Define the activities your program will perform;

Storage

Location tration Date: Container (est.) Location Name Number Date: Container (est.)

Disposal

Flammable Cabinet, 1-Propanol 71-2 3-8 100% 2x500 ml poly 750 Room 202 poly; Flammable Cabinet, Acetone 67-64-1 none 2x4 L metal 4.5 Room 202 Chemical Storage Shelves, Aluminon 569-58-4 none 25 grams glass 20 Room 110 plastic Flammable Cabinet, Aluminum 7429-90-5 100% none 2 oz cup 5 Room 202 Chemical Storage Shelves, Aluminum 7429-90-5 100% none 2 x 500 ml glass jar 850 Room 110 Flammable Cabinet, Aluminum Sulfate 10043-01-3 100% none 1x 5 lb glass 3.25 Room 202 4-28 Chapter 4 – Put Your SC3 Program Into Action SUB-ACTIVITY B - IDENTIFY A QUALIFIED PROFESSIONAL(S) TO ASSIST IN THE CLEANOUT AND D ISPOSAL PROCESS It is important to have a qualified and experienced professional to handle the chemical cleanout process, in cluding packing, removing, transporting, and disposing of the chemicals. You may have this expertise in y our school district; however, it is likely you may need to call on partners or outside professionals. In the Introduction to this Workbook, we identified a variety of potential partners who may contribute to the success of your SC3 program. For example, organizations, such as chemical manufacturers and engineering firms, fire and police, and colleges and universities are good sources for advice or labor in the performance of chemical cleanouts and disposal. These potential partners can help to: Identify additional chemicals to add to your disposal list; Identify chemicals that can be safely disposed of without a chemical cleanout professional5; Prepare chemicals for disposal; Develop requests for proposal for cleanout service providers; Coordinate your cleanout and disposal with other community hazardous waste events, if possible, to reduce the cost of disposal; or Dispose of unwanted chemicals. For each partner that may assist with chemical cleanout and disposal, it is important to define roles and responsibilities. Remember that only qualified personnel should be involved with chemical handling, packing, removal, and transport to bring about a safe and successful cleanout. Disposal of chemicals and chemical waste must be done in compliance with local and state regulations, as well as with the federal Resource Conservation and Recovery Act. A qualified professional will be aware of the proper cleanout and disposal techniques and applicable regulatory requirements. In addition, using qualified personnel will help to minimize chemical exposure to students and staff, environmental damage, and the likelihood of accidents and their associated costs. One way to evaluate and competitively select a qualified hazardous waste disposal contractor is to issue a request for proposal (RFP). I don’t know much about cleanout and disposal professionals. How do I find one? Check your state environmental agency Web site for company listings and information. While most agencies cannot recommend a specific company, they may be able to provide you with contact information for a number of service providers. Check with your school’s business manager(s) for companies that may have provided similar services in the past. Perhaps a college or university or an industry partner in your area can perform the cleanout and disposal or has a contract you can tap into. 5 If you are unable to involve a qualified professional to do this, it may be safer to wait until you have secured a contractor who can safely determine which chemicals, if any, can be disposed of without a contractor’s professional removal. 4-29 Chapter 4 – Put Your SC3 Program Into Action What is a Request for Proposal? A Request for Proposal (RFP) is an invitation for service providers to bid on a contract to provide a service or product to a customer. In an RFP, you spell out the services and qualifications you s eek in a p rofessional and describe your needs in sufficient detail so that vendors can bid a realistic, competitive price. In response to an RFP, qualified professionals submit a prop osal describing how they plan to meet your r equ rements. For a sample RFP, see Exhibit 4-11 in the Additional Tools and Examples section a i t the en d o this chapter. f We ha ve rovided examples of common components of an RFP for chemical cleanout and disposal p services. E very situation is unique, so tailor your RFP to your specific needs and your state and local requir ements! You should consult with your school or district’s legal counsel to be sure you have included a ll legal requirements for a contract. Exhibit 4-11 in the Additional Tools and Examples section at the end of this chapter is an actual RFP that w as used by a regional education unit to solicit bidders to assist with school chemical cleanout and disposal. In developing an RFP, it