Printed on Recycled Paper

United States 

Environmental Protection 

Agency 

Office of Pollution Prevention 

and Toxics 

Washington, DC 20460 

EPA 747-R-06-002 

December 2006 
| i Chemical Management Resource Guide for School Administrators 

Acknowledgements 

The time and effort that many individuals contributed to the review and development of this 

document is gratefully acknowledged by the U.S. Environmental Protection Agency (EPA). This 

document was prepared by Battelle Memorial Institute under contract EP-W-04-021 at the 

direction of Mr. Clarence Lewis of the EPA Office of Pollution Prevention and Toxics. 

Disclaimer 

This document was prepared under contract to an agency of the United States Government. 

Neither the United States Government nor any of their employees makes any warranty, expressed 

or implied, or assumes any legal liability for any third party’s use of or the results of such use of any 

information, product, or process discussed in this document. Mention or illustration of company 

or trade names, or of commercial products does not constitute endorsement by the EPA. As of 

the date of this document, external links are current and accurate, and are offered by way of 

example only for reference purposes. The EPA is not responsible for content of non-EPA links. 
 Chemical Management Resource Guide for School Administrators ii |

Summary 

“...No one was sure what chemicals were involved in the fire [in the facilities maintenance warehouse at the 

school]. Pallets of bleach, ammonia and sulfuric acid based drain cleaner had been stored adjacent to each other, 

and rupturing of the chemicals during the fire created an acid vapor cloud as well as chlorine and phosgene gases. 

The total cost of this event was about half a million dollars.” 

– From a case study of a suburban public high school in New England1

Are there 

Dangerous 

Chemicals in 

Your School? 

The sources of dangerous 

chemicals in schools are not 

always obvious. This guidance applies to any 

school that purchases, uses, stores, or 

disposes of chemicals or products containing 

dangerous materials. Some of the most 

common dangerous chemical products in 

schools include: 

• Laboratory chemicals (e.g., acids, bases, 

solvents, metals, salts) 

• Industrial arts or “shop” classes (e.g., inks, 

degreasers) 

• Art supplies (e.g., paints, photographic 

chemicals) 

• Pesticides, fertilizers, and de-icers 

• Maintenance supplies and equipment 

(e.g., drain cleaners, floor stripping 

products, paints, oils, boiler cleaners, fuels, 

mercury switches and gauges) 

• Health care equipment (e.g., mercury 

thermometers). 

Who Should Read 

This Guidance? 

This document is 

designed primarily for 

school administrators 

(principals and other 

policymakers), but may also be of value for 

teachers, maintenance personnel, 

superintendents, school business officials, 

insurance industry risk managers, and 

parents.

What Can Schools 

Do to Prevent 

Spills and 

Costly Incidents 

of Dangerous 

Chemicals? 

• Establish a leadership team consisting of 

qualified and experienced individuals to 

oversee chemical management activities 

and confirm the availability of budget and 

resources (Section III.A) 

• Implement pollution prevention and green 

chemistry (safer alternatives) principles, 

whenever possible, to minimize the use 

of hazardous chemicals at schools 

(Section III.B) 

• Establish a chemical management policy 

and chemical hygiene plan (Section III.C) 

• Conduct periodic chemical inventories to 

identify hazards (Section III.D) 

• Establish an environmentally preferable 

purchasing policy (Section III.E) 

• Implement an appropriate chemical storage 

and handling policy (Section III.F) 

• Establish a training program for hazardous 

chemicals management and safety 

(Section III.G) 

• Develop a hazard communication plan to 

foster awareness among school personnel 

and students about the range of chemicals 

and products used in schools 

(Section III.H) 

• Create an emergency response and spill 

clean-up plan and ensure that all chemicals 

are disposed of in accordance with federal, 

state, and local regulations (Section III.I) 
| iii Chemical Management Resource Guide for School Administrators 

EPA Resources for Additional Information 

• EPA, Healthy School Environments, http://www.epa.gov/schools/ 

• EPA’s Schools Chemical Cleanout Campaign (SC3), http://www.epa.gov/sc3/ 

• EPA, Where You Live, http://www.epa.gov/epahome/whereyoulive.htm 

What Legal Requirements Do I Have? 

Some chemicals purchased by schools may need to be managed as hazardous wastes and may 

ultimately require disposal as such. Hazardous wastes need to be managed from their initial point of 

generation until their ultimate point of disposal, known as “cradle to grave.” The Resource Conservation 

and Recovery Act (RCRA) gives EPA the authority to control the generation, transportation, treatment, 

storage, and disposal of hazardous waste. Any school that generates hazardous wastes must notify their 

state environmental agency and obtain an EPA Identification (ID) Number. This EPA ID Number must be 

put on all manifests for tracking disposal of school wastes and must be site specific for the address given. 

School liability does not end when the wastes leave the school, and school administrators must make sure 

they receive a copy of the shipping manifest stating that their wastes arrived at their destination (e.g., 

treatment, storage, or disposal facility). Laws and regulations pertaining to RCRA are available at 

http://www.epa.gov/epaoswer/osw/laws-reg.htm. 

EPA’s Healthy School Environments Assessment Tool (HealthySEAT) provides information to help 

determine if a school is subject to Federal OSHA requirements at 

http://www.epa.gov/schools/healthyseat/frequentquestions.htm Although Federal OSHA does not have 

jurisdiction over state and local government employees, including those in public schools, the 26 states 

that operate OSHA-approved State Plans are required to extend their state standards to these workers. 

A list of OSHA State-Plan states is located at http://www.cdc.gov/niosh/docs/2004-

101/appena.html#oshasps. Each state’s programs are unique and may have additional regulations and 

requirements. In states under Federal OSHA without State Plans, OSHA has no authority to inspect or 

enforce standards in public schools; however, the local Federal OSHA office may be able to provide 

hazard recognition assistance and technical support. Compliance assistance information is available 

on OSHA’s website at http://www.osha.gov. 

The National Institute for Occupational Safety and Health (NIOSH) provides a comprehensive safety 

checklist program for schools at http://www.cdc.gov/niosh/docs/2004-101/default.html, which contains 

recommendations and detailed checklists on OSHA regulations, along with background information on 

how to make sense of regulations that may be applicable to schools (http://www.cdc.gov/niosh/docs/ 

2004-101/chap1.html). 

In addition, EPA may enforce certain OSHA standards, such as Hazardous Waste Operations 

(29 CFR 1910.120) or relevant EPA standards in public schools. In addition to Federal 

requirements, states may have their own laws. Legal requirements are often updated and vary 

from state to state. In many states, the health and safety of public employees, including teachers 

and other school staff, fall under the jurisdiction of a state agency, such as the state department 

of labor or commerce. 

 Check It Out 

Note: 

This document is intended 

to serve as guidance only 

and does not supersede 

any federal, state, or 

local laws and regulations. 

Where Can I Get 

Additional Help? 

Each EPA Regional Office shares common 

chemical management goals; each region has 

its own contact point to best serve schools in 

their respective states. For more information 

on EPA programs for schools, such as EPA’s 

Schools Chemical Cleanout Campaign (SC3), 

legal requirements that schools may face, and 

where your school can receive additional 

help, refer to the following regional contact 

information and websites in the box below. 

Local government entities that may be able 

to help your school understand and address 

chemical management issues (e.g., treatment 

and disposal options) include Local 

Emergency Planning Committees (LEPCs), 

local health departments, state environmental 

departments, and fire departments. 

For more information about how local 

organizations can help, visit EPA’s SC3 - 

Businesses and Community Organizations 

website at http://www.epa.gov/sc3/. 
 Chemical Management Resource Guide for School Administrators iv |

Table of Contents 

Page 

Summary ................................................................................................................................................ii

I. Overview......................................................................................................................................... 1

I.A. Introduction...................................................................................................................................................... 1

I.B. Organization of this Guide............................................................................................................................. 2

I.C. Why You Should Be Concerned.................................................................................................................... 3

II. Hazardous Chemicals and Products in Schools ............................................................................ 4

II.A. Chemicals and Products of Concern........................................................................................................... 4

II.B. Chemical Categories....................................................................................................................................... 4

II.C. Where Chemicals and Products are Found................................................................................................ 6

III. Policies and Actions ....................................................................................................................... 8

III.A. Leadership and Resources........................................................................................................................... 8

III.B. Pollution Prevention and Greener Alternatives....................................................................................... 9

III.C. Chemical and Product Management........................................................................................................11

III.D. Chemical Inventory....................................................................................................................................12

III.E. Purchasing....................................................................................................................................................13

III.F. Storage and Handling .................................................................................................................................15

III.G. Training.........................................................................................................................................................16

III.H. Hazard Communication .............................................................................................................................17

III.I. Spills, Cleanup, and Disposal .....................................................................................................................17

IV. Special Cases ................................................................................................................................ 20

IV.A. Arsenic..........................................................................................................................................................20

IV.B. Asbestos........................................................................................................................................................20

IV.C. Lead...............................................................................................................................................................21

IV.D. Mercury ........................................................................................................................................................22

V. Conclusion.................................................................................................................................... 24

References............................................................................................................................................ 25

Appendix.............................................................................................................................................A-1 

 Chemical Hygiene and Management Plans........................................................................................................A-1 

 Sample Guidelines .................................................................................................................................................A-3 

 Checklists.................................................................................................................................................................A-5 

 Chemical Purchasing, Storage, and Design Guidelines ...................................................................................A-7 

 Use of Chemicals in Schools................................................................................................................................A-8 

 Chemical Management Resource Guide for School Administrators 1 |

EPA has developed a unique software tool to help 

school districts evaluate and manage all of their 

environmental, safety, and health issues, including 

all aspects of their chemical management 

programs. The Healthy School Environments 

Assessment Tool (HealthySEAT) can be 

customized and used, free of charge, by districtlevel staff to conduct voluntary self-assessments 

of their facilities and to manage information on 

environmental conditions within each building. 

Source: EPA, HealthySEAT, 

http://www.epa.gov/schools/ 

healthyseat/index.html 

I. Overview 

I.A. Introduction 

From elementary school maintenance storage 

closets to high school chemistry laboratories, 

schools house a variety of chemicals. Many 

of these chemicals are hazardous and are 

used daily; however, in some cases, these 

chemicals have been unused for decades. 

Ensuring that these chemicals are managed 

properly will help school administrators to: 

safeguard the health and safety of students 

and school employees; avoid disposal 

expenses and costly school closures associated 

with spills and emergency incidents; maintain 

a sense of trust between the district and the 

surrounding community; and prevent damage 

to the environment. School districts need 

solid, useful, specific recommendations and 

information on responsible chemical 

management to facilitate the establishment of 

sound district-level policies and procedures. 

This document is intended to aid K-12 public 

school districts and private, religious, and 

independent schools and school system 

policymakers in reducing dangerous chemical 

use and implementing responsible chemical 

management practices. Institutionalizing 

such practices will help to minimize the 

incidence of chemical spills, exposures, and 

emergency scenarios in schools. This 

document focuses on broad policy 

considerations that EPA recommends school 

administrators consider implementing to 

properly manage and use all dangerous 

chemicals. Parents and others in the 

community interested in school health 

and safety policies also may use this booklet 

to determine whether their children’s schools 

are effectively minimizing potential exposure 

to dangerous chemicals and products. 

This document is part of EPA’s Healthy 

School Environments Initiative. The 

Healthy School Environments website 

(http://www.epa.gov/schools/) serves as a 

gateway to on-line resources to help school 

administrators, teachers, facility managers 

and other staff, and parents address 

environmental health issues in schools. 

This document is also an integral part of the 

EPA Schools Chemical Cleanout Campaign 

(SC3) toolkit. The goals of the SC3 are to: 

remove potentially harmful chemicals from 

schools; emphasize the implementation of 

preventive programs such as chemical 

management training for lab instructors and 

microscale techniques; and raise national 

awareness of the issue of chemicals in 

schools. The ultimate goal of the SC3 is 

to create a chemically safer school 

environment in which chemicals are 

purchased wisely, stored safely, handled by 

trained personnel, used responsibly, and 

disposed of properly. Finally, this document 

includes numerous boxes highlighting 

information on relevant EPA and state 

information, such as the HealthySEAT tool 

developed by EPA as a resource to address 

chemical management among other 

environmental, safety, and health issues. 

 
| 2 Chemical Management Resource Guide for School Administrators 

I.B. Organization of this Guide 

Section I explains the need for responsible 

chemical management policies and why 

school administrators must be concerned 

about chemical management in their schools. 

