edited by MIRIAMC. NAOEL Avo" High School Avon, CT 06001
Safe Olsposal of Unwanted School Chemicals-A Proven Plan Jack A. Gerlovlch
University Chemist
Iowa Department of Education Grimes State OfficeBldg. DBs Moines, IA 50322
Classroom Chemistry Teacher
Jlm Miller
SET Environmental lnc 350 Sumac Rd. Wheeling, IL 60090 The great majority of schools in this nation are stockpiling unwanted and often hazardous laboratorv chemicals due to problems and costs associated with their kffective disposal. In 1986 and 1987, many states implemented hazardous chemicals risk right-to-know legislation. These Occupational Safety and Health Association (0SHA)Department of Labor rulings require that employers identify all hazardous chemicals, label them properly, and apprise employees, public. and emereencv services agencies of their existence. associated hazards, and appropriate emergency procedures. Since manv chemicals stored in schools are unidentifiable due to age br abuse, this often becomes a very difficult task to accomplish. In most instances, schools have decided it would be best t o purge these chemicals rather than attempt "right-to-know" compliance for them. A t about this same time, the U S . Environmental Protection Agency (EPA) tightened regulations concerning the identification and disposal of hazardous waste for ~ m d l - ~ u a n generators tit~ such as schools. These new regulations make it much more dit'iicult for schools to dispose of unwanted chemicals from science laboratories. The ereat maioritv of schools in this nation are thus stockpiling unwanted and often hazardous chemicals due to problems and costs associated with their effective dis~osal.The purpose of this paper is todescribe a plan, recently completed statewide in Iowa, for the safe, cost-effective redistribution and disposal of unwanted school chemicals.
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Three Steps to Success: The Iowa Paradigm Form Advlsory Committee
The state Department of Education should serve as the coordinator of the overall project for statewide efforts. Parallel regional or county offices can fill the same educational coordination role on a smaller scale. The coordinating offices must identify critical agencies and personnel capable of completing this task, arrange for meeting times and places for this committee, arrange for all mailings to local schools involved in this process, and communicate with necessary state and federal agencies. The core membership of this committee and their respective duties should include, as a minimum, the following: StateDepartmentofNatural Resources State Department of Transportation State Fire Marshall's Office
Intermediate Educational Agencies
Review of relevant state guidelines and advice to the committee concerning conformity. Review of guidelines concerning transport of chemicals over intrastate highways. Review of parameters necessary for safe intrastate handling and disposal of flammables and exdosives.
School Administrat01 Chemical Transport and Disposal Company Representative
Establishment of regional training and chemical pickup sites and local school billing procedures. Technical advice concerning chemicals. Reaction totasks proposed for local classroom teachers to accomplish. Advising the committee eoncerning building related activities. Securing EPA permits for schools, packaging instructions for chemicals,cost itemization.
Additional, optional organizations: Major School Insurance Carrier School Board Association
Supplying accident information and possible funding assistance for safety software dissemination and personnel training. Apprising administrative groups and gaining support for the process.
In selecting a chemical transport and disposal company for these tasks, make certain that information is secured from the state Department of Natural Resources concerning which com~anieshave ex~eriencein doing this t v ~ of e work. Be careful t o eliminate those who have cornmitiid environmental violations. Most important, the advisory committee should ask each company bidding to do this job to put their plan, including all costs, in writing. After review of these ilans, the stn,ngest contenders should he invited to present their plans, in person, tothecommittee. I1 iscriticollhor the company selefted haue had past experience in such operations with schools! I t is equally critical that the company haue several disposal site options auailable to it! D ~ V ~ aOPlan D of Action
The advisory committee should anticipate 12-15 months to complete this total plan. Three to four months should be devoted todevelopingand refining the total plan: one month for in-service of oartici~ants,three to four months for conducting the safety ass&sments and chemical inventories, and six months for the actual chemical pickups. The advisory committee should complete their preliminary plan and secure tentative approval from the state organizations represented. They should then send the plan to their respective Environmental Protection Agency regional office for chanees and annroval. Aeain. - . anticioate three to four months t ~ c o m p l e t e ~ hphase. is Immediatelv after selecting a transDort and d i s ~ o s acoml pany to assistln this operati&, the advisory committee will need to make a decision concerning landfilling versus incineration of chemicals. Landfilling is 25% to 35% of the cost of incineration; however, the liability for the chemicals is perpetual. In addition, since only 6040% of chemicals can be legally and safely incinerated, landfilling will have to be included as at least part of the solution. Ask your transport and disposal company for advice early. Arranee for in-service trainine of all school renresentatives p&icipating in the chemiFal pickup. Each h-service should he approximately three to eight hours in duration, depending upon whether the in-service also includes awareness training in state "right 40-know" legislation, and Volume 66
Number 5
May 1989
433
should be conducted a t the regional intermediate educational agency, community college, or college campus sites where the pickup will eventually occur. The critical requirements for such a site are: locations that assure limited travel requirements for all participants sufficient auditorium space to accommodate all school teams (chemistryteacher, principal from each school) easily accessible for semi trucks to park for chemical pickup, including a covered area in the event of rain or snow area which em he cordoned off from traffic agency which is accustomed to working regularly with schools.