is important to define “evaluation selection criteria” that reflect your particular program needs so that bidders can write responsive proposals. Tip: Common Components of an RFP Statement of work or “SOW” (i.e., the services you want a vendor to provide); o Chemical inventory services ( see Project 1 in this chapter for more information) o Packing o Transport o Treatment and Disposal o Reconciliation of items removed/disposed or provide waste manifests Evaluation selection criteria; Period of performance (i.e., the timeframe over which you require the SOW services to be performed); Specifications of what you consider to be a qualified service provider (e.g., can the contractor provide a sufficient, competent, and trained staff to receive, handle, weigh, package, store, and transport chemicals?); Insurance requirements; Items to include in cost estimate (Refer to the Question titled “How do I estimate cleanout and disposal costs?” in this chapter for tips on what is typically included in a cost estimate); and Your organization’s standard legal or regulatory language. 4-30 Chapter 4 – Put Your SC3 Program Into Action How do I advertise an RFP? T here are a variety of ways to communicate the opportunity for qualified vendors to bid on your RFP. T ypically, organizations advertise on their Web sites, in trade publications, on e-mail distribution lists, or in local newspapers. Your organization may have a special process for RFPs. You should ask your manager or supervisor for specific guidance on Advertising your RFP in a local newspaper is how and where to advertise RFPs. Consider easy. With a simple transmittal letter, you are on your way! For example: other venues that may appeal to chemical cleanout service provide rs, such as trade Hometown Newspaper p ublications. Also consider asking partners to Attention: Legal Advertising help with advertising and distributing your RFP. To Whom It May Concern: Please run the enclosed “Request for Proposals” in your paper on January 6, 9, and 17, 2009. Billing for these ads along with a tear sheet should be forward ed Keep timing in mind when issuing to my attention at the address above. an RFP. Consider timeframes for budgeting, advertising, collecting Please confirm that you have received this request, by vendor responses, and your SC3 contacting me at (123) 456-7890 or program’s goals. myemail@myorganization.com. Thank you in advance for your prompt action and cooperation in executing this request. How do I select a qualified professional? You may have multiple entities that respond to your RFP. So, how do you compare them and find the one that is right for you? You want the vendor to be both qualified and propose an approach that meets your needs. Also check to see if the RFP includes minimum vendor qualifications. Exhibit 4-12 provides a sample checklist to document prospective vendor qualifications. In addition to ensuring that a vendor is qualified, you can evaluate a vendor by how well it tailors an approach to meet your needs. In reading a vendor’s proposal, “score” them by the quality and completeness of their approach to performing all of the services in your SOW. For example, a vendor that proposes an approach guaranteeing that all work will be done after school and on weekends may be a better choice because of minimal potential disruptions to school operations. Also remember that while your evaluation and selection of the most qualified vendor is an ideal approach, your school or district may have a selection policy (e.g., lowest qualifying bid) that affects your decision. 4-31 Chapter 4 – Put Your SC3 Program Into Action Exhibit 4-12: Vendor Qualifications Checklist Vendor Name: Ensure that your vendor meets all applicable Federal, State and Local requirements before selecting. T he Vendor: 1. Can pack the chemicals? 2. Can transport the chemicals? 3. Can treat and dispose of the chemicals? 4. Can reconcile the chemicals? 5. Has appropriate bonds, licenses, and insuran ce? 6 . Has chemical technicians that have proper training and certifications? 7 . Has truck drivers that have proper training and certifications? 8 . Can provide acceptable USDOT compliance history? 9 . Can provide acceptable USEPA compliance history? 1 0. Can provide acceptable OSHA compliance history? 11. Can provide acceptable TSDF compliance history? 12. Has all the appropriate permits for transportation? 13. Has all the appropriate permits for storage? 14. Has all the appropriate permits for treatment and disposal? Tip: Other questions to help compare potential cleanout professionals What are the qualifications and experience of your staff? Will you be using subcontractors for any of your services? Can your company provide copies of necessary permits? Have you had any citations or violations in the past 5 years? Can you provide references? What is your plan for responding to the SOW (i.e., what is their process or approach to performing the required services and achieving objectives ou tlined in the RFP)? 