemicals removed or 

new storage solutions implemented. Once we begin collecting the data, we will have a better 

sense of the most appropriate way to illustrate and summarize our findings. At this point, we 

will present our strategy for presenting the information we collected. To be most efficient, 

this may happen in conjunction with the draft report outline below. 

2. Evaluation report. Indtai will draft an evaluation report summarizing our findings and 

outlining recommendations, as appropriate. Prior to writing the report, we will submit a 

detailed outline to the WAM for review and comment. Included in the report will be highlevel graphical representations based on data from the ten grantees. As appropriate, we will 

include more detailed data and lists of sources as appendices to the report. 

The draft evaluation report will be submitted to WAM and other relevant EPA 

personnel for review. Indtai will then incorporate comments, as necessary, and transmit final 

report to WAM. The final report will be prepared and delivered in accordance with OPEI's 

Report Formatting and Presentation Guidelines of March 2005. The report will follow this 

basic structure: 

EXECUTIVE SUMMARY 

I. Introduction 

A. Background and History of the SC3 Grant Program 

B. Purpose/Objectives of the Evaluation 

C. Research Questions 

D. Structure of the Report 

 
 9 

II. Methodology and Approach 

A. Study Design 

B. Quality Assurance Plan 

C. Information Collection Assumptions 

D. Data Collection 

E. Data Analysis 

III. Results 

A. Overall Summary of Results Organized by Evaluation Questions and SubQuestions 

B. Summary of Results from Interviews (e.g., best practices, factors that 

contributed to achieving results) 

C. Summary of Results from Mining of Quantitative Data (this may not 

require a separate section, it may be interwoven in other sections) 

IV. Discussions and Conclusions 

A. Suggestions for Improving the Effectiveness of the SC3 Grant Program 

B. Recommendations for Creating a National SC3 Program (based on lessons 

learned from grant results) 

C. Conclusion 

APPENDICES 

3. Oral presentation. Indtai will present the evaluation findings to the WAM and other 

relevant EPA personnel at a time and location to be determined. Indtai will develop all 

necessary presentation materials, such as PowerPoint slides or handouts, and distribute at 

presentation. All presentations materials will also be electronically transmitted to WAM. 

Quality Assurance Plan

To maintain quality assurance throughout this evaluation project, Indtai will take the following 

steps. With regards to documentation analysis, we will coordinate with the EPA WAM and SC3 

personnel to obtain final versions of key documents. We will craft interview questions that are 

tied to answering the information objectives and overall evaluation questions. We will work 

with WAM to vet all interview questions and potentially conduct a “dry-run” interview to 

improve the clarity and completeness of questions. Every interview will involve two contractor 

personnel, thereby ensuring that comprehensive notes are taken and all relevant questions and 

follow-up inquiries are made. We will send follow-up emails to certain interviewees to clarify 

statements and collect additional documents and information for review. Indtai will maintain 

regular communication with the EPA WAM to advise on the status of the evaluation process. 
 10 

Evaluation Timeline 

Below is a tentative deliverable schedule. More firm dates will be decided once this 

methodology is approved and the introductory email is sent. Indtai will make every effort to 

ensure the information collection process is efficient and effective. Since IEc’s contract year 

ends during the middle of this project, we realize this may create potential delays or brief period 

of stop work while contract details are finalized. 

Task Deliverable Tentative Delivery Schedule as of 

April 4, 2006 

3 Begin Information Collection 

Complete Information Collection 

Draft Information Analysis Plan 

Final Information Analysis Plan 

April-May 2006 

June-July 2006 

June-July 2006 

July-August 2006 

4 Detailed Outline of Draft Report 

Draft Report 

Prepare Presentation Materials 

Oral Presentation 

Final Report 

July-August 2006 

August 2006 

August-September 2006 

August-September 2006 

August-September 2006 
 11 

Attachment: Sample Introductory Email

This sample introductory email was used during the SC3 formative evaluation and was 

transmitted by Kristina Meson in OSW. For this evaluation, we will develop text to differentiate 

this “results” evaluation from the formative so that interviewees realize we want to gather a new 

set of information from them. 