Section II provides an overview of the 

various classes of hazardous chemicals and 

products of concern found in schools, and 

discusses where these chemicals and 

products of concern might commonly be 

found in schools. 

Section III presents recommendations for 

school administrators to develop their own 

consistent and effective policies, promotes 

concepts such as pollution prevention and 

green chemistry, and provides information 

on best practices for the purchase, 

identification, tracking, storage, use, and 

disposal of hazardous chemicals found in 

elementary and secondary schools. 

Section IV discusses special types of 

chemicals that are of particular concern. 

Section V presents conclusions. 

The Appendix lists specific examples of 

various “how to” forms, templates, and 

checklists for establishing policies and 

procedures that schools may use to 

facilitate the implementation of EPA’s 

recommendations. 

This document contains numerous 

references and endnotes to school-focused 

guidance documents and materials on 

chemical management, green chemistry, 

pollution prevention, environmentally 

preferable purchasing, and school cleanout 

campaigns initiated in school districts. For 

example, the Los Angeles Unified School 

District, one of the largest school districts in 

the country, along with its home state of 

California, have been committed to spreading 

awareness about chemicals in schools, as 

illustrated below. 

The Los Angeles Unified School District (LAUSD) has been particularly active on issues related to chemicals in 

schools. The LAUSD’s Office of Environmental Health and Safety (OEHS) website contains a wealth of resources 

for school officials, including a searchable product review tool available on the OEHS Chemical Evaluation Program 

page (http://www.lausd-oehs.org/productreview_chemeval.asp) and comprehensive information about its Chemical 

Hygiene Program. The OEHS Chemical Hygiene Program page (http://www.lausd-oehs.org/chemical-hygiene.asp) 

contains links to various handouts and the Science Safety Handbook for California Public Schools (http://www.lausdoehs.org/docs/Misc/CAScienceSafetyHandbook.pdf). It also lists chemicals approved by the State of California and 

OEHS for use in LAUSD school laboratories. These chemicals can be viewed by clicking the “View Approved 

Laboratory Chemicals” button on the OEHS Chemical Hygiene Program page (listed above). 

The State of California has customized EPA’s HealthySEAT software to incorporate California’s regulations and 

links to other state-specific information, including funding sources. State-customized versions of HealthySEAT make 

it easier for individual school systems to adapt and use the tool. 
 Chemical Management Resource Guide for School Administrators 3 |

1 

2 

3 

4

5

I.C. Why You Should Be 

Concerned 

There are five key reasons why school 

administrators should be concerned about 

chemical management in their schools: 

Improper chemical management 

poses health and safety risks to students 

and school employees. Health, learning, 

and behavior risks to students are 

of particular concern, as children are 

more vulnerable than adults to chemical 

exposures because their bodily systems are 

still developing; they eat more, drink more, 

and breathe more in proportion to their 

body size; and their behavior can expose 

them more to chemicals than adults. 

The expenses incurred from disposal, 

spills, and other incidents, including 

potential liabilities/lawsuits, can 

be considerable. The costs of 

responding to chemical incidents can 

reach hundreds of thousands of dollars or 

more at a single school.2 In addition to 

response costs, improper chemical waste 

management can result in fines and 

increased insurance premiums. 

It only takes one chemical incident, 

such as a spill, explosion, or 

chemical exposure, to break the trust 

with the community. Reported school 

incidents can lead to increased parental and 

community concern, negative publicity, 

and embarrassment to the school and 

school district. 

Improper chemical management 

may result in school closures that 

result in a loss of valuable education 

time. 

Improper chemical management 

can lead to unintended chemical 

discharges and spills, which inflict 

damage upon the environment where 

students, teachers, staff, and parents live 

and work. Improper chemical discharges 

into sanitary sewer lines or on-site waste 

treatment systems (including septic tanks) 

can have adverse effects on rivers, streams, 

and groundwater. Chemical releases and 

spills can also contribute to air pollution. 

Spills to the ground can ultimately result 

in long-term harm to the land and 

considerable remediation costs. 

A safe school environment that prevents 

harm to students and protects school 

employees from dangerous chemicals must 

be promoted. Responsible chemical 

management is likely to lead to improved 

learning in the classroom and improved 

overall health of the environment and the 

community. 
| 4 Chemical Management Resource Guide for School Administrators 

II. Hazardous Chemicals and Products 

in Schools 

II.A. Chemicals and Products 

of Concern 

Approximately 75,000 chemical substances 

are in commercial use today.3 Many of these 

chemical substances are considered toxic or 

otherwise hazardous to humans and other 

living beings. Toxic chemicals are associated 

with a variety of serious health problems, 

including cancer, brain and nervous system 

disorders, reproductive disorders, organ 

damage, as well as asthma. Toxic chemicals 

that are persistent in the environment and 

bioaccumulate through the food chain can 

make exposure during childhood and 

adolescence especially dangerous. Chemicals 

also can irritate the skin, eyes, nose, and 

throat. Some chemicals pose significant 

safety hazards, such as fire or explosion risks. 

Many hazardous chemicals can be found in 

school facilities. Material Safety Data Sheets 

(MSDS), comprehensive fact sheets prepared 

by chemical manufacturers, describe the 

physical properties, health effects, and 

other characteristics of chemicals, as well as 

procedures for handling, storing, and 

disposing of these substances.4 Chemical 

manufacturers should supply MSDSs along 

with each shipment of chemicals delivered to 

your school. The proper use and 

management of these substances, as well as 

the products that contain them, are critical to 

maintaining a healthy atmosphere for school 

occupants and the surrounding environment. 

The term “hazardous chemicals” may include 

(but is not limited to) the following: 

• Laboratory chemicals used or stored in 

science laboratories and preparation areas; 

• Art supplies, including paints, stains, inks, 

glazes, and photo processing chemicals, 

used in (visual and performing) art and 

shop; 

• Cleaning products utilized by custodial, 

cafeteria, and maintenance staff; 

• Pesticides, fertilizers, and de-icers/salts/ 

sands used for grounds maintenance, 

as well as pesticides used for building 

maintenance; 

• Paints, solvents, fuels, degreasers, and 

lubricants used in building operation and 

maintenance; 

• Oils, fuels, paints, antifreeze, and other 

chemicals used to maintain and repair 

equipment for transportation, school 

maintenance, and shop classes; 

• Inks, solvents, and adhesives used for 

printing in school offices; and 

• Chemicals used to treat water associated 

with drinking water and swimming pools. 

II.B. Chemical Categories 

Chemicals can be grouped based on the type 

of hazard they pose. Understanding the 

different types of chemicals in a school is 

important for developing an effective 

chemical management policy. Hazardous 

substances in schools may fall into one or 

more of the following categories: 

flammables/explosives, corrosives (the 

majority of which in high school laboratories 

are acids and bases), oxidizers/reactives, 

toxics, and compressed gases. Federal 

agencies and legislative authorities have 

developed specific definitions for each of 

those categories; however, the hazards can be 

described generally as follows:5 

The risks associated with exposure to a 

chemical are dependent on many factors, including 

the chemical’s hazard level (degree of flammability, 

toxicity, etc.), the route of exposure (e.g., absorbed 

through skin, inhaled, consumed, injected), and the 

duration of exposure. 
 Chemical Management Resource Guide for School Administrators 5 |

Chemical Type Description and Examples 

Flammables/ 

Explosives 

Chemicals that have the potential to catch fire rapidly and burn in the air. Liquids, gases, 

and solids (in the form of dusts) can be flammable and/or explosive. 

Examples: paint thinner; laboratory solvents (acetone, alcohols, acetic acid, hexane); 

adhesives (some) 

Corrosives Chemicals that can burn, irritate, or destroy living tissue or corrode metal through direct 

chemical action. This category includes strong acids and bases (alkalines), as well as 

dehydrating agents and oxidants. 

Examples: sulfuric, nitric, and hydrochloric acids; potassium, ammonium, and sodium 

hydroxides (bases); hydrogen peroxide or chlorine (oxidants); acetic acid 

Oxidizers/ 

Reactives 

Chemicals that react violently when combined with heat, light, water, or atmospheric 

oxygen, causing explosions or violent chemical reactions. 

Examples: nitrates; chlorates; nitrites; peroxides; picric acid (crystallized); ethyl ether 

(crystallized); water reactive metals (e.g., sodium) 

Toxics Any substances that, even in small amounts, can injure living tissue when ingested, 

inhaled, or absorbed into the skin. 

Examples: mercury; arsenic; lead; asbestos; cyanide 

Compressed 

Gases 

Gases stored under high pressure such that cracks or damage to the tanks and valves 

used to control these gases could cause significant physical harm to those in the same 

room. 

Examples: acetylene; helium; nitrogen 

Improper storage practices may increase the risks associated with certain chemicals, particularly those that are flammable, 

corrosive, or reactive. The King County Laboratory Waste Management Guide (http://www.govlink.org/hazwaste/ 

publications/LabGuidelinesRevAugust06.pdf) provides suggestions for safe and effective chemical storage, including shelf 

storage patterns for small stockrooms (see Table 1). 

EPA’s “No More ‘Methyl Something’: Improving Management of Curriculum Chemicals in Schools” presentation provides 

examples of dangerous storage scenarios: http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/pdfs/chemsafe.pdf. 

 Check It Out 
| 6 Chemical Management Resource Guide for School Administrators 

II.C. Where Chemicals and 

Products are Found 

Chemicals can be found throughout a school. 

They are used in both the maintenance of 

schools and the curriculum taught. 

Chemicals help students to perform 

experiments and learn new skills, among 

other benefits. In the absence of chemicals, 

schools would lack certain fundamental tools 

needed to educate students. Despite their 

useful purposes, chemicals can be dangerous 

to students and staff when managed 

improperly. Hazardous chemicals are found 

in classrooms, laboratories, storerooms, 

maintenance sheds, and numerous other 

areas. High schools usually have larger 

inventories and more hazardous chemicals 

than middle and elementary schools. 

Chemicals may have been purchased by the 

school or brought in by employees or 

students for their personal use. 

The table on the following page lists some 

specific locations in which chemicals and 

products of concern might be found in a 

typical school. Please keep in mind that this 

list is by no means all-inclusive, and that 

chemicals, when used appropriately, can be 

important to the educational process. 

Types and Locations of Hazardous Chemicals/Products in Schools: 

• EPA, Chemical Management and Usage, http://www.epa.gov/Region7/education_resources/teachers/ 

ehsstudy/ehs1.htm and “No More ‘Methyl Something’: Improving Management of Curriculum Chemicals in 

Schools,” http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/pdfs/chemsafe.pdf 

• Colorado Department of Public Health and Environment, One Hundred Most Commonly Found Explosive 

and Shock-Sensitive Materials, www.cdphe.state.co.us/cp/Institutions/Schools/ChemsInSchools/ 

ExplosiveTop40.PDF 

Alternatives to Products of Concern: 

• EPA, Environmentally Preferable Purchasing, http://www.epa.gov/epp/Massachusetts Environmentally 

Preferable Purchasing Program, Product and Service Information, http://www.mass.gov/epp/products.htm 

• Maryland State Department of Education, Safety in Ordering, Storing, Using and Disposing of Chemicals, 

http://www.mdk12.org/instruction/curriculum/science/safety/chemicals.html 

 Check It Out 

Hazardous chemicals are found in classrooms, laboratories, 

studios, maintenance areas, and numerous other areas. 

The photo above depicts one location where chemicals and 

products of concern might be found in a typical school. This photo 

also demonstrates a properly organized chemical storage area. 

Photo Credit: Rehab the Lab Program, 

Local Hazardous Waste Management. 