4-32 Chapter 4 – Put Your SC3 Program Into Action How do I estimate cleanout and disposal c osts? Yo r RFP should request pote u ntial qualified vendors to include a price quote or cost estimate. Thus, you should provide suffic ient details in the RFP to enable potential bidders to have a b asis for their price quotation (e.g., identify the number of schools to be cleaned out, the typ s and quantities of chemicals e e valua d in the inventory, etc.). The collection of bidders te wi ll “ define the market price,” but be mindful of price quotes at the low and high ends of the spectrum – attempt to understand the underly ing assumptions. Exhibit 4-13 is an example Typical cleanout and of a price quote that a qualified professional may send in re sponse to your RFP; it contains disposal costs range from some typical costs associated with chem al clean ut and isposal. ic o d $2,000-$5,000 per school. Exhibit 4-13: Sample Price Quote Re: Disposal of My High School’s Waste Our company is pleased to submit a detailed quotation for the management, transportation and disposal of the hazardous materials located at My High School. Given our understanding of the scope of work per the chemical inventory that was provided us, we present the following Price Estimation to complete this project. This estimate specifies the following services to be carried out and the requirements to be met: Materials will be classified and marked with a label giving the chemical name or composition, or the MSDS must be available. The cost for mar king each container is $XX.00 Materials will be segregated by compat ibility, hazard class and disposal requirements. The cost for segregation of materials is $XX.00. Lab packing materials into drums and/or DOT approved over packing containers. The cost of lab packing each drum is $XX.00. Lab packs will be labeled to meet state and federal regulations. Completion of appropriate documentation, manifests, and shipping documents. The cost for preparing these documents is $XX.00. Lab packs will be transported to our facility for storage/transfer/processing for final disposal. The cost for these services is $XX.00. Materials that are not included in this price quote include: radioactive materials, shock sensitive compounds, biological wastes, explosives, and pressurized cylinders and/or gases unless otherwise stated in the attached Price Estimation. This proposal is valid for 45 days from the issue date. 4-33 Chapter 4 – Put Your SC3 Program Into Action Are there ways to lower disposal costs? You may want to consider ways to potentially minimize the costs associated with the disposal o f the chemicals removed from your school. State and local organizations use a variety of approa ches that result in cost-effective solutions. Please keep in mind that not all of these examples may be applica ble to your situation. You should explore the legal or regulatory impacts of any technique before getting s tarted! Exhibit 4-14 provides examples of some real world cost saving techniques that you can con sider for your SC3 program. Exhibit 4-14: Examples of Cost Saving Techniques Technique Type of Cost Real World Example Savings L everaging a household Transportation and The Tennessee Department of Environment and h azardous waste (HHW) labor. Conservation used an existing contract to do HHW col lection event for chemical collection and facilitate simultaneous cleanouts of school d isposal. labs. U se a knowledgeable partner to Packing, labor, The Northwest Tri-County Intermediate Unit i n Pennsylvania h elp identify substance(s) that transportation, and leveraged the State environmental agency to review can b e safely disposed of without disposal. inventories and denote items that could be safely disposed . a hazar dous waste contractor. Work with a partner organization Disposal (lower rates) In Iowa, in the early stages of their chemical management to take ad vantage of an existing efforts, the Metropolitan Waste Authority partnered with EPA disposal con tract. Region 7 to use existing chemical management services. Incorporat e performance-based chemical A pilot program in Lansing, Michigan incorporated contr acting in your RFP. purchasing, future performance-based contracting clauses to encourage chemical cleanout professionals to find ways to minimize costs, while management. providing other chemical and resource lifecycle services. Negotiat e disposal rates by Lower disposal rates Qualified school personnel in the Fort Worth, Texas’ comb ing m in ultiple cleanouts. and reduce c ost for Independent School District collected smaller amounts of lab packing, labor, waste from all district schools prior to one large consolidate d and transportation. disposal to save on transportation costs and negotiate a lower disposal rate per drum of hazardous waste. 