GOVERNMENT
Schools Grapple with Rules on Hazardous Chemicals As more states have adopted and expanded federal rules, both large and small schools have moved to develop procedures to cope The impact of federal and individual state safety and health and environmental laws on businesses large and small has been more than adequately documented. A less familiar topic, how educational institutions ranging in size from large universities to local school systems are coping with these laws, was explored at the recent American Chemical Society meeting in New Orleans. For instance, the effect of the Occupational Safety & Health Administration's hazard communication, or right-to-know, standard was examined. As it is now written, the standard applies only to the chemical manufacturing sector, though it soon will be extended to cover all industries that use chemicals. A number of states have adopted and expanded the OSHA standard, however, as a state law. For example, the Commonwealth of Virginia has its own hazard communication standard, adopted in August 1984, that is identical to the federal standard, except for the fact that it covers employees in the public as well as the manufacturing sector. Thus, it applies to the state's public school systems. The experience of one school system, Fairfax County, in dealing with the hazard communication standard was detailed by Thomas Ferguson, an employee of the Fairfax County public school system, and Daniel J. Marsick, an OSHA employee, ACS member, and resident of Fairfax County at the Division of Chemical
Health & Safety's symposium on right-to-know education. The Fairfax school system has 14,765 employees, 161 schools, and 130,981 students. Before employees can be warned about the occupational hazards they face, just what those hazards are has to be determined. Thus, the first step Fairfax took to comply with the standard, according to Marsick, was to ask employees at 179 locations to conduct a hazardous chemical inventory. They were to report the name of the product, name of the manufacturer, quantity on hand, and maximum amount stored. It soon became obvious, Marsick said, that many employees had a difficult time deciding which chemicals were hazardous. Employees engaged in similar activities often did not include the same substances on their inventories. A composite inventory list was then prepared and employees were asked to update their original inventories. Since this updating followed employee training, he noted that reporting and accuracy increased considerably. Though not completely accurate,
the initial inventory did show, according to Marsick, that the school system uses a large number of hazardous chemicals in its instructional and support programs. It also showed that many storage areas contained excess chemicals. Teachers, as a matter of convenience and in an attempt to get the lowest per-unit cost, frequently purchased chemicals in large quantities and tended not to throw them away even when they were no longer needed for instructional purposes. This, he pointed out, led to a variety of problems. For example, large volumes of flammable liquids often were stored in violation of National Fire Protection Association and local fire department guidelines. However, conducting an inventory prompted many teachers to request that the chemicals be removed. This in turn encouraged the county to create a standard removal procedure. During the summer of 1986, a team of two specially trained chemistry teachers visited 41 intermediate and high schools. The team removed excess and obsolete chemi-
Labs must dispose of chemical wastes in environmentally acceptable manner September 28, 1987 C&EN
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Government cals, acutely hazardous art materials, potential explosives, known human carcinogens, and highly toxic substances. A licensed chemical waste contractor was then hired to remove more than 120 55-gal lab packs, three 5-gal lab packs, and 11 2-gal pails. "Even though the cost was high," Marsick pointed out, "the liability created by having such large quantities of excess chemicals on laboratory shelves, under benches, in hoods, and in various other places was even greater." To avoid building up excess inventories in the future, Marsick said the school system instituted controlled purchasing procedures that included an approved list of chemicals for use in the classroom, along with a recommended container size and a maximum-on-hand quantity for each chemical. In addition, he said, the school system is establishing a policy of discontinuing purchases from vendors or manufacturers who are unable to supply a readable and accurate material safety data sheet (MSDS) upon request. Copies of the MSDS for all hazardous chemicals to which school employees may be exposed are kept at each work location. In addition, training courses are available for department heads and supervisors, who in turn train the workers they supervise. The courses detail the physical and health effects of chemicals present in the employee's workplace; methods that can be used to determine the presence of hazardous chemicals in the work area; what work practices and personal protective equipment can be used to lessen or prevent exposure to hazardous chemicals; and emergency procedures to follow if employees or students are exposed to hazardous chemicals. Another law that is having an impact on academic institutions is the Resource Conservation & Recovery Act. High schools, small colleges, and large universities are all legally required to dispose of their chemical wastes in an environmentally acceptable manner. The old practice of throwing waste chemicals in the trash or, more often, down the drain will no longer do. Yet, said Peter Ashbrook, environmental chemical specialist at the 16
September 28, 1987 C&EN
University of Illinois, Urbana-Champaign, laboratory workers still frequently argue that the chemical wastes produced by their single laboratory are extremely unlikely to cause any hazard to anyone because the wastes will be diluted heavily when put down the sewer. That may be true. But as Ashbrook pointed out, at a large university it is not just a question of one laboratory dumping chemicals down the drain, it's 2000. "You may know what you are disposing down the sewer, but you don't know what everyone else is putting down. There is a great potential for mixing incompatible chemicals, as has unfortunately been found out in a number of instances." He suggested that individuals check with their local sanitary district to find out what can and cannot be put into the sewer system. Next, he said, they should consult "Prudent Practices for Disposal of Chemicals from Laboratories," published by the National Academy Press, which provides some general criteria for what types of compounds may be suitable for sewer disposal. Illinois has instituted a centralized waste management program that heavily discourages researchers from disposing of chemicals down the drain for two reasons,
Ashbrook explains. First, since most researchers are there to do research, "we suggest that they give all wastes to my staff and let us determine the best method of disposal. Second," he says, "in an embarrassing number of instances I have found that our researchers have difficulty determining whether a material is hazardous or not." So the only chemicals that can go down the drain, the university has decided, are nonhazardous aqueous wastes such as buffers and aqueous solutions with nonhazardous constituents, and diluted and/or neutralized solutions of inorganic acids and bases and hydrogen peroxide. The first rule for trash disposal, according to Ashbrook, is absolutely no liquids. It is also a good idea, he says, to label empty chemical containers as being safe for disposal and to check with the local sanitary landfill to find out what kind of materials they will accept. Altogether, Ashbrook notes, "at Illinois we have found that 5 to 10% of the waste chemicals handled by our chemical waste management program can be disposed of via the sewer or trash." The rest must go through the regular hazardous waste disposal channels. Janice Long, Washington
Space station plans face formidable challenges The U.S. program to have a permanently manned space station orbiting Earth by 1996—a high-visibility, high-cost, high-risk effort to maintain U.S. leadership in space—has reached a kind of crossroads. On the one hand, a National Research Council panel formed to review the National Aeronautics & Space Administration's space station plans has just issued a report finding the current design for the station's first phase to be "reasonable" and "a good compromise" among the priorities and sometimes conflicting requirements of its potential users (C&EN, Sept. 21, page 16). NASA is reviewing proposals from industry and is primed to award contracts in November for the detailed design and construction of the station hardware. NASA has already awarded three major support
contracts this year. And the House and Senate have authorized full funding of NASA's request of $767 million for the station for fiscal year 1988, with final authorization of NASA's budget awaiting a conference committee. On the other hand, the station has long been embroiled in scientific, budgetary, political, and diplomatic controversy. Building the space station, the NRC panel notes, poses formidable technological, financial, and management challenges, and constitutes "the most ambitious and lengthy task NASA has ever undertaken." The panel criticizes as "marginal" the capacity of the current space shuttle to support assembly and operation of the station. It also finds fault with NASA's decentralized program management and cost underestimates.