King County, Washington 
 Chemical Management Resource Guide for School Administrators 7 |

Location Product Type 

Hazardous Ingredient 

Examples 

Concentrated Acids (undiluted) Hydrochloric acid 

Nitric acid 

Concentrated Bases (undiluted) Sodium hydroxide 

Solvents Methanol 

Methylene chloride 

Oxidizers Lead nitrate 

Compressed gases Oxygen 

Science laboratories 

Toxics 

Cyanides 

Chromates (VI) 

Lead salts 

Mercury salts 

Solvents (used in paints, paint thinners, adhesives, lacquers, 

primers, and other products) 

Petroleum naphtha 

Turpentine 

Cleaning supplies/detergents Phosphoric acid 

Sodium silicate 

Compressed gases Acetylene 

Nitrogen 

Vocational and 

trade shops (can also be 

referred to as Career and 

Technical Education) 

Fuels, transmission, and brake fluids Gasoline 

Solvents (used in paints, inks, paint thinners, adhesives, 

lacquers, primers, and other products) 

Toluene 

Mineral spirits 

Pottery clear coating glaze Lead 

Other heavy metals 

Pigments for paints and coatings 

Cadmium 

Manganese 

Chromium 

Dry clay for ceramics and jewelry Silica 

Visual and 

performing art studios 

Acids for etching Nitric acid 

Hydrochloric acid 

Cleaning supplies/detergents 2-Butoxyethanol 

Trisodium phosphate 

Drain cleaners (alkaline) 

Drain cleaners (acidic) 

Potassium hydroxide 

Sulfuric acid 

Pesticides (including disinfectants/sterilizers) Permethrin 

Sodium hypochlorite 

Paint thinners Toluene 

Solvents (used in paints, paint thinners, adhesives, lacquers, 

primers, and other products) Xylene 

Custodial/maintenance 

areas 

Water treatment chemicals for swimming pools Chlorine tablets 

Pesticides (including disinfectants/sterilizers) Permethrin 

Sodium hypochlorite 

Refrigerants CFCs

Ammonia 

Kitchens/cafeterias 

Cleaning supplies/detergents Ammonium hydroxide 

Nurses’ offices Medical equipment Mercury (thermometers and 

blood pressure manometers) 

Intensifiers/reducers Potassium dichromate 

Hydrochloric acid 

Developers Hydroquinone 

Photography laboratories Lactic acid 

Stop baths and fixer 

Acetic acid 

Chrome alum (potassium 

chromium sulfate) 

Pesticides 2,4-D 

De-icers Sodium chloride School grounds/ 

athletic fields Fertilizers Ammonium nitrate 

Correction fluid Ethylene glycol 

Trichloroethane 

Solvents (used in paints, inks, paint thinners, adhesives, 

lacquers, primers, and other products) 

Methyl ethyl ketone 

Petroleum distillates 

Administrative offices 

Printer/copier toners Carbon black 
| 8 Chemical Management Resource Guide for School Administrators 

Training and Teamwork Approach 

to Safety and Chemical Hygiene 

“Northshore School District, in Washington State, 

has adopted the training and teamwork approach to 

Safety and Chemical Hygiene in the past 2 years. 

As a result, last year our insurance pool lowered our 

annual insurance premium by $30,000 for our efforts. 

In enacting these programs our Director of Curriculum, 

Director of Risk Management, and the Chemical Hygiene 

Officers saved money for the district.” 

 John Schmied, 

Northshore School District 

Chemical Hygiene Officer

III. Policies and Actions 

The following sections provide guidance on 

recommended chemical management policies. 

These policies relate to: pollution prevention 

and green chemistry (concepts that minimize 

the potential for hazardous chemical use in the 

first place); the general management of 

chemicals and products already present in 

schools; chemical inventories; the purchasing 

and tracking of chemicals; the storage and 

handling of hazardous chemicals; personnel 

training and hazard communication; and 

chemical spills, cleanup, and disposal. To 

properly implement these suggested policies, 

schools should establish a leadership team and 

confirm the availability of budget and 

resources. 

III.A. Leadership and 

Resources 

To institute good chemical management 

policies, school administrators need to set the 

tone that chemical management is important 

by assigning roles and responsibilities for 

implementing proper safety and chemical 

hygiene practices. Guidelines are provided 

below that policymakers at the district level 

and school administrators should implement 

in order to initiate responsible chemical 

management practices in their schools. 

• Establish or confirm that your district 

has committed budget and staff 

resources for chemical management. 

When schools consider their costs for 

chemicals, they generally consider only the 

purchase price. Each stage of chemical 

and product management, however, has 

associated costs of labor (e.g., training 

chemical hygiene officer and other staff), 

materials, equipment, and disposal, as well 

as costs of storage space and potential 

liability when responsible chemical 

management is not practiced. 

• Design and communicate a chemical 

management policy. School district 

administrators and principals need to 

establish an overall policy stating a strong 

commitment to responsible chemical 

management, including implementation of 

the policies and actions defined in this 

document. The policy should be 

communicated to all by the highest level of 

management. Strong support from the 

administration, combined with adequate 

resources, will enable responsible chemical 

management. Active involvement by the 

full school community is an important 

element of success, as well. 

• Appoint a chemical hygiene officer. 

The chemical hygiene officer is someone 

who is qualified by training and experience 

to provide technical guidance and 

leadership in the development and 

implementation of the provisions of the 

chemical hygiene plan. T he position 

description or job classification of a 

chemical hygiene officer will vary across 

school districts; however, in all cases, they 

should be trained to provide chemical 

management leadership to the school. 

• Designate a team to oversee the 

chemical management program at your 

school. This team should consist of 

teachers, janitorial staff, and maintenance 

personnel to comply with the chemical 

hygiene plan and help oversee the chemical 
 Chemical Management Resource Guide for School Administrators 9 |

management program at your school 

described in the sections that follow. 

Team members should be trained by the 

chemical hygiene officer (and reinforced 

at least annually). At a minimum, team 

members should understand physical/ 

chemical properties and potential 

health effects of chemicals, chemical 

compatibility, applicable environmental 

regulations and compliance issues, and 

waste management procedures of the 

school. You may also consider involving 

students (as applicable) as part of the 

process. 

• Disseminate information. Share 

experiences and lessons learned with other 

school districts and administrators. 

Maintain a proactive program of informing 

parents, guardians, teachers, and other staff 

about chemical and product management 

activities ongoing at your school. 

III.B. Pollution Prevention and 

Greener Alternatives 

A key aspect of responsible chemical 

management is identifying opportunities 

to minimize chemical use through the 

implementation of pollution prevention 

and green chemistry principles. 

Pollution prevention (sometimes referred to 

as “P2”) is defined as preventing or reducing 

pollution at the source, whenever feasible, 

and other practices that replace or eliminate 

the creation of pollutants. An example of 

pollution prevention would be using smaller 

quantities of (or environmentally benign 

substitutes for) chemical products used for 

grounds maintenance or cleaning. 

A related concept, green chemistry, focuses 

on science laboratories by reducing the levels 

of toxicity and amount of chemicals used in 

experiments, promoting safety, pollution 

prevention, and waste minimization. Similar 

concepts, microscale chemistry and smallscale chemistry, involve scaling down the 

quantities of chemicals required for science 

experiments resulting in improved laboratory 

safety. Exploring and adopting pollution 

prevention and green chemistry concepts in 

a school system results in many direct 

environmental benefits and often results in 

cost savings for schools. 

The following guidelines can be used to 

reduce or eliminate the generation of 

chemical pollutants and wastes. 

• Establish a policy that makes pollution 

prevention the preferred form of waste 

management and strives to eliminate the 

purchase and use of most, if not all, 

hazardous chemicals. If elimination of the 

particular chemicals is not possible, other 

options include, in order of preference, 

reuse or recycling of chemicals and 

products; treatment of chemicals to reduce 

toxicity; and disposal of chemicals in an 

environmentally safe manner. 

While treatment may be a useful activity, it should be cautioned that the treatment of hazardous waste may require 

a permit or be subject to regulation. You should consider discussing any treatment options with state or local 

regulatory agencies before you implement them in your laboratory. Neutralization of acids and bases, permitted 

under federal law, is probably the most commonly used treatment method in educational institutions; however, 

states may have more stringent standards regulating the disposal of acids and bases. To learn more about 

treatment methods, see Battelle Seattle Research Center’s “In-Laboratory Treatment of Wastes,” available on the 

P2 Pays website at http://www.p2pays.org/ref/01/text/00779/ch13.htm. 

 Check It Out 
| 10 Chemical Management Resource Guide for School Administrators 

The following resources provide technical background information to help schools implement their 

own pollution prevention/waste minimization programs: 

• Ohio EPA, Laboratory Pollution Prevention fact sheet, http://www.epa.state.oh.us/opp/Fact16_web.pdf 

and P2 checklist of lab opportunities, http://www.epa.state.oh.us/ocapp/p2/labp2checklist.pdf 

• Battelle Seattle Research Center, Laboratory Waste Minimization and Pollution Prevention: A Guide for 

Teachers, http://www.p2pays.org/ref/01/00779.htm, and Chapter 8, Scaling Down Experiments, 

http://www.p2pays.org/ref/01/text/00779/ch08.htm 

• EPA, Pollution Prevention: Definitions, http://www.epa.gov/opptintr/p2home/p2policy/definitions.htm 

• EPA, 12 Principles of Green Chemistry, http://www.epa.gov/greenchemistry/principles.html and Teachers, 

http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/teachers.htm 

• EPA, state P2 Programs, http://www.epa.gov/opptintr/p2home/resources/statep2.htm 

• EPA, Integrated Pest Management (IPM) in Schools, http://www.epa.gov/pesticides/ipm/ 

• EPA’s Schools Chemical Cleanout Campaign (SC3), http://www.epa.gov/sc3/ 

• Great Lakes Regional Pollution Prevention Roundtable, Topic HubTM for Pollution Prevention for Arts Education, 

http://www.glrppr.org/hubs/toc.cfm?hub=509&subsec=7&nav=7 

• Green Cleaning Pollution Prevention Calculator, http://www.ofee.gov/janitor/index.asp 

• Colorado State University, National Small-Scale Chemistry Center, http://www.smallscalechemistry.colostate.edu 

• Merrimack College, National Microscale Chemistry Center, http://www.microscale.org/ 

• Contact your state pollution prevention 

department for assistance in conducting 

a pollution prevention opportunity 

assessment, or contact your EPA Regional 

Office at http://www.epa.gov/p2/pubs/ 

local.htm to find programs available in 

your area as well as the issues affecting 

your part of the country. Each EPA 

Regional Office supports pollution 

prevention activities that reduce or 

eliminate the sources of waste and 

pollutants through work with voluntary 

programs, partnerships with business 

and industry, state and local governments, 

citizens groups and other federal agencies. 

• Establish a pollution prevention program 

to help your school minimize the amount 

of chemical waste generated throughout 

your school. The program may consist of 

developing school-wide and departmental 

annual waste reduction goals. The 

program may also include pollution 

prevention education sessions for teachers, 

maintenance staff, and students 

emphasizing the importance of substituting 

hazardous chemicals with chemicals that 

are less hazardous and scaling down the 

volume of chemicals used in classroom 

experiments and maintenance applications. 

• Minimize the use of pesticides, a term that 

refers not only to insecticides but also to 

herbicides, fungicides, and various other 

substances used to control pests. Children 

may be especially sensitive to the health 

risks posed by pesticides because their 

bodies are growing and developing; they 

may also have greater exposure to 

pesticides because of their increased handto-mouth behaviors. A form of pollution 

prevention, integrated pest management 

(IPM), is an effective and environmentally 

sensitive approach to pest control that 

relies on common sense strategies to 

disrupt the life cycles of pests. 
 Chemical Management Resource Guide for School Administrators 11 |

EPA’s Schools Chemical Cleanout Campaign 

Resources such as EPA’s SC3 program (see 

http://www.epa.gov/sc3/) are designed to facilitate chemical 

and product management. The purpose of SC3 is to 

reduce chemical exposures and improve chemical 

management in K-12 schools. By achieving these 

environmental goals, the SC3 will contribute to the broader 

goals of fewer lost schools days and healthier students, 

faculty, and staff. 

In addition to EPA’s SC3, states have developed their own 

SC3 programs: 

• Florida Department of Environmental Protection, School 

Chemical Cleanout Campaign (SC3), 

http://www.dep.state.fl.us/waste/categories/hazardous/p

ages/schoolchemicals.htm; and 

• Tennessee Department of Environment and 

Conservation, School Lab Chemical Cleanout Campaign 

(SC3), http://www.state.tn.us/environment/sc3/. 

III.C. Chemical and Product 

Management 

Responsible chemical management is critical 

to controlling a variety of environmental, 

health, and safety issues within any school. 

Knowing what materials are present in your 

school and how they are used, stored, and 

discarded will enable you to understand the 

issues associated with these substances. 