4-34 Chapter 4 – Put Your SC3 Program Into Action Exhibit 4-14: Examples of Cost Saving Techniques (cont’d) Identify agency assistance for No-cost removal of The Illinois Emergency Management Agency has launched removal of radioactive wastes. radioactive a program to help schools safely dispose of radioactive chemicals. materials. IEMA officials colle ct the mat erials and send them to a radioactive waste di posal facility. The Illinois s program is one of several around the country; othe r states include Connecticut, Colorado and Vermont.6 R esearch your chemical Reduced packing and Rochester City School District, New York environmenta l m anagement regulations to transportation costs. personnel talked to regulators about the amounts and typ es i dentify potential ways to lower of chemicals that could be legally and safely transported by c osts. the school district to a proper disposal facility. SUB-ACTIVITY C – PRE PARE FOR CHEMICAL CLEANOUT AND DISPOSAL After you identify a qualified cleanout professional or other qualified par tner and enter into an ap propriate agreement or contract, the chemical removal and disposal process can begin. Communication and coordination with the p erson per forming the cleano ut a nd disposal is important. You should obtain a copy of their recommended p lan of ac tion for the cleano ut an d disposal project and ensure you understand a nd agree with the steps and d etails. Such upfront discuss ion will minimize performance risks and bolster chances that the project will be completed safely, with minimal disruption, and within budget. For instance, you may want to sk the following a questio ns so that you know what to expect when the cleanout oc cur s: When during the school day/week will the cleanout occur? Is there anything our school can do to help you prepare for Due to financial or other constraints, you may the cleanout (e.g. , m ark chemicals slated or removal)? f not be able to remove all of the ide ntified What safety preca utions should we take? chemicals at one time from one or mo re schools. Any amount of potentially Wha t areas of the school will you need acc ess to? dangerous chemicals that can be removed What school staff needs to be present during the cleanout? from a school helps to pre vent accidents What should I ex pe ct on the day of the cle anout (i.e., what before they happen . are the ste ps of the cleanout process)? While you may not personally be involved in cleanout a ctivities, we suggest that someone knowledgeable about the conditions and locatio ns of chemicals in yo ur school be available to answer questions and facilitate communication to h elp guarantee cleanout su ccess. Learn more about the Illinois Emergency Management Agency’s Orphan Source Recovery Program--High 6 School Initiative: http://www.state.il.us/iema/publications/pdf/Radiation_In_Schools.pdf 4-35 Chapter 4 – Put Your SC3 Program Into Action SUB-ACTIVITY D – TAKE ADDITIONAL STEPS TO REDUCE THE NEED FOR FUTURE CHEMICAL CLEANOUTS Congratulations on completing the chemical cleanout of your school. We recommend that you take the appropriate steps to ensure that you don’t have to u nde rtake another cleanout again. It will be important to develop and adhere to respo nsi ble chemica l managem ent practices to minimize the chance of having to conduct future cleanouts. Chapter 5 of this Workbook provides some helpful guidance in this regard: You should keep your policies and procedures current by periodically evaluating your SC3 program (Activity 2: Establish and modify existing chemical management procedures ); and See the Textbox “Key to Sustained Success: M aintaining Chemical Inventories” on page 5-1. 4-36 Chapter 4 – Put Your SC3 Program Into Action PROJECT 3 – IMPLEMENT A GREEN CURRICULUM PUTTING TOGETHER A GREEN CURRICULUM What is a “green curriculum”? A “green curriculum” involves the use of more environmentally friendly, less hazardous chemicals in the smallest possible quantities. The purpose of a green curriculum is to reduce waste, minimize treatment after use, and conserve energy and resources. A green curriculum can be used in almost any discipline that involves chemicals, such as: Chemistry; Biology; Physics; Art; Photography; and Vocational courses (e.g., woodworking class, auto/machine shop, etc.). ‘Greening’ a course curriculum can result in: Fewer chemicals consumed throughout the school year; Less waste being produced; Fewer students exposed to chemicals; Lower risk of spills or accidents; and Lower costs associated with chemical purchases, storage, and disposal. Learn More about the Green Curriculum Concept The concept of a green curriculum borrows from the practices of “green” (or ‘sustainable’) and “microscale” (or ‘small-scale’) chemistry. The following links provide some helpful background information on how these concepts promote a greener curriculum: http://www.epa.gov/opptintr/greenchemistry/index.html http://www.uoregon.edu/~hutchlab/greenchem/whygreen.html http://www.microscale.org/about.asp http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/resources.htm#labs For more information on developing green curricula for specific classes, see Web site links provided on page 4-24. 