The Importance of a Chemical Hygiene Plan in Schools

As science educators, we bear a responsibility not only to educate students but also to ensure their safety within our classrooms and labs. A critical element of this responsibility is the implementation of a comprehensive Chemical Hygiene Plan (CHP). In school districts across the country, CHPs are an essential part of maintaining safe environments for both staff and students who work with hazardous chemicals.  It is a legal requirement to have a Chemical Hygiene Plan that is comprehensive and current (reviewed at least once in a 12 month period) for districts and private schools.  There are some exceptions to this in certain states and circumstances yet having this CHP is a great safety reference and resource for multiple reasons.

A well-developed CHP helps schools comply with OSHA’s “Occupational Exposure to Hazardous Chemicals in Laboratories” standard, commonly known as OSHA 1910.1450 or commonly as the ‘Laboratory Standard’. It sets guidelines for chemical safety, ensuring that everyone working with chemicals and related hazards in the laboratory is protected from potential hazards and resulting risks. Below are the main points your school’s CHP should address to create a safer and more compliant lab environment.

1. What is a Chemical Hygiene Plan (CHP)?

A Chemical Hygiene Plan is a written document designed to protect employees, students, and anyone in a laboratory from exposure to hazardous chemicals. This plan outlines safety procedures, practices, and policies to responsibly manage chemicals, minimize potential risks, and ensure that anyone handling chemicals has the proper knowledge and equipment to do so safely.  This will include PPE, engineering controls like fume hoods and eye wash stations among others.

According to OSHA 1910.1450, every school or institution using chemicals in a laboratory setting must have a CHP in place. The National Science Teaching Association (NSTA) reinforces this requirement, advocating for science educators to take an active role in understanding and maintaining their school’s chemical hygiene policies.  This is in an effort to provide a safer teaching and learning instructional space for science and STEM programs.

2. The Components of a CHP

Your school’s Chemical Hygiene Plan should be a living document, updated regularly to address the evolving safety needs of your labs. Key components of a CHP include but not limited to:

• Chemical Inventory and Labeling: Accurate documentation of all chemicals in your lab is vital. A comprehensive inventory system ensures that no hazardous materials go untracked and that proper GHS labeling is in place to prevent misuse.
• Standard Operating Procedures (SOPs): These are step-by-step instructions on how to safely handle, store, and dispose of chemicals. SOPs help standardize safety practices, reducing the chance of accidents.  These are often extended to other hazards in the science department such as biologicals and physical concerns and protocols and procedures to minimize risks.
• Exposure Controls and Equipment: The CHP should define the use of appropriate personal protective equipment (PPE), such as non-latex (nitrile) gloves, certified indirectly vented ANSI/ISEA Z87.1 D3 2020 safety goggles, and lab coats/aprons, and outline specific engineering controls including fume hoods to minimize possible exposure to hazardous substances.
• Emergency Procedures: In case of a chemical spill, exposure, fire or other emergencies, the CHP should include specific procedures for evacuation, containment, and first aid measures. Quick, decisive actions based on clear protocols can prevent minor incidents from becoming serious accidents or injuries.
• Employee Training and Education: Ongoing and appropriate safety training is one of the most critical aspects of a successful CHP. Teachers, lab technicians, and students need to be familiar with the potential risks in the lab and how to mitigate them. This training must be refreshed at least annually to keep everyone updated on best practices.  Safety training is required for science educators upon initial hire, on new assignment (grade level or subject area change) and at least annually.  These are not recommendations but legal safety standards under the OSHA 1910.1450 Laboratory Standard regulations.
• Medical Consultation and Examination: As per OSHA 1910.1450, employees exposed to hazardous chemicals must have access to medical consultations and follow-up examinations when necessary. The CHP should outline when and how this will be provided.

3. Why is a CHP Crucial for School Districts?

School labs, particularly in middle and high schools, often store a wide range of chemicals that pose varying degrees of risk. Without a CHP, your school could be exposed to legal, financial, and safety risks. Here’s why the CHP is critical:

• Legal Compliance: OSHA mandates that educational institutions using hazardous chemicals must comply with safety standards, particularly OSHA 1910.1450. Failure to have a CHP can lead to serious consequences, including hefty fines and legal action if an incident occurs.  This is used to reduce potential liability and to provide an accurate representation of accepted safety practices in your school science departments.
• Preventing Accidents: Safety incidents in science labs can result in significant harm to students and staff. A well-maintained CHP is your first line of defense in preventing accidents. It ensures that everyone in the lab follows strict safety protocols, significantly reducing the chances of mishaps and potentially serious accidents or injuries to faculty or students.
• Creating a Culture of Safety: A CHP fosters a culture where safety is a priority. Students who see their teachers consistently following safety practices are more likely to adopt these practices themselves, building lifelong habits of safer laboratory conduct. NSTA promotes this safety culture as part of creating responsible future scientists and innovators in our communities.

4. Best Practices for Implementing a CHP

For science teachers, the successful implementation of a CHP in your school requires leadership and collaboration with administration, lab staff, and students. Here are some accepted better professional safety:

• Collaborate with Your School’s Chemical Hygiene Officer (CHO): Every school should designate a Chemical Hygiene Officer who oversees chemical safety. Science teachers should work closely with this officer to stay informed about updates to the CHP and to ensure compliance in the lab.   FYI – if your district doesn’t have a Chemical Hygiene Officer, that role automatically falls to the Superintendent regardless of their understanding, experience or familiarity with responsible chemical management and hygiene practices.
• Regularly Update the Chemical Inventory: Chemicals degrade over time, and new ones may be added as curricula evolve. Regularly auditing and updating the inventory ensures that the CHP reflects the actual risks present in the lab and under NFPA regulations this must occur at least annually.  Keep an accurate record of the chemicals on-site in the science department in case of emergency such as fire, flood or vandalism.
• Conduct Annual Safety Audits: An annual review of the lab’s safety practices, equipment, and procedures helps to ensure that the CHP remains relevant. These audits should include inspections of fume hoods, eyewash stations, and safety showers as well as PPE, clutter, obstructions and other areas of concern.
• Engage Students in Safety Protocols: Students must be aware of the CHP’s guidelines and adhere to them. Begin each semester with a thorough review of lab safety procedures, and make safety a regular part of class routines.  Having science teachers complete an annual acknowledgement of their review of the CHP is important to demonstrate that they have access to and understand the information in the chemical hygiene plan.

5. Supporting CHP development and implementations

Safer STEM recognizes the importance of chemical hygiene plans and offers resources and guidance to help science educators maintain safer learning environments as well as our Chemical Hygiene Officer safety awareness training programs. Through its advocacy, Safer STEM encourages school districts to adopt comprehensive CHPs and provides ongoing support through professional development, publications, and accepted better professional safety practices in science education.

Conclusion

A Chemical Hygiene Plan is not just a regulatory requirement but a vital tool for ensuring the safety of everyone in your school’s science program. By actively participating in the development, maintenance, and implementation of the CHP, science teachers play a key role in protecting themselves, their students, and their schools from chemical hazards. In doing so, you also set a powerful example for your students about the importance of safety in science, both in the classroom and beyond. 

For more information on how to create or update a CHP, you can consult resources from OSHA (OSHA 1910.1450) and NSTA’s safety recommendations. Together, we can build safer, more responsible science labs for future generations.

A safer tomorrow begins today.

James Palcik, NRCC Chemical Hygiene Officer #5092