Properly recognizing and controlling the 

hazards inherent to these materials, wherever 

they are found in your schools, will enhance 

your ability to create a safe school with 

minimal environmental liabilities/lawsuits. 

Guidelines are provided below that 

schools and administrators should implement 

to initiate responsible chemical management 

practices in their school. 

• Establish an environmentally preferable 

chemical management policy considering 

the entire chemical and product lifecycle, 

which begins with chemical purchasing and 

includes identification, labeling, storage, 

inventory maintenance, and the activities 

associated with the use and disposal of 

chemicals and wastes generated from their 

use, including training, spill control 

procedures, and record-keeping 

requirements. 

• Establish a district-level chemical 

purchasing policy, chemical products 

evaluation process, and a district-approved 

chemicals and products list (see Section 

III.E). For example, the Los Angeles 

Unified School District’s Chemical 

Hygiene Program (http://www.lausdoehs.org/chemical-hygiene.asp) allows only 

approved chemicals to be used in school 

laboratories. Controlling what chemicals 

are used within your schools is essential to 

ensuring that only products that have been 

reviewed and approved for use are brought 

into the school environment. 

• Create a written chemical hygiene plan that 

describes procedures and practices for the 

protection of students and school 

employees from the health hazards 

presented by hazardous chemicals and 

products that are found in school 

laboratories. The chemical hygiene plan is 

a critical element of chemical management 

and should contain specific requirements 

and guidelines for chemical handling, 

inventory, storage, spills, and disposal. 

The plan should be updated annually and 

whenever necessary. The Appendix 

contains excerpts and references to several 

examples of chemical hygiene plans 

Chemicals that are not correctly and clearly 

labeled, as shown in the photos above, 

should be disposed of properly. Products 

used in schools should have an MSDS, be 

stored in their original containers, and be 

correctly and clearly labeled. 

Photo Credit: Rehab the Lab Program, 

Local Hazardous Waste Management 

 King County, Washington 
| 12 Chemical Management Resource Guide for School Administrators 

Chemical Inventory Safety Tips 

The process of assessing existing chemical hazards can be 

dangerous. The following guidelines are recommended: 

• Contact a trained professional to conduct a walk-through 

inspection of the school to pre-screen for potential 

hazards. Certain types of chemicals pose an imminent 

hazard (e.g., shock-sensitive materials) and must be 

handled only by qualified emergency personnel or 

hazardous waste professionals. 

• If the pre-screening establishes that it is safe to conduct 

an inventory, ensure that the inventory team is properly 

equipped with personal protective equipment and 

emergency response supplies as well as chemical 

management and safety knowledge. 

• Ensure that chemical storage areas are properly 

ventilated and that potential sources of ignition are 

turned off. 

• Conduct pre-screening, inventory and removal while 

students are NOT in school. 

• When complete, provide your local fire department a 

copy of the chemical inventory. 

Appendix 2 of the Massachusetts School Chemical 

Management Program (available at http://www.mass.gov/ 

dep/service/schlchem.pdf) includes a step-by-step guide to 

conducting chemical inventories. 

currently in use by school districts 

nationwide. 

• Contact state or local health departments 

or environmental agencies for more 

information. Many chemical management 

practices are often regulated at the federal, 

state, and/or local level. 

III.D. Chemical Inventory 

Existing accumulations of outdated, 

unknown, poorly labeled, improperly stored, 

degraded, and excessive quantities of 

hazardous chemicals are present in many 

schools. These chemicals pose safety and 

health risks to students and school personnel. 

Properly identifying and removing these 

chemicals is a key step in preventing 

accidents. An important part of responsible 

chemical management is the creation of an 

accurate chemical inventory. A chemical 

inventory identifies the quantities and 

physical locations of, as well as the potential 

hazards associated with, all of the chemicals 

used and stored in a school. It also serves 

as a reference for school and emergency 

personnel (e.g., local fire department) in 

the event of an emergency. Furthermore, 

a chemical inventory, when used to guide 

necessary purchases, can reduce the costs and 

management needs associated with excess 

chemicals. 

Guidelines are provided below that 

schools and administrators should follow in 

order to conduct an inventory at their school. 

Some guidelines refer to other documents 

(e.g., chemical hygiene plans); information 

about these documents is discussed in later 

sections. 

• Conduct an inventory of all of the 

chemicals and products containing 

chemicals (e.g., mercury thermometers) 

stored on-site, covering all sections of the 

school including maintenance rooms and 

closets, storage sheds, greenhouses, and all 

A chemical inventory identifies the amount and location 

of all of the chemicals stored on-site, covering all 

sections of the school including maintenance areas. 

A thorough inventory would identify inappropriate 

chemical storage practices, such as the one shown in 

this photo. Chemicals such as ammonia and bleach 

are commonly found in schools. Despite their useful 

purposes, these chemicals are incompatible and 

should not be stored near each other, especially in 

maintenance storage areas or in hot boiler rooms where 

the bottles may bulge or break. Mixing of these two 

chemicals would create a chlorine gas cloud. 

Photo Credit: Marina Brock, Barnstable County 

(Massachusetts) Department of Health and 

Environment
 Chemical Management Resource Guide for School Administrators 13 |

classrooms. Engage all school staff who 

will either be involved in conducting the 

inventory, or will be having their chemicals 

inventoried. Pre-packaged science 

experiments or demonstration kits should 

be included in the chemical inventory. 

• Establish a policy that chemical inventories 

be conducted and updated annually, unless 

state or local regulations require a more 

frequent schedule. Contact your local state 

agency, college or university, industry 

partner, or chemical supplier, or identify 

a responsible person within the school 

who has training in hazardous chemical 

management to assist with the inventory. 

• Review other documents you may have in 

schools in your district, such as a chemical 

hygiene plan or hazard communication plan, to 

ensure that chemicals are consistently 

being managed, stored, handled, and 

disposed of properly. Review your approved 

chemicals and products list (see Section III.E). 

Chemicals and products not on this list 

should be removed and properly disposed 

of or recycled according to applicable 

federal, state, and local laws. Update the 

inventory when new chemicals or products 

are added to the list and when chemicals or 

products are used or disposed. 

• Conduct periodic cleanouts by identifying 

and removing unnecessary hazardous 

materials and expired chemicals through 

appropriate recycling and/or disposal 

methods. Chemical inventories should be 

conducted prior to cleaning out chemicals 

from schools. Contact your local state 

agency, college or university, industry 

partner, or chemical supplier, or someone 

with technical qualifications to identify 

potentially dangerous situations (i.e., school 

staff should not move very old chemicals 

because of the extreme hazard they may 

present) and properly handle the chemicals 

during a chemical cleanout. 

III.E. Purchasing 

Chemicals enter school systems through 

a variety of avenues such as regular purchases 

(including purchase orders, purchasing cards, 

and personal purchases) by teachers and 

facility maintenance personnel, as well as 

donations from local industries and chemical 

suppliers. 

Chemicals have varying hazard levels; thus, 

the determination to purchase should factor 

in need, use, safety, environmental factors, 

and chemical/product management lifecycle 

costs. Remember, just because a chemical 

can be purchased at your local hardware or 

grocery store does not mean it is safe if 

improperly used or stored. 

To create a chemically safer school 

environment, school administrators should 

implement measures to reduce the amount 

and hazardous nature of chemicals entering 

their schools. Perform small-scale or 

microscale chemistry experiments or seek 

environmentally preferred products or 

services “that have a lesser or reduced effect 

on human health and the environment when 

compared with competing products or 

services that serve the same purpose.”6

 

The following resources provide information to 

help schools conduct their own chemical 

inventories, including a suggested chemical 

inventory list. You may also wish to check with 

your own state’s environmental and educational 

agencies. 

• Colorado Department of Public Health 

and Environment, Guidance on 

Chemical Management in Schools, 

http://www.cdphe.state.co.us/cp/Institutions/

Schools/ChemsInSchools/ChemMgmt.html 

• Montana Department of Environmental 

Quality, Montana School Labs, 

http://www.mdeqschoollabs.com/ 

 Check It Out 
| 14 Chemical Management Resource Guide for School Administrators 

Environmentally Preferable Purchasing 

EPA’s Environmentally Preferable Purchasing (EPP) 

program was developed to assist federal agencies in 

making environmentally conscious purchasing decisions; 

however, businesses and state and local agencies have 

also found the program to be of value. The EPP website 

(http://www.epa.gov/oppt/epp/pubs/about/faq.htm) 

discusses frequently asked questions concerning EPP 

and includes a number of tools and links to guidance 

documents and case studies that schools can use to 

identify products that are less hazardous. 

Here are some suggestions of best 

management practices to create a 

chemically safer school environment: 

• Establish a purchasing policy that 

addresses how chemicals and products 

containing chemicals are entering a school, 

who is using them, why they are being 

used, and how they will need to be 

disposed. Involve all teachers, 

maintenance and custodial personnel, and 

other staff to ensure that the chemical 

purchasing policy meets educational and 

facility maintenance needs while reducing 

the quantities and toxicity of chemicals. 

The Appendix provides resources to 

chemical purchasing examples in schools. 

• Investigate pollution prevention and green 

chemistry options (see Section III.B) to 

determine whether certain chemicals can 

be reduced in quantity or eliminated 

entirely from science and art classes. 

• Establish an environmentally preferable 

chemical screening process to ensure that 

all chemicals and products containing 

chemicals have been screened for 

environmental, health, and safety hazards 

prior to purchase, thus reducing and/or 

eliminating hazardous chemicals. 

For example, the Maryland State 

Department of Education provides 

guidance on responsible chemical 

purchasing.7 The MSDS may be useful 

in this process. 

• Create an approved chemicals and 

products list, based on less toxic or nontoxic alternatives to make non-toxic 

implementation and enforcement easier 

in your school. Only allow procurement of 

approved chemicals. 

• Purchase chemicals and products 

containing chemicals in quantities that will 

be used during the current school year or 

that can be fully consumed under normal 

conditions within the shelf life of the 

product. Another concept is “just in time” 

purchasing in which chemicals are 

purchased as needed throughout the 

school year. These purchasing methods 

reduce the costs and management needs 

associated with excess and expired 

chemicals. 

• Use products purchased or approved by 

the school. Teachers and other staff 

should be strongly discouraged from 

bringing in products on their own. 

Products used in schools should have 

an MSDS, be stored in their original 

containers in a secure location, and be 

correctly and clearly labeled. 

Schools should exercise 

EXTREME CAUTION when accepting chemical 

donations, product samples, or promotional products 

(e.g., do not accept chemicals more useful for 

electroplating than for the teaching of high school 

chemistry). Schools should not give away chemicals 

to avoid the costs of disposal. 
 Chemical Management Resource Guide for School Administrators 15 |

A few school districts have developed their own chemical 

hygiene plans that provide step-by-step procedures, as well 

as checklists for the safe handling and storage of 

chemicals. 

• Northshore School District Chemical Hygiene Plan, 

http://schoolcenter.nsd.org/education/components/scrapb

ook/default.php?cms_mode=view§iondetailid=58540

&sc_id=1161987494 

• Lake Havasu Unified School District, Arizona District 

Chemical Hygiene Plan, http://www.havasu.k12. 

az.us/support/warehouse/chempolicy.html 

• LAUSD, School Laboratory Chemical Hygiene and Safety 

Plan (Appendix F), http://www.lausd-oehs.org/docs/ 

CSC/Chemical%20Hygiene%20Plan.pdf 

III.F. Storage and Handling 

School administrators should be aware 

of proper use and storage policies 

and procedures to ensure student and 

employee safety. Guidelines are provided 

below that schools and administrators can 

follow in order to reduce the risk of chemical 

accidents and ensure that chemicals and 

products in their schools are stored and 

handled safely. 

• Establish a chemical storage and handling 

policy that addresses how chemicals should 

be properly stored, labeled, and secured, as 

well as who should have access to these 

chemicals and chemical storage locations. 

Chemicals should not be stored in areas 

that are occupied by or accessible to 

students, such as classrooms or restrooms; 

they should preferably be stored in a 

central, secure location. The Appendix 

provides resources to guidelines on the 

proper labeling of chemicals, 

recommended storage methods, and other 

considerations for proper storage (e.g., 

examples of incompatible chemicals and 

chemical segregation). 