4-37 Chapter 4 – Put Your SC3 Program Into Action In addition to educational settings, the principles of green curricula can also be applied to reducing c hemicals used in the operational aspects of your school (i.e., janitorial/sanitation). As discussed in Chapter 2 of this Workbook, “green cleaning” inv olves selecting environmentally friendly products when a ppropriate, using those products properly, and t aking other steps to reduce risks, while maintaining an a ppropriate level of cle nliness and disinfection. Visit EPA's Green Cleaning resource page a (http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/resources.htm#clean ) and refer to the Additional Tools and Examples section at the end of Chapter 5 for additional resources. How can I start a green curriculum in my school? As with any change your SC3 Team makes to improve chemical management in a school, a green curriculum needs to be embraced and implemented by those who are affected. In this case, we believe that the teachers and department chairs where green curriculum is being proposed should be engaged and supportive of the effort. Your team will need to gauge the level of interest among people who could help mak e it happen. Identify a teacher – preferably a department head – who knows the current curriculum and w ould ik l e to take on the task of assessing: What changes could be made to existing curricula to use smaller quantities and less hazardous chemicals; and The costs (or cost savings!) o f any changes to existing curricula. Success Stories: Going Small in Rhode Island After attending a teaching workshop, Mrs. Kathleen Beebe, a teacher and a Chemical Hygiene Officer in Rhode Island, found that ‘greening’ her school’s chemistry classes did not require major changes to the curriculum itself. Instead, her approach was to modify current experiments to use smaller quantities of chemicals. In addition to saving money and requiring less time to prepare chemicals for instructional labs, Mrs. Beebe’s school realized a number of other benefits to adopting a green curriculum, including: Students work in smaller groups and receive more hands-on experience; Errors are minimized since experiments are easy to run multiple times; Minimal set-up time allows students the opportunity to set up experiments themselves and increases time for discussion and interaction among students about what they are learning; and Experiments are safer for students to conduct since fewer chemicals are involved and disposal concerns are minimized. 4-38 Chapter 4 – Put Your SC3 Program Into Action In Exhibit 4-15, we describe some common motivations that a school may have to adopt a green curriculum. Have your SC3 Team refer to these motivations when discussing green curricula with teache rs and administrators. Exhibit 4-15: Motivations for Supporting a Green Curriculum Stakeholder Motivation What to Mention to Them • Smaller amounts of chemicals used means less to store, track, and clean up; • Smaller chemical amounts may mean more students can participate (groups of 2 instead Department Heads Time savings; potential to of 4); improve learning, risk • More experiments can be redone if mistakes and Teachers reduction should occur given their scaled down approach; and • Small amounts (droppers) of chemicals used in class may not pose as great a threat to health and safety as large amounts (bottles). • Storing, using, and disposing of smaller amounts of less hazardous chemicals can significantly reduce risks to students and Adm inistrators school staff; an d School Board Risk reduction; cost savings. • Having to pur chase and dispose of less Members chemicals saves money; and • Using and disposing of less hazardous chemicals and waste may help lower insurance and disposal costs. Some teachers who have adopted a green curriculum found that a good place to start is the microscale approach of using smaller quantities of chemicals in current classroom assignments. Work with department heads and teachers on how to make the microscale approach work for them. Other changes to a curriculum along the lines of substituting new ‘green’ chemicals and introducing new labs or assignments may require permission and/or approvals beyond the department, so we suggest that the appropriate administrators be involved in the decision-making process. You may find that your school revisits and revises curricula each year. Discuss opportunities for incorporating elements of a green curriculum with Look to partners who ok to partners who the appropriate people whenever a school revisits a particular course of study. may have experience with developing curricula, such as colleges and your state’s Department of Education. 