Hi SC3 Leads- 

 

I wanted to alert you that you may be contacted by our contractor Indtai, Inc. seeking 

information on your SC3 projects. Shelley Rappaport is the lead contractor who may be 

contacting you. You may also hear from Rob Brotzman. 

 

We have heard from many of you that it would be really helpful to do some analysis of SC3 

programs, both those funded in 2004 and those run by states or other organizations, to see 

what the key factors are that lead to program success, or present obstacles to implementing 

an effective program. So, we listened, and are working with Indtai on a formative 

evaluation to do just that. The purpose of this evaluation is to help us design our own SC3 

program, or help others better design theirs. The evaluation is intended to provide 

information to help EPA understand what processes, operations, functions, and structure 

would best enable EPA and its partners to meet the goals for the program. 

 

We are in the process of looking at the breadth of SC3 type programs and are narrowing 

down those that we will look into further. We will likely focus on 4 2004 EPA projects and 6 

or so non-EPA funded projects. We are trying to get a wide range of programs that vary on 

how the are run. Once selected, Shelley will contact the regional lead to discuss the 

project. If the regional lead and the contractor believes it might be useful to contact the 

grantee, the regional lead will make that decision and decide how best to make the contact. 

 

We would like to move quickly on this project so that we will have a good analysis complete 

to feed into the development of a "how-to" guide and, of course, in time for the next 

funding cycle. I would appreciate your cooperation in making this happen. I don't expect 

that it will take too much of your time. If for some reason you do not want to participate, 

please let me know. And, of course, if you have questions, just give me a holler. 

 

Thanks, as always, for the wonderful work you do in creating a safer learning environment 

for our children, - K 

 

Kristina (Krysia) L. Meson 

EPA/Office of Solid Waste 

Hazardous Waste Identification Division and 

EPA Peer Support and CISM Team 

Tele: (703) 308-8488 

Fax: (703) 308-0514 

meson.kristina@epa.gov
 A3-1 

Appendix 3: SC3 Results Evaluation Interview Guide 

Submitted: 

24 May 2006
 A3-2 

SC3 Results Evaluation Interview Questions 

{We will start by introducing ourselves and asking if a brief recap on the purpose of the call and 

the evaluation is necessary. If not, proceed directly to questions} 

BACKGROUND/CONTEXT

{We will ask a few background/contextual questions gauge the level of familiarity each person 

has with the program in question as well as verify facts. These questions will also give us 

information so that we can tailor the remaining program specific questions accordingly} 

• Describe your involvement in the program/describe your interaction with those leading 

the program 

• How long have you been aware/involved with the program? 

• What is the program’s purpose? Is it part of a larger effort? 

• Give us a sense of the scope of the program. For example: 

o How many schools are involved? What percentage of total? Elementary, middle 

(define), high school? How many kids impacted, faculty impacted? 

• How many people were involved in the program and what was the total FTE required to 

implement the program? (e.g., 2 FTE of 10 teachers’ time) 

RESULTS SPECIFIC QUESTIONS

(We will start with questions that are specific to each of the programs of interest to the 

evaluation project and then transition to more generic questions. Throughout this interview, we 

will ask, as necessary, for any program documentation, such as results or information not 

available on the Internet, that may be helpful to our evaluation.)

Did the SC3 grantees achieve their goals?

• What were the goals of each of the 10 state and local programs funded by EPA grants? Were 

these goals unique to the grant funding or part of a larger program or strategy?

o Do you feel the program has made schools safer? Please describe. 

o Do you feel the program has reduced risks of releases / exposure going 

forward?

o Describe any changes in policies, procedures, or behavior (e.g., chemical 

purchasing or chemical management policies). 

• Specifically, how were the EPA grants intended to help achieve goals? Without EPA 

funding, would each program have achieved goals? If so, how?

• Did you evaluate the progress toward meeting goals at any point throughout the process? Did 

you readjust your approach to reaching goals?

• Were the intended results of the 10 grants achieved? Explain.

• Were any goals not achieved? Explain.

• What metrics or measures did you use?

• Who was responsible for tracking results?

• Were there any unintended results that either benefited or detracted from the grantee’s ability 

to achieve program goals?
 A3-3 

What factors contributed the most to achieving or not achieving results?