• Conduct at least annual inspections of 

classrooms, janitorial closets, and chemical 

storage rooms and cabinets in your school 

to ensure the integrity of chemicals and 

storage structures. Spot inspections may 

be performed periodically throughout the 

school year. Engage maintenance staff in 

these inspections if storage shelving or 

locks are in need of updates or repair. 

Create and maintain an up-to-date map 

of the location and storage pattern of 

chemical storage rooms and cabinets in 

your school. 

• Inspect and test emergency equipment 

(e.g., eyewash stations and safety showers) 

as well as fume hoods and ventilation 

systems/exhaust fans at least on an annual 

basis. Engage maintenance staff in these 

inspections if safety equipment is in need 

of updates or repair. Establish protocols 

for the upkeep of emergency equipment 

and the associated maintenance records. 

• Work with a local chemical supplier to 

ensure you have MSDS information for all 

chemicals on site. Hazardous chemicals in 

schools should be stored in accordance 

with MSDS specifications. Maintaining 

a hard copy or secure website access to 

MSDS information at the district level 

could be a cost-effective approach to 

ensuring that chemical safety information 

is available across all schools. At a 

minimum, MSDS information should be 

located in all chemical storage rooms and 

cabinets and in a central place within the 

school (away from the chemicals), as well 

as a central location for the school district. 

To avoid a situation like the example shown above, 

schools should establish a chemical storage and 

handling policy that addresses how chemicals should 

be properly stored, labeled, and secured, as well as 

who should have access to them. 

Photo Credit: Rehab the Lab Program, 

Local Hazardous Waste Management, 

King County, Washington 
| 16 Chemical Management Resource Guide for School Administrators 

III.G. Training 

Proper training of staff and students on 

the handling of chemicals and products 

containing chemicals will help prevent 

accidents, thus reducing exposure to harmful 

chemicals. Training at various levels should 

be provided for all school employees and 

students on basic chemical hygiene, storage 

and handling procedures, and how to 

respond in the event of a chemical spill or 

accident. Guidelines are provided below that 

schools and administrators should follow on 

training. 

• Establish a hazardous chemicals 

management and safety training program 

that addresses how school employees (and 

students, as applicable) are to be properly 

trained to handle certain chemicals and 

products and how to respond to a chemical 

spill or release, to understand the hazards 

of these materials, and to understand the 

types of liability associated with accidents 

involving chemical usage in schools. 

Targeted employees should include school 

management, custodial and maintenance 

personnel, and appropriate teaching staff. 

The training program should include a 

review of the chemical hygiene plan, 

hazard communication plan, and approved 

products listing. Training sessions should 

be documented in a log for each employee 

and repeated periodically (e.g., on an 

annual basis) to serve as a refresher for 

existing personnel. Training also should 

be conducted for new hires. 

• Contact a local health department, 

environmental management agency, 

hazardous waste agency, or chemical 

supplier to provide a training session 

with school employees that raises their 

awareness of using less toxic alternatives 

to certain chemicals, chemical 

substitutions, green purchasing, and 

performing small-scale experiments. 

The following resources provide useful additional information on training: 

• LAUSD, School Laboratory Chemical Hygiene and Safety Plan (Section III), http://www.lausdoehs.org/docs/CSC/Chemical%20Hygiene%20Plan.pdf 

• OSHA, Training Curriculum Guidelines - (Non-mandatory) - 1910.120 App E, 

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9770 

 Check It Out 
 Chemical Management Resource Guide for School Administrators 17 |

Environmental Planning and Community Right-toKnow Act 

The Environmental Planning and Community Right-toKnow Act (EPCRA) was passed in response to concerns 

regarding the environmental and safety hazards 

associated with toxic chemicals. EPCRA establishes 

emergency planning and chemical reporting 

(“Community Right-to-Know”) requirements for Federal, 

state, and local governments; Indian Tribes; and 

industry. The reporting provisions help increase the 

public’s knowledge and access to information on 

chemicals at individual facilities (such as schools), their 

uses, and accidental releases into the environment. The 

EPA sponsors various programs that pertain to chemical 

management. 

For more information see: EPA, EPCRA Information, 

http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/ 

EPCRA.htm?OpenDocument 

III.H. Hazard Communication 

Hazard communication planning is an 

important element in chemical and product 

management. Dissemination of information 

on the quantity and hazards of hazardous 

chemicals and products creates awareness 

about the range of chemicals and products 

used and fosters proper use and disposal of 

these chemicals and products. 

Guidelines are listed that schools and 

administrators should follow in order to 

create a safer school environment for 

students and school employees. 

• Create a written hazard communication plan 

that communicates how chemicals should 

be properly managed, stored, handled, and 

disposed. The plan should consist of an 

updated chemicals and products list, 

chemical labeling requirements, MSDS 

information, a disposal log, and instructions 

on employee training programs regarding 

hazards of chemicals and protective 

measures. The Appendix offers examples of 

hazard communication programs that have 

been implemented for various school 

districts across the country. 

• Work with your local chemical supplier to 

help identify specific concerns. Depending 

on your location, state and/or federal 

hazard communication requirements 

specify your responsibility to identify and 

address the hazards associated with the 

chemicals and products used in your 

school facility. 

III.I. Spills, Cleanup, and 

Disposal 

Failing to take necessary safety precautions 

may put your school at increased risk of fire, 

explosions, and spills that may result 

in chemical exposure to students and school 

personnel, harm to the environment, and 

considerable clean-up costs to the school 

district. Hazardous wastes must be disposed 

of in accordance with RCRA and other 

applicable state and local requirements. 

Such requirements generally prohibit any 

drain disposal of hazardous chemicals or 

“treatment” of hazardous wastes beyond pH 

adjustment, and may be far more stringent 

than the disposal suggestions provided by 

chemical suppliers. 

Refer to these resources as recommended guidance for creating your hazard communication plan: 

• OSHA Hazard Communication Standard, Title 29 Code of Federal Regulations 1910.1200, 

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099 

Reminder: Federal OSHA does not have jurisdiction over state and local government employees, including 

those in public schools. 

• Section III, Summary and Explanation of the Issues and the Provisions of the Final Rule, 

http://www.osha.gov/pls/oshaweb/owadisp. 

• LAUSD OEHS Hazard Communication training presentation, http://www.lausd-oehs.org/docs/CSC/ 

HazComPresentation.ppt 

 Check It Out 
| 18 Chemical Management Resource Guide for School Administrators 

Chemical Safety Day Program in Minnesota 

The Chemical Safety Day Program (CSDP) is a costeffective waste management program available to 

educational institutions and non-profit organizations 

throughout the state of Minnesota. The CSDP has 

helped hundreds of high schools, colleges, and 

nonprofit organizations in disposing of hazardous 

material/waste at a reasonable cost and in an 

environmentally responsible way. More information 

about the program can be found on the CSDP website 

at http://www.dehs.umn.edu/csdp/. 

Proper chemical disposal can reduce the 

costs and management burdens associated 

with excess chemicals, including disposal 

costs of expired chemicals and the time 

required for inventory and storage of excess 

and unwanted chemicals, as well as costs of 

penalties due to enforcement actions that 

may result from improper chemical 

management. 

Guidelines are provided below that 

schools and administrators can follow 

in order to reduce the risk of chemical 

accidents, improve spill response procedures, 

and ensure that chemicals and products in 

their schools are safely discarded. 

• Create a written emergency response and 

spill clean-up and response plan for all 

chemicals and products. This plan should 

describe what to do and who to contact in 

the event of a spill or release, as well as the 

location of spill management supplies and 

equipment (e.g., spill kits, spill control 

materials, fire extinguishers) within the 

school. The clean-up and response plan 

should include a process for 

communicating with students, parents, 

teachers, and other staff about the incident, 

as well as methods for preventing accidents 

and exposures. 

• Develop a budget for chemical 

management and disposal. Initial costs 

may involve hiring a chemical expert and 

disposing of accumulated chemicals and 

products. A longer-term waste disposal 

budget should account for the staff time 

necessary to develop and maintain disposal 

procedures, the purchase of special 

equipment and supplies, the upkeep of 

safety equipment (e.g., fume hoods), and 

annual hazardous chemical disposal and 

staff training. 

• Establish a chemical disposal policy that 

addresses how unused and outdated 

chemicals and products containing 

chemicals should be properly removed 

from schools, including materials generated 

from the cleanup of spills. 

As shown in the photo above, existing stocks of 

outdated, unknown, degraded, and excessive 

quantities of hazardous chemicals are present in 

many schools posing safety and health risks to 

students and school personnel. Identifying and 

removing these chemicals is a key step in preventing 

accidents. Establish a chemical disposal policy that 

addresses how unused and outdated chemicals and 

products containing chemicals should be properly 

removed from schools. 

Photo Credit: Rehab the Lab Program, 

Local Hazardous Waste Management, 

King County, Washington
 Chemical Management Resource Guide for School Administrators 19 |

Disposal Guidelines for School Facilities 

Schools must comply with regulations regarding the management, transport, and disposal of hazardous waste. 

Schools are required to track the amount of hazardous waste they generate and ensure that all wastes are properly 

disposed of according to federal, state, and local requirements. These requirements can affect the way chemicals 

and chemical wastes are managed in schools. Subtitle C of RCRA regulates hazardous waste generators. 

According to RCRA (40 CFR Part 261), there are three categories of hazardous waste generators (large, small, 

and conditionally exempt), based upon the quantity of waste they produce per month. Most schools fall into the 

Conditionally Exempt Small Quantity Generator (CESQG) category. A CESQG generates 100 kilograms 

(220 pounds) or less per month of hazardous waste, or 1 kilogram (2.2 pounds) or less per month of acutely 

hazardous waste. EPA provides definitions of each generator category and its specific requirements at 

http://www.epa.gov/epaoswer/osw/gen_trans/generate.htm; however, states may have additional requirements for 

generators. Refer to these waste management and disposal resources as recommended guidance for your school: 

• EPA, Hazardous Waste Management for School Laboratories and Classrooms, 

http://www.epa.gov/region8/humanhealth/children/2HWManagementToolKit.pdf 

• Idaho Department of Environmental Quality, Idaho Chemical Roundup Waste Management and Disposal at 

Schools, http://www.deq.state.id.us/waste/educ_tools/chemical_roundup_waste_disposal_fs.pdf 

• Nebraska Department of Environmental Quality, School Chemicals and Disposal, 

http://www.deq.state.ne.us/Publica.nsf/0/d9583aaae76ad49c8625690b007378a3?OpenDocument 

• Florida Department of Environmental Protection, Disposal Guidelines for School Facilities, 

http://www.dep.state.fl.us/waste/quick_topics/publications/shw/hazardous/SC/DisposalMemoFinal.pdf 

The following resources may provide useful additional information in order to reduce the risk of chemical accidents, 

improve spill response procedures, and ensure chemicals and products in their schools are safely discarded: 

• EPA, Hazardous Waste & Your School, www.epa.gov/ne/assistance/schools/pdfs/mefact.pdf 

• King County, Washington, Laboratory Waste Management Guide, Final Report, 

http://www.govlink.org/hazwaste/publications/LabGuidelinesRevAugust06.pdf 

• Nebraska Department of Environmental Quality, Guidance Documents: School Chemicals and Disposal, 

http://www.deq.state.ne.us/Publica.nsf/0/d9583aaae76ad49c8625690b007378a3?OpenDocument 

• Massachusetts Department of Environmental Protection, Massachusetts School Chemical Management 

Program, Working Draft, http://www.mass.gov/dep/service/schlchem.pdf 

• Council of State Science Supervisors, Science and Safety: Making the Connection, http://www.csssscience.org/downloads/scisafe.pdf 

The U.S. National Library of Medicine’s on-line Wireless Information System for Emergency Responders 

(WISER) provides assistance in identifying hazardous substances, as well as spill containment advice. 

See http://webwiser.nlm.nih.gov for more information. 

 Check It Out 
| 20 Chemical Management Resource Guide for School Administrators 

IV. Special Cases 

Certain chemicals are worthy of special 

consideration due to their presence in 

schools and their negative impacts upon 

human health and the environment. It is 

important to identify potential sources of 

exposure to these chemicals in schools and 

to follow procedures for minimizing the risk 

of such exposures. Although this section is 

not all-inclusive, several examples of 

chemicals that pose special risks to children 

(arsenic, asbestos, lead, and mercury) are 

discussed. 

