III. ADMINISTRATIVE PREPARATION & TRAINING
Performing a chemical cleanout of a school necessitates a multi-faceted approach led by the school’s administration and preferably backed by the assistance of key players at the district level, including the Purchasing Director and the Facilities Service Manager amongst others. One of the first steps in preparation and training is informing employees of the federal regulations that exist governing chemical use. Most notably is OSHA’s Right to Know Law (“HAZCOM”) or CFR 1910.1200. The crux of HAZCOM is simply that employees have a right to know what chemicals they are working with or around in their workplace. HAZCOM mandates that all chemicals in the workplace be evaluated for health and physical hazards and requires for that information to be made available to all employees (MSDS sheets - see Administration folder).
In addition, an effective school chemical cleanout will have a person(s) filling one or more of five different roles:
- an administrative leader
- a point-person for the inventory process, to make sure an inventory is completed for each relevant school sector
- a point-person for the disposal process, to gather together the information on products and chemicals requiring disposal from each of the school's relevant sectors, and to make arrangements with a hauling company
- a point-person to oversee implementation of preferred storage and labeling procedures
- a point-person overseeing new purchases (and the adoption of a purchasing policy) to encourage teachers and school staff to incorporate "green product" recommendations
To get started, it may be sufficient to identify your point-person for the inventory process, but you will soon need to be sure the other roles are filled as well.
In the Administration Department-Specific section of this Toolkit, the administrative lead will find the following helpful documents :
- A Chemical Management Intro questionnaire/checklist to assist school administrators in assessing the status of their school’s chemical management system.
- BMP checklists for purchasing, storage, and labeling mirroring those found in the individual sector folders.
- Inventory Instructions document and Inventory Tips document for review and planning before the inventory process.
- Sample forms including MOU’s, purchasing logs etc.
- Keller’s Official OSHA Safety Handbook, 5 th edition