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Speakers who are knowledgeable in science safety and who have been involved in school chemical pickup operations in the past should he identified to explain each phase of the o~eration.The advisorv committee members should assist in further explanation. The following comoonents are essential to explain fully during each in-iervic; (please refer to the reference by Gerlovich et al. for assistance):
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Relevant Laws, eodes,regulations,andstandards, including review of relevant case studies. Conducting asafety assessment of school facilitiesand equipment and hnw t.~. n correct ....... identified . ~nmhlems. ~ ~ Inventtrying, labeling, properly storing, and identifying hazards aaawiated with chemicals in your in$,entory.All items left after this process should be disposed' Completing EPA temporary disposal permits. Pre~arinp:chemicals identified for disposal to be transported and disposed. Costs involved for local schools. Timelines for completing each of the above steps.
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Review and code the waste chemical inventories,including EPA and DOT hazard class information. Organize and consolidate similiar and compatible chemicals from multiple schools. Secure school EPA and DOT chemical permits. Prepare master drum inventory forms. Prepare disposal site permit applications. Distribute instructions to teachers far safe handling and legal shipment of waste chemicals from the schools to the chosen drop-off site. Technical specialists,familiar with chemical hazards, spill clean-up procedures, and disposal site requirements, package the waste chemicals. Pick up and transport chemicals to multiple disposal facilities.
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Conduct the Chemical Pickuo and Diswsal No one wants to see a teacher or student injured during such chemical cleanuo ooerations. This chemical pickup is n therefore based ~ ~ o n ' t h e a s s u m p t i othat:
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teachers have conducted safety assessments of their facilities and equipment and that they haw properly labeled, stored, and assessed the hazards of all chemicnlr in their inrentow ~ r i o to r beainning.this -process of removal of those chemicals that are excissive in quantity, unlabeled, or exceptionally hazardous for student use.
Once chemicals are set aside for disposal, a complete waste chemical inventory should be submitted to the chosen waste disposal company. The following information would be required, as a minimum, in order to make an evaluation of possible disposal options and costs: complete chemical name container type container size amount in container physical state (liquid or solid). I t is important to note that lab chemicals have a wide variety of properties, many of them requiring unique disposal methods, such as: Organic soluents require incineration. Water reactives and air-sensitiue materials require special handling and customized treatment methods. Heauy metal salts, cyanides, acids, bases, require chemical treatment. Unknowns or trade nornes must be fully identified prior to disposal site acceptance. Explosir,esor peroxide formera may require remote detonation. Nunhazurdous lab chemicola may not be accepted in local landfills unlicensed to accept such items.
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Any size school could have waste chemicals that fit in these categories. This is the major economic reason for implementing statewide, regional, county, community (involves schools, husinesses, hospitals, filling stations, etc.) or school district-wide collection and disoosal oroerams. The actual chemical pickup,at thechosen protected central location for all schools involved. will follow the stem outlined below. The price for the pickup and disposal will Le based upon how many of these essential services the chosen company can provide.
Journal of Chemical Education
Bv coordinatine the disoosal activities among manv schools s&ultaneousl< waste disposal companies can red;ce their costs for such services by as much as 70%. Expectations In Iowa this total plan was completed in 15 months with 97% of Iowa's 436 school districts participating. Twentyeight thousand containers were transported from 900 huildings t o 15area education agencies and then repacked by S E T Environmental, Inc., in 55-gallon drums (lab packs) and shipped to approved disposal sites throughout the United States. The cost of this operation was borne by the local school districts a t an average price of $575 per district (approximately $7.25/1b, 1 p t = 1 lb). A second pickup is being planned for such intractihle chemical problems as: Gas cylinders Unknowns Air-renrrtivechemicals Peroxide-formingchemicals Radioactive wastes Due to careful ~ l a n n i n e .a strone safetv emohasis. the involvement of ciitical s k e agenEies, tde flekhilit; of the EPA, and the experience of the disposal company selected, this process was completed quietly and efficiently without incident. All varticioating . - schools were well satisfied with the outcome of the process; the only concern expressed was the perception of excessive time required to accomplish the total process. Considering that there were no guidelines to follow and that the process was completed without a single incident. these timelines are auite remarkable. Other states can takeadvantage of the 1o;a experience and may he able to accomolish this critical activitv in somewhat shorter timelines. General References Code of Federal Regulstions. 40. Part 261. Envhnmcrntd ProtectionAgency, July, 1985. " R i h t To Know"Rules, Iowa Bureau of Lshor, April 9,1986. Gerlovieh,J.: Gererd,T.;Hartman, K."TheTotdScienceSafetySystem".Thiaiaathreediskmfkware package in 1BMor Appleversionsavsilable for under $€OffromNASCO. 1-W-558-9595,or Sargent Welch, 1-800-332-4341.Diak 1 encamp-a Ism, d e a , standards, regulations, and case studies: Disk 2 provides checklists and form%for mnducting a safety aaseeament: Disk 3 is a 4M-item chemical isbeling, starage,hazsrd assessment data baa*.