IV.A. Arsenic 

Arsenic is a toxic heavy metal used in 

products such as wood preservatives and 

pesticides. Exposure to arsenic is associated 

with an increased risk of bladder and lung 

cancers, among other serious health effects.8 

Children may be exposed to arsenic on 

school grounds through contact with 

materials containing arsenic compounds, 

such as chromated copper arsenate (CCA). 

CCA is a preservative and pesticide that was 

historically used to pressure-treat lumber for 

outdoor products, including playground 

equipment. Children can be exposed to 

arsenic by playing on CCA-treated 

recreational equipment. Arseniccontaminated soil from playground areas 

containing CCA-treated wood also can be 

tracked into classrooms on shoes or 

clothing.9 

The likelihood that wooden playground 

equipment at existing schools has been 

treated with CCA is high. Though its use 

was discontinued in 2003, existing stocks 

of CCA-treated wood may have been sold 

through mid-2004. If there is any question 

as to whether wooden playsets have been 

treated with CCA, it should be assumed that 

they have.10 Exposure to CCA-treated wood 

can be minimized. Children should wash 

their hands thoroughly with soap and water 

immediately after outdoor play. Children 

also should be discouraged from eating near 

CCA-treated wood.11 

IV.B. Asbestos 

Asbestos is a naturally occurring mineral that 

was once widely used in products for its heat 

resistant properties, though its uses have 

diminished substantially. Exposure to 

asbestos, particularly for long periods of 

time, can lead to diseases such as asbestosis, 

lung cancer, and mesothelioma.12 Intact, 

undisturbed asbestos-containing materials 

(ACMs) generally do not pose a health risk. 

These materials may become hazardous if 

they are damaged, disturbed, or allowed to 

deteriorate and thus release asbestos fibers 

into building air. 

Though its use has been discontinued in 

many products, ACM can be found in most 

of the nation’s primary, secondary, and 

charter schools. Asbestos is most commonly 

found in insulation and building materials 

such as floor and ceiling tile, cement asbestos 

pipe, corrugated paper pipe wrap, acoustical 

The EPA provides links to detailed information on Chromated Copper Arsenate (CCA), its uses, and its potential 

health effects on the CCA homepage, http://www.epa.gov/oppad001/reregistration/cca/. 

 Check It Out 

If your school is planning to replace its 

playground equipment, alternatives to CCA are 

available. These alternatives include several 

arsenic-free wood pressure treatments and building 

material alternatives to pressure-treated wood. 

EPA provides information on alternatives to CCA at 

the Chromated Copper Arsenate (CCA) homepage, 

http://www.epa.gov/oppad001/reregistration/cca/ 

index.htm#alternatives. 
 Chemical Management Resource Guide for School Administrators 21 |

Asbestos in Schools 

EPA’s The ABCs of Asbestos in Schools (available at 

http://www.epa.gov/asbestos/pubs/abcsfinal.pdf) answers 

common questions about asbestos in schools and outlines 

the responsibilities of school boards and other school 

officials to protect children and employees from exposure 

to asbestos.

and decorative insulation, pipe and boiler 

insulation, window caulking, spray-applied 

fireproofing, and plaster walls in older 

schools. Asbestos has also been used in 

laboratory gloves, laboratory hoods, and 

chalkboards.13 Some of these products remain on 

the market. 

Federal requirements for asbestos 

management in schools were established by 

the Asbestos Hazard Emergency Response 

Act (AHERA) of 1986, which requires public 

school districts and non-profit private 

schools to inspect buildings for asbestos; 

develop plans to manage any asbestos found 

in these buildings; and carry out management 

plans in a timely fashion.14 Damaged ACM 

may be managed through repair; various 

containment methods; or, in cases where 

loose fibers are present, proper removal. It is 

important to note that AHERA only applies 

to building materials. No regulations govern 

the purchase or use of certain asbestoscontaining products, such as laboratory 

gloves, in schools.15 EPA recommends that 

asbestos-free versions of these products be 

purchased for use in schools, along with 

proper disposal of existing asbestoscontaining materials. 

IV.C. Lead 

Lead is a highly toxic metal once widely used 

in products like paint, gasoline, solder, pipes, 

plumbing, and construction materials. Other 

sources of lead in the environment include 

lead from industrial emissions. Exposure to 

lead occurs when it enters the body through 

inhalation or ingestion of lead dust, particles, 

or chips. Lead can cause serious damage to 

the brain, nervous system, kidneys, and red 

blood cells. Young children, especially those 

6 years and younger, are at particular risk for 

lead exposure because they have frequent 

hand-to-mouth activity and absorb lead more 

easily than do adults. Even at low levels, lead 

can cause children to have learning and 

behavior problems, delays in physical growth, 

and lower IQs. 

In schools, lead is most commonly found in 

the paint, dust, soil, and water. Some schools 

may have other sources of lead, such as art 

and photography supplies, pottery glazes, and 

science lab materials. Consider reducing the 

use of lead in science experiments and, where 

it must be used, only use it in dilute solutions 

that are captured and properly disposed. 

Lead paint hazards are of special concern in 

areas occupied by children. In 1978, the 

Consumer Product Safety Commission 

banned the use of lead in paint; therefore, 

lead-based paint is limited to older school 

buildings. These buildings and the 

surrounding soil can be contaminated by 

flaking paint chips or dust. The only way to 

know for sure whether your school has leadbased paint is to have the paint and soil 

tested for lead by a state-certified lead 

inspector. 

Lead in Paint, Dust, and Soil: 

• EPA , Rules and Regulations, http://www.epa.gov/lead/pubs/regulation.htm 

Lead in Drinking Water in Schools: 

• EPA, 3Ts for Reducing Lead in Drinking Water in Schools, http://www.epa.gov/safewater/schools/pdfs/lead/ 

toolkit_leadschools_guide_3ts_leadschools.pdf 

• EPA, Guidance and Tools, http://www.epa.gov/safewater/schools/guidance.html 

 Check It Out 
| 22 Chemical Management Resource Guide for School Administrators 

A Mercury Spill in Washington, D.C. 

“On October 2, 2003, the Washington, D.C.'s Fire 

Department Hazmat Unit responded to an emergency call 

unlike any call Ballou High School had ever had to make. 

What the D.C.'s Hazmat unit found that afternoon proved to 

be the beginning of a long, exhausting search for and clean 

up of an elemental mercury spill. By the time the D.C. 

Hazmat Team and the D.C. public health officials arrived, 

it was too late to contain all the spills; varying amounts of 

mercury were found in the classrooms, gymnasium, and 

cafeteria. Contamination did not stop there. Students 

unknowingly carried mercury through the streets, onto city 

and school buses, and into their homes. As a result of the 

spill, Ballou High School was closed for 35 days and over 

200 homes were tested for mercury contamination.” 

For additional information, see EPA’s Superfund 

Featured News Article, http://www.epa.gov/ 

superfund/news/mercury.htm 

Lead can also leach into drinking water from 

pipes, solder, or brass plumbing fixtures. 

There is no federal law requiring sampling of 

drinking water in schools that are served by a 

public water system, although schools and 

local jurisdictions may establish programs for 

testing drinking water lead levels in schools. 

EPA and others have issued guidance 

designed to help schools develop and 

implement a sampling protocol to test for 

lead in their drinking water.16,17,18,19 

IV.D. Mercury 

Mercury is a naturally occurring element used 

to make many consumer products. Exposure 

to high levels of mercury, as would occur 

with the direct inhalation of mercury vapor 

released during a mercury spill, is associated 

with damage to the brain, heart, kidneys, 

lungs, and immune system.20 While the 

general public can clean up small mercury 

spills no greater than the amount contained 

in a single fever thermometer following 

proper instructions, larger spills must be 

cleaned up by professionals.21 In fact, when 

a spill of more than two tablespoons of 

mercury occurs, it is mandatory to call the 

National Response Center (800-424-8802).22

Science classrooms and storerooms often 

contain elemental mercury or mercury 

compounds used as laboratory reagents. 

Science classes also may use mercury 

thermometers, or other mercury-containing 

laboratory instruments such as barometers 

(pressure gauge for measuring the pressure of 

the atmosphere). These all create significant 

risks of mercury spills, particularly if students 

have access to them. There is no need for 

science classrooms to use these chemicals 

or devices; there are safe, non-mercury 

replacements for all of them. In addition, 

nurses’ offices often contain mercury fever 

thermometers and sphygmomanometers 

(blood pressure measuring devices), which 

also pose spill risks because they are easily 

breakable. EPA encourages schools to 

prevent spills by removing all elemental 

mercury, mercury compounds, and mercury 

measurement devices from classrooms and 

nurses’ offices. 

Mercury is also used in many of the types of 

items that are found in all buildings, such as 

thermostats, flow meters, boiler controls, 

and electrical equipment. Generally, such 

equipment poses little risk of spill because 

the mercury is not easily accessible and the 

products are not easily broken. However, 

such equipment needs to be disposed of 

properly at the end of its life, and new 

equipment should be mercury free. School 

building maintenance staff should inventory 

mercury-containing equipment, properly 

dispose of it when it comes out of service, 

and implement mercury-free purchasing 

policies. Maintenance staff should also not 

use, and instead properly dispose of, any 

remaining stores of old janitorial supplies, 

such as latex paints (prior to 1992) and 

pesticides (prior to 1994), because these may 

contain mercury.23

Schools should not use or store elemental 

mercury or mercury compounds. They should 

replace all mercury thermometers and manometers 

with mercury-free products. Mercury must be 

disposed of properly. 
 Chemical Management Resource Guide for School Administrators 23 |

Schools should continue to use one category 

of mercury-containing product – fluorescent 

lamps. There is currently no alternative to 

mercury-containing fluorescent lamps that is 

as energy efficient and that is appropriate for 

general indoor lighting. The energy 

efficiency of fluorescent lamps makes them a 

good environmental choice because of less 

emissions of mercury and other pollutants 

from power generation. However, while the 

amount of mercury in each lamp is small, 

schools use significant numbers of lamps, 

and these must be disposed of properly. 

Contact your EPA Regional Office, the EPA 

RCRA hotline at (800-424-9346), or your 

state agency to confirm the most current 

rules and information on fluorescent lamp 

waste management and disposal in your state. 
| 24 Chemical Management Resource Guide for School Administrators 

V. Conclusion 

Chemicals are used daily in both the 

maintenance of schools and the curriculum 

taught. They help students to perform 

experiments and learn new skills, among 

other benefits. They are important to many 

aspects of school maintenance. In the 

absence of chemicals, schools would lack 

certain fundamental tools needed to educate 

students. Despite their useful purposes, 

chemicals can be dangerous to students and 

staff when managed improperly. Some 

chemicals that are persistent in the 

environment and bioaccumulate through the 

food chain can make exposure during 

childhood and adolescence especially 

dangerous. Ensuring that chemicals are 

properly managed will help school 

administrators to safeguard the health and 

safety of students and school employees; 

avoid disposal expenses and school closures 

associated with spills and emergency 

incidents; maintain a sense of trust between 

the district and the surrounding community; 

and prevent unintended discharges and spills 

which inflict damage upon the environment. 

Consistent policies and practices are 

recommended in all school systems: 

• Appoint responsible leadership and 

institute “team training” regarding best 

practices of chemical and product 

management. 

• Support chemical management effort with 

appropriate budget. 

• Share your experiences with other districts 

and administrators. 

• Purchase safer alternatives to hazardous 

substances. 

• Adopt policies encouraging proper 

purchasing, labeling, storage, and disposal 

of chemicals and products. 

• Train faculty and staff (and students, as 

applicable) on the potential dangers posed 

by chemicals and on alternatives that are 

less hazardous that may be available. 

• Disseminate information on reducing the 

quantity and hazards of hazardous 

chemicals and products. 

When implemented effectively, chemical 

management promotes awareness about the 

range of chemicals and products used in 

schools and creates a healthier and safer 

atmosphere for school occupants and the 

surrounding environment. For additional 

information, contact your EPA Regional 

Office or consult on-line resources to 

understand environmental health issues in 

schools, such as EPA’s SC3 and EPA’s 

HealthySEAT. The ultimate purpose of the 

SC3 is to reduce chemical exposures and 

improve chemical management in K-12 

schools, while HealthySEAT can be 

customized to assist school districts in the 

evaluation and management of all of their 

environmental, safety, and health issues, 

including all aspects of their chemical 

management programs.