• Which programmatic elements (e.g., cleanout, inventorying, P2) were the most difficult to 

achieve intended results? Which was the easiest? Why?

• Did particular approaches, such as the use of an EMS, have a greater impact on the results 

achieved? Explain.

• Which program implementer had the greatest impact on achieving or not achieving results?

• Please describe any partnerships formed or stakeholder involvement in the implementation 

of the program. 

o What was their role? 

o What impact did they have? 

o Do you feel they are an integral part of the program? Why or why not?

o Do you feel it would be helpful to speak with any of the partners or stakeholders? 

If so, could you provide me with contact info.

o Was a stakeholder group formed/used? Was it ad hoc, already established, did it 

become permanent?

• What costs were involved in implementing these programs? Did they have an impact on 

achieving results?

How can the results of these grants be used to inform development or improvement of SC3 

programs?

• Are there best practices that can contribute to achievement of grant goals? 

• Are these practices applicable to different sets of circumstances? 

• If {insert name} program overcame any impediments to success, how could others learn 

from that experience?

• What metrics are appropriate for evaluating the results of various types of state and local SC3 

programs? Can measures be identified that allow for comparison of the effectiveness of 

different programs? What system/process did you use to track data?

• What types of activities could EPA, other federal agencies, or states/local undertake to 

inform the development or improvement of SC3 programs?

In the future, what can EPA do to improve achievement of intended results?

• What can be done reduce barriers to achievement of grant goals?

• What can be done to encourage or discourage unintended results (e.g, additional P2 efforts 

not included in original program scope)?

• What can EPA do to help {insert program name} achieve sustainability and self-sufficiency?

• Are there any specific program element areas where EPA could be of assistance? Explain.
 A4-1 

Appendix 4: SC3 Results Evaluation Interviewees 
 A4-1 

SC3 Results Evaluation Interviewees 

EPA Regional Personnel 

Contact Person EPA Region SC3 Program 

Joan Jouzaitis 1 Rhode Island Chemical Safe Schools Committee 

Laura Livingston 2 Rochester City School District (NY) 

Sharon Perez-Suarez 3 Northwest Tri-County Intermediate Unit’s Safer School 

Initiative 

Delores Rodgers-Smith 4 Tennessee Department of Environment and 

Conservation’s Safe SC3 Program 

Janet Haff 5 Osh Kosh/Green Bay School Chemical Collection 

Program (WI) 

Donna Cooper 6 Fort Worth Independent School District’s Clean Out 

Your Chemical’s Project (TX) 

Ed Buckner 7 Iowa Rehab the Lab 

Matt Langenfeld 8 Wyoming Department of Education’s Safer Schools 

Initiative 

Bill Jones 9 Los Angeles Unified School District Pilot Program for 

Laboratory Chemicals 

Carmen Caldwell 10 Idaho Chemical Roundup 

State/Local SC3 Program Implementers 

Contact Person Affiliation SC3 Program 

Jim Ball RI Department of 

Environmental 

Management 

Rhode Island Chemical Safe Schools Committee 

Suzanne Wheatcraft Rochester City School 

District 

Rochester City School District (NY) 

Lacey Maze NW Tri- County 

Intermediate Unit 

Northwest Tri-County Intermediate Unit’s Safer School 

Initiative 

Ken Nafe 

Cynthia Rohrbach 

TN Dept of Environment 

and Conservation 

Tennessee Department of Environment and 

Conservation’s Safe SC3 Program 

Janet Haff US EPA, Region 5 Osh Kosh/Green Bay School Chemical Collection 

Program (WI) 

George Reid Fort Worth Independent 

School District 

Fort Worth Independent School District’s Clean Out 

Your Chemical’s Project (TX) 

Kent Candee EMC Insurance Iowa Rehab the Lab 

Becky Wehrman Metro Waste Authority Iowa Rehab the Lab 

Bruce Hayes WY Department of 

Education 

Wyoming Department of Education’s Safer Schools 

Initiative 

Soe Aung 

Yi Hwa Kim 

Los Angeles Unified 

School District Office of 

Environmental Health and 

Safety 

Los Angeles Unified School District Pilot Program for 

Laboratory Chemicals 

Patti Best ID Dept. Environmental 

Quality 

Idaho Chemical Roundup