EPA Resources for Additional Information 

Schools Chemical Cleanout Campaign (SC3), http://www.epa.gov/sc3/ 

Healthy School Environments Assessment Tool (HealthySEAT), http://epa.gov/schools/healthyseat/ 

 Check It Out 
 Chemical Management Resource Guide for School Administrators 25 |

References 

1 EPA. 2006. Case Study – Environmental, Health & Safety Issues in One New England Public High 

School, Summary 1996. Available at http://www.epa.gov/region1/assistance/schools/health.html

[Accessed March 24, 2006]. 

2 University of Wisconsin-Extension. 2004. Why Focus on Mercury in Schools? Available at 

http://www.mercuryinschools.uwex.edu/schools/why.htm [Last updated July 15, 2004; Accessed 

May 23, 2006]. 

3 EPA. 2006. What is the TSCA Chemical Substance Inventory? Available at 

http://www.epa.gov/opptintr/newchems/pubs/invntory.htm [Last updated March 3, 2006]. 

4 National Institutes of Health, National Library of Medicine. 2004. Household Products Database 

Frequently Asked Questions. Available at http://householdproducts.nlm.nih.gov/faq.htm#7 [Accessed 

April 26, 2006]. 

5 Maryland State Department of Education. 1999. Science Safety Manual: Chapter VII. Chemicals: 

Managing, Handling and Disposing. Available at http://www.mdk12.org/instruction/curriculum/

science/safety/chemicals.html [Accessed April 6, 2006]. 

6 Executive Order 13101-- Greening the Government Through Waste Prevention, Recycling, and Federal 

Acquisition. September 14, 1998, available at http://www.ofee.gov/eo/13101.htm. 

7 Maryland State Department of Education, http://www.mdk12.org/instruction/curriculum/science/

safety/chemicals.pdf. 

8 U.S. Consumer Product Safety Commission. 2006. Chromated Copper Arsenate (CCA) – Treated 

Wood Used in Playground Equipment Fact Sheet. Available at: http://www.cpsc.gov/phth/ccafact.html 

[Accessed April 5, 2006]. 

9 Shendell, D., C. Barnett, and S. Boese. 2004. Science-based recommendations to prevent or reduce 

potential exposures to biological, chemical, and physical agents in schools, Healthy Schools Network, Inc. 

[Available at http://www.healthyschools.org/documents/HPSchlsWhtPpr.pdf]. 

10 U.S. Consumer Product Safety Commission. 2006. Chromated Copper Arsenate (CCA) -Treated Wood 

Used in Playground Equipment Fact Sheet. Available at: http://www.cpsc.gov/phth/ccafact.html 

[Accessed April 5, 2006]. 

11 U.S. Consumer Product Safety Commission. 2006. Chromated Copper Arsenate (CCA) -Treated Wood 

Used in Playground Equipment Fact Sheet. Available at: http://www.cpsc.gov/phth/ccafact.html 

[Accessed April 5, 2006]. 

12 EPA. 2006. Asbestos and Schools. Available at: http://www.epa.gov/asbestos/pubs/

asbestosinschools.html#5 [Accessed April 5, 2006]. 

13 EPA. 2006. Where Can Asbestos Be Found? Available at: http://www.epa.gov/asbestos/pubs/

asbuses.pdf [Accessed April 5, 2006]. 

14 EPA. 2003. The ABC’s of Asbestos in Schools. Available at http://www.epa.gov/asbestos/pubs/

abcsfinal.pdf [Revised August 2003; Accessed October 4, 2006]. 

15 Phil King, U.S. EPA Region V Asbestos Coordinator. 2006. Personal communication 

[February 24, 2006]. 
| 26 Chemical Management Resource Guide for School Administrators 

16 University of California at Berkeley. 2000. Working in a Lead-Safe School, Facts for School 

Maintenance Workers. Available at http://ist-socrates.berkeley.edu/~lohp/graphics/pdf/

LEADSAFE.PDF [Accessed May 30, 2006]. 

17 EPA. 2006. Lead in Paint, Dust, and Soil. Available at http://www.epa.gov/lead/index.html 

[Accessed May 16, 2006]. 

18 EPA. 2006. 3Ts for Reducing Lead in Drinking Water in Schools. Available at http://www.epa.gov/

safewater/schools/pdfs/lead/toolkit_leadschools_guide_3ts_leadschools.pdf [Accessed May 26, 2006]. 

19 EPA. 1994. Lead in Drinking Water in Schools and Non-Residential Buildings. Available at 

http://www.epa.gov/safewater/consumer/pdf/leadinschools.pdf [Accessed May 30, 2006]. 

20 EPA. 2006. Mercury - Basic Information. Available at http://www.epa.gov/mercury/

about.htm#sources [Accessed April 5, 2006]. 

21 EPA. 2006. Mercury - Spills, Disposal, and Site Cleanup. Available at http://epa.gov/mercury/

disposal.htm#SPILLS [Accessed April 5, 2006]. 

22 EPA. 2006. Environmental Emergencies. Available at http://www.epa.gov/epahome/emergenc.htm

[Accessed November 1, 2006]. 

23 University of Wisconsin Extension’s Solid and Hazardous Waste Education Center. 2003. Where is 

Mercury in Schools? Available at http://www.mercuryinschools.uwex.edu/schools/where.htm 

[Accessed April 5, 2006]. 

24 LAUSD, OEHS. 2005. LAUSD Approved Chemicals List (Inventory List). Available at 

http://www.lausd-oehs.org/docs/CSC/Combined%20Chemical%20Inventory.pdf 

[Accessed April 5, 2006]. 

25 Californians for Alternatives to Toxics. 2006. Model School IPM Policy. Available at 

http://www.alternatives2toxics.org/pdfs/sampleIPMpolicy.pdf [Accessed April 4, 2006]. 

26 LAUSD, OEHS. 2005. School Laboratory Chemical Hygiene & Safety Plan. Available at 

http://www.lausd-oehs.org/docs/CSC/Chemical%20Hygiene%20Plan.pdf [Accessed April 5, 2006]. 

27 U.S. Centers for Disease Control and Prevention, Office of Health and Safety. 2000. Chemical Storage 

Guidelines. Available at http://www.cdc.gov/od/ohs/ENVIRONM/khemstore.htm 

[Accessed April 28, 2006]. 

28 Rhode Island Department of Health and Department of Elementary and Secondary Education. 1964 

(as amended, through 2005). Rules and Regulations for School Health Programs. Available at 

http://www.rules.state.ri.us/rules/released/pdf/DOH/DOH_3592.pdf [Accessed April 5, 2006]. 

29 Washington Department of Health and Office of Superintendent of Office of Public Instruction. 

2003. Health and Safety Guide for K-12 Schools in Washington, 2nd Edition. Available at 

http://www.k12.wa.us/SchFacilities/pubdocs/SafetyManual2002-2003/CompleteSafety& 

HealthManual2002-2003.pdf [Accessed April 27, 2006]. 
 Chemical Management Resource Guide for School Administrators A-1 |

Appendix 

Chemical Hygiene and Management Plans 

Responsible chemical management and hazard communication procedures help to minimize the 

risk of accidental exposures in schools. Chemical hygiene or management plans provide 

guidelines for handling chemicals in schools using tools such as inventory lists (see example below, 

extracted from an existing inventory list24). 

LAUSD APPROVED CHEMICALS LIST (INVENTORY LIST) 

School/Site: _______________ 

Name: ___________________ 

Signature: ________________ 

 Room No.: ___________ 

Time Spent: ___________ 

Date: ___________

Chemical 

Name Manufacturer 

Material 

Safety 

Data 

Sheet 

Yes/No 

Compatible 

Storage 

Hazard Health 

Effects HR 

Total 

Number of 

Containers 

Total Quantity 

GM=grams, 

KG=kilograms, 

LB=pounds, 

OZ=ounce, 

CC, liter 

Shelf Life 

(Months) 

Expired 

Chemical 

Yes/No 

Gram’s Iodine 

Stain= Iodine 

Solution, Gram 

 I-2 Poison, Human 

mutation data 

reported, 

Experimental 

reproductive effects. 

3 1 – 10 

Gypsum 

CaSO4.xH2O 

 I-2 See Hazard Rating 

(HR) 

1 1 – 10 

Iodeosin 

C20H8I4O5

 I-2 Poison, Human 

mutation data 

reported, 

Experimental 

reproductive effects. 

3 1 – 10 

**** Iodine 

(crystals) 

(PEL 0.1 ppm) 

 I-2 Poison, Human 

mutation data 

reported, 

Experimental 

reproductive effects. 

3 1 – 10 

Iodine Solution I-2 Poison, Human 

mutation data 

reported, 

Experimental 

reproductive effects. 

3 1 – 10 

Lithium 

Chloride LiCl 

 I-2 Poison, Human 

mutation data 

reported, 

Questionable 

carcinogen, 

Experimental 

neoplastigenic, 

teratogenic and 

reproductive effects. 

3 1 – 10 
| A-2 Chemical Management Resource Guide for School Administrators 

Examples of school chemical hygiene/management plans and associated resources include: 

• Maine Department of Labor, Sample Chemical Hygiene Plan for Maine Schools, 

http://www.safetyworksmaine.com/safe_workplace/sample_programs/school_chemical_hygiene_plan.htm 

• Maine Department of Environmental Protection, Scientific Lab Chemical Inventory spreadsheet, 

http://www.maine.gov/dep/mercury/chemical_inventory_list.xls 

• Colorado Department of Public Health and Environment, Guidance on Chemical Management in Schools, 

http://www.cdphe.state.co.us/cp/Institutions/Schools/Chems%20In%20Schools/ChemMgmt.html 

• Massachusetts Department of Environmental Protection, Massachusetts School Chemical Management 

Program, http://www.mass.gov/dep/service/schlchem.pdf 

• Illinois State Board of Education, Chapter 12 of the Guidebook for Science Safety in Illinois, 

http://www.isbe.net/ils/science/pdf/science_safety.pdf 

• EPA, Chemical Management and Usage, http://www.epa.gov/Region7/education_resources/ 

teachers/ehsstudy/ehs1.htm 

Hazard Communication Programs also have been implemented in various school districts: 

• Putnam City Schools (Oklahoma) – Hazard Communication Standard, 

http://www.putnamcityschools.org/pageid333.html 

• Penasco Independent School District (New Mexico) – Hazard Communication Program, 

http://www.penasco.k12.nm.us/policies/10_12.htm 

 Check It Out 
 Chemical Management Resource Guide for School Administrators A-3 |

Model School IPM Policy 

A. Policy Statement 

The {insert name} School District recognizes that the maintenance of a safe, clean, and healthy environment for 

students and staff is essential to learning. It is the goal of the District to provide the safest and lowest risk approach 

to control pest problems, while protecting students, staff, the environment, and district property. 

The District hereby adopts a Least-Toxic Integrated Pest Management (IPM) policy. This policy shall focus on 

long-term pest prevention and give non-chemical methods first consideration when selecting appropriate control 

techniques. The full range of alternatives, including taking no action, will be considered first, with chemical controls 

used as a last resort. Preference will be given to chemicals and methods of application that pose the least hazards 

to people and the environment. The District’s long-term goal is the elimination of all chemical pest control methods. 

B. Role of the IPM Coordinator 

The IPM coordinator shall be named to coordinate the district’s efforts to adopt IPM techniques, and shall be 

provided with training on least toxic pest management practices. Specific responsibilities include: 

• Overall program management and providing proposed regulations or procedures and products for use in 

managing pest populations 

• Education and training for IPM personnel 

• Formal annual notification to parents, staff, and students of any potential chemical pesticide application 

• Posting of warning signs for all pesticide applications 

• Establishment and maintenance of a registry of parents, staff, and students who have indicated a desire for prior 

notification of each pesticide application 

• Advance notification for individual pesticide applications 

• Recordkeeping for any chemical pesticide application 

C. Pesticide Product Selection and Use Approval 

Selection of pesticide products will be based on the IPM coordinator’s review of the product’s contents, precautions, 

and adverse health effects. The IPM Coordinator will prioritize the use of the following nontoxic products: 

1. Approved Products 

Mechanical or Biological Products 

• Caulking agents and crack sealants 

• Physical barriers 

• Electronic products, heat, and lights 

Chemical Products 

• Soap-based products 

• Borates, silicates, and diatomaceous earth 

• Insecticide or rodenticide self-contained baits and traps 

Sample Guidelines

In addition to preparing comprehensive management plans, many school districts throughout the 

U.S. have implemented other types of guidelines, such as integrated pest management (IPM) 

policies, to minimize the use of toxic chemicals. An excerpt adapted from a sample policy

developed for use by California schools is shown below:25
| A-4 Chemical Management Resource Guide for School Administrators 

For more information on IPM in schools, visit: 

• EPA, Integrated Pest Management (IPM) in Schools, http://www.epa.gov/pesticides/ipm/ 

• EPA, Pesticides: Controlling Pests, Storing Pesticides, http://www.epa.gov/pesticides/ipm/brochure/steps6-7.htm 

• California Department of Pesticide Regulation, Model Program Guidebook, 2nd Edition, 

http://www.cdpr.ca.gov/cfdocs/apps/schoolipm/managing_pests/guidebook.cfm 

• University of Florida/EPA, National School IPM Information Source, http://schoolipm.ifas.ufl.edu/ 

• Texas A&M University/EPA, IPM Resource Center for Schools and Childcare Facilities, 

http://schoolipm.tamu.edu/ 

• Massachusetts Natural Resources Collaboration, IPM Tools & Resources, http://massnrc.org/ipm/schoolsdaycare/ipm-tools-resources.html 

• Minnesota Department of Agriculture, Management of Pesticides, www.mda.state.mn.us/ipm/fspesticides.pdf 

• National Pesticide Information Center, http://npic.orst.edu/ 

 Check It Out 
 Chemical Management Resource Guide for School Administrators A-5 |

Checklists 

Checklists are often used to clearly identify chemical management actions and to verify that they 

have been completed (see basic example below, an excerpt adapted from the Los Angeles Unified 

School District “School Laboratory Chemical Hygiene & Safety Plan”26). 

LOS ANGELES UNIFIED SCHOOL DISTRICT 

MONTHLY CHECKLIST FOR SAFE HANDLING AND STORAGE OF CHEMICALS 

To be completed by C.S.C. 

ACTIVITY Yes No 

1. All chemicals are correctly and clearly labeled. 

2. Unlabeled containers and chemical wastes have been inventoried and a disposal request submitted to OEHS. 

3. Only chemicals that are being used are continually being stored. 

4. Only the amount of chemicals which can be consumed within a year are being stored. 

5. CSC is aware of and has trained others on hazards and precautions for protection prior to using any chemical, 

and has reviewed the precautionary labels and contents before using any chemical product. 

6. All chemicals are stored by compatibility (see CHSP Appendix IV, Table 1: Chemical Shelf Storage 

Identification Chart and Table 2: Storage for Compatibility Categories). 

7. Chemicals are stored on shelves below eye level. 

8. Chemicals are being stored on the floor. 

9. Chemicals are being stored in approved storage cabinets. 

10. Neutralizing chemicals, absorbent and other spill control materials are readily available. 

11. Compressed gas cylinders are upright and secured to the wall with caps in place. 

12. Storage cabinets for corrosive chemicals (separated for acids and for bases) are appropriately labeled. 

13. Flammable materials are stored in approved storage cabinets. 

14. Shelving is equipped with lips to prevent products from rolling off shelves and secured to walls/floor to prevent 

tipping of entire sections. 

15. Storage areas/cabinets are labeled to identify the hazardous nature of the products stored within. 

16. Class ABC fire extinguishers are available in chemical storage areas and are in working order. 

17. There are no sources of ignition in the chemical storage area. 

18. Chemical storage area has two exits and egress (exiting) area is clear. 

19. Used and contaminated reagents are stored and labeled properly. 

20. Current and dated inventory lists are posted clearly in each storage room throughout the science department. 

21. Chemical storage cabinets are locked when laboratory classes are not in session. 

 

Certification: I hereby certify that I have completed all of the above activities in fulfillment of my responsibilities as the Chemical Safety 

Coordinator (CSC) for my school. 

 

 

Date School 

 

CSC Signature CSC Name (print) 
| A-6 Chemical Management Resource Guide for School Administrators 

Additional checklists are available at: 

• EPA, HealthySeat Assessment Checklist, 

http://www.epa.gov/schools/healthyseat/AssessmentChecklist_Blank.pdf 

• National Institute for Occupational Safety and Health, NIOSH Safety Checklist Program for Schools, 

http://www.cdc.gov/niosh/docs/2004-101/default.html 

• Massachusetts Healthy Schools Council, Checklist Concerning Environmental Health & Safety in Schools, 

http://mass.gov/Eeohhs2/docs/dph/environmental/iaq/schools_checklist.pdf 

• Washington Department of Health and Office of Superintendent of Office of Public Instruction, Health and Safety 

Guide for K-12 Schools in Washington (Part II), http://www.k12.wa.us/SchFacilities/HealthSafetyGuide.aspx 

 Check It Out 
 Chemical Management Resource Guide for School Administrators A-7 |

Chemical Purchasing, Storage, and Design Guidelines 

Chemical purchasing, storage, and design guidelines have been developed by many school districts and 

state agencies in an effort to eliminate unnecessary purchases of hazardous substances and avoid dangerous 

storage scenarios. General chemical storage principles are illustrated in the following example, adapted from 

the U.S. Centers for Disease Control and Prevention, Office of Health and Safety’s Chemical Storage 

Guidelines:27

Class of Chemical Recommended Storage Method Examples Incompatibilities

Compressed gases – 

Flammable 

Store in a cool, dry area, away from oxidizing gases. 

Securely strap or chain cylinders to a wall or bench. 

Methane, Hydrogen, 

Acetylene, Propane 

Oxidizing and toxic 

compressed gases, 

oxidizing solids 

Compressed gases – 

Oxidizing 

Store in a cool, dry area, away from flammable 

gases and liquids. Securely strap or chain cylinders 

to a wall or bench. 

Oxygen, Chlorine, 

Bromine 

Flammable gases 

Compressed gases – 

Poisonous 

Store in a cool, dry area, away from flammable 

gases and liquids. Securely strap or chain cylinders 

to a wall or bench. 

Carbon monoxide, 

Hydrogen sulfide, 

Nitrogen dioxide 

Flammable and/or 

oxidizing gases 

Corrosives – Acids Store separately in acid storage cabinet. Segregate 

oxidizing acids (i.e., Chromic, nitric, sulfuric, and 

perchloric acids) from organic acids. 

Acetic acid, Phenol, 

Sulfuric acid, 

Chromerge, Nitric acid, 

Perchloric acid, 

Chromic acid, 

Hydrochloric acid 

Flammable liquids, 

flammable solids, 

bases, oxidizers 

Corrosives – Bases Store in separate corrosive storage cabinet. Store 

solutions of inorganic hydroxides in labeled 

polyethylene containers. 

Ammonium hydroxide, 

Sodium hydroxide, 

Calcium hydroxide 

Flammable liquids, 

oxidizers, poisons, 

acids 

Flammable Liquids Store in flammable storage cabinet and away from 

sources of ignition. Store highly volatile flammable 

liquids in an explosion-proof refrigerator. 

Acetone, Benzene, 

Diethyl ether, Methanol, 

Ethanol, Toluene, 

Glacial acetic acid 

Acids, bases, 

oxidizers, poisons 

Consult the following resources for more information on chemical storage, purchasing, and design: 

• Californian Department of Environmental Health Hazard Assessment, Art Hazards, 

http://www.oehha.ca.gov/education/art/index.html 

• King County, Washington, Rehab the Lab, http://www.govlink.org/hazwaste/schoolyouth/rehab/index.htm and 

http://www.epa.gov/epaoswer/osw/conserve/2004news/03-labs.htm 

• Iowa Metro Waste Authority, Rehab the Lab (Hazardous Materials), http://www.metro-waste.com/sch_reh.html 

• EPA, Healthy School Environment Resources: Chemical Purchasing, 

http://cfpub.epa.gov/schools/top_sub.cfm?t_id=361&s_id=363 

• Massachusetts Department of Environmental Protection, Massachusetts School Chemical Management 

Program, http://www.mass.gov/dep/service/schlchem.pdf 

• Commonwealth of Massachusetts, Environmentally Preferable Purchasing Program, Product & Service 

Information, http://www.mass.gov/epp/products.htm 

• Illinois EPA and Waste Management Resource Center, Greening Schools homepage, 

http://www.greeningschools.org/ 

• Maryland State Department of Education, Science Facilities Guidelines, Chapter 5: Design Considerations, 

http://www.mdk12.org/instruction/curriculum/hsa/science_facility/chapter5.html 

 Check It Out 
| A-8 Chemical Management Resource Guide for School Administrators 

Use of Chemicals in Schools

Some states have taken regulatory actions to limit the use of chemicals in schools. For example, Rhode 

Island28 prohibits the use of listed chemicals in schools (see excerpts from Rhode Island’s list below). The 

State of Washington’s Department of Health and Office of Superintendent of Public Instruction also have 

published a tiered list of chemicals: (1) unsuitable for use (see Appendix D, Table 1 of their guide) in K-12 

schools due to excessive risk that exceeds their educational utility, and (2) appropriate only for advanced-level 

high school science classes due to high risk and limited to small- or micro-scale quantities (see Appendix D, 

Table 2 of their guide).29 Furthermore, chemicals that are allowed in schools may vary across districts for 

different reasons (e.g., staff experience, training). 

Full Chemical Name CAS # Reference 

1-(2-tert-Butylperoxy isopropyl)-3-isopropenylbenzene 96319-55-0 49CFR173.225 

1-(o-Chlorophenyl)thiourea 5344-82-1 EPA Acutely Toxic (P Listed) 

1,1-Di-(tert-amylperoxy)cyclohexane 15667-10-4 49CFR173.225 

1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane 6731-36-8 49CFR173.225 

1,1-Di-(tert-butylperoxy)cyclohexane 3006-86-8 49CFR173.225 

1,1'-Diazoaminonaphthalene DOT Forbidden 

1,1-Dimethyl-3-hydroxybutylperoxyneoheptanoate 49CFR173.225 

1,2,3-Propanetriol, trinitrate (R) 55-63-0 EPA Acutely Toxic (P Listed) 

1,2,4-butanetriol trinitrate DOT Forbidden 

Benzene 71-43-2 Reproductive Toxic, Select Carcinogen 

benzene diazonim chloride DOT Forbidden 

Benzene sulphohydrazide 80-17-1 49CFR 173.224 

benzene triozonide DOT Forbidden 

Benzene, (chloromethyl)- 100-44-7 EPA Acutely Toxic (P Listed) 

carbazole 86-74-8 IARC List of Known and Suspected 

 Human Carcinogens 

Carbonic dichloride 75-15-0 EPA Acutely Toxic (P Listed) 

carrageenan 9000-07-1 IARC List of Known and Suspected 

 Human Carcinogens 

chlordane 57-74-9 IARC List of Known and Suspected 

 Human Carcinogens 

dichloromethane 75-09-2 IARC List of Known and Suspected 

Human Carcinogens 

Dieldrin 60-57-1 EPA Acutely Toxic (P Listed) 

guanyl nitrosaminoguanylidene hydrazine DOT Explosive 

hexanitrodiphenylamine 131-73-7 DOT Explosive 

Isopropyl Ether 108-20-3 Peroxidizable 

Lead and lead compounds 7439-92-1 Reproductive Toxic

Methyl chloromethyl ether 107-30-2 OSHA Listed Chemicals 

Methyl ethyl ketone peroxide 1338-23-4 49CFR173.225 

Other states that have passed regulations related to chemicals in schools: 

• Colorado Department of Public Health and Environment, Rules and Regulations Governing Schools in the State 

of Colorado, http://www.csmate.colostate.edu/cltw/Colorado_Rules.pdf 

 Check It Out 

Leadership and Resources

 Pollution Prevention and Greener Alternatives

 Chemical and Product Management

Chemical Inventory

 Purchasing

Storage and Handling

Training

Hazard Communication

Spills, Cleanup, and Disposal

United States Environmental Protection Agency 

Office of Pollution Prevention and Toxics, (7409-M) 

Washington DC 20460 

Official Business 

Penalty for Private Use $300 

EPA 747-R-06-002 

December 2006