4-39 Chapter 4 – Put Your SC3 Program Into Action How should we design our green curriculum? Bec ause they are most familiar w ith the conte nt and structure of the courses and the educational standards, teachers and department chairs are in the best position to determine how a curriculum can be made “greener.” Members of the SC3 Team who work i n a epartment where chemicals are being used d are ideal candidates to champion the development of a gr e e n curriculum. There are numerous ways to green the curriculum. Depend ing on the chemicals and processes involved, y ou may wish to start wi th one approach or a combin ation of approaches and build as your green curriculum matures. Choose approaches that are bes t s uited for a certain course or department, which ma y include: Reducing the quantity of chemicals used. A dap ing lesson plans to use smaller amounts of t chemicals is a great way to reduce the amount o h f c emicals needed in storage, the quantity of waste produced in the classroom, and the level of ch emical exposure students experience. See the text box entitled “An Effective Solution” below fo r additional information on using fewer chemicals in your school’s curricula. Using safer chemicals and practices. Consider s ubstituting your current chemicals w ith alternatives that are less hazardous and/or toxic. R esearching alternative ex pe riments, processes, and activi s for courses and operational tie activities that incorporate the techniques mentioned above is also a key part of both a greener curriculum and practicing mor Check ou t Illinois EPA’s e re ponsible chemical s listing of a lternatives for management. Some helpful resources to identify le ss hazardous, alternative devices c ontaining mercury: chemicals (and processes) to adopt are listed below : http://www.epa.s tate.il.us/p2 /green-schools/mercury- o Massachusetts Institute of Technology’s (MIT) Green Chemical free-alternatives-for- Alternatives Purchasing Wizard schools.pdf. http://web.mit.edu/environment/academic/purchasing.html o Illinois EPA and WMRC’s Greening Schools http://www.greeningschools.org/ Eliminating the use of specified chemicals. Consider phasing out or stopp ing immediately the use of chemicals that pose a risk to the health and safety of th e Use MSDSs to school. Some examples to check out are included below: compare less hazardous alternative o King County, Washington’s Rehab the Lab chemicals for potential http://www.govlink.org/hazwaste/publications/highrisktable.pdf substitution in a curriculum. o American Chemical Society http://membership.acs.org/c/ccs/pubs/NotInSecondarySchools.pdf 4-40 Chapter 4 – Put Your SC3 Program Into Action Remember to keep administrators involved in the process, as appropriate. Administrators can assist with budget questions, purchasing procedures, and getting your green curriculum approved, if necessary. To give you an idea of what others are doing to ‘green’ school curricula, we provide a variety of Web links below organized by classroom subject. An Effective Solution: Use Smaller Quantities of Chemicals Adopting a microscale approach at first may be less expensive and easier to implement than redesigning a curriculum by eliminating experiments using d angerous chemicals or modifying experiments by substituting alternative green chemicals. However, some microscale practices may require new, specific equipment and thus, additional upfront costs. Teachers in each department should collaborate to identify where to make changes in or der to reduce risks, save costs, and maintain or enhance the educational experience. GGrreeeenn CCuurrrriiccuulluumm RReessoouurrcceess ffoorr DDiiffffeerreenntt TTyyppeess ooff CCllaasssseess Chemistry: http://www.govlink.org/hazwaste/schoolyouth/rehab/labs.htm http://www.state.tn.us/environment/sc3/greenchemistry.shtml http://academic.scranton.edu/faculty/CANNM1/dreyfusmodules.html http://fusion.stolaf.edu/gca/ http://greenchem.uoregon.edu/gems.html http://www.deq.utah.gov/Schools/pollution_prevention.htm http://www.epa.gov/greenchemistry/pubs/educat.html Biology: http://w ww . greeningschools.org/resources/view_cat_teacher.cfm?id=2 http://www.govlink.org/hazwaste/publications/reh abbio.pdf h ttp://w ww . chem.harvard.edu/resources/gree n_labs/index.php Art: http://www.greeningschools.org/resources/view_cat_teacher.cfm?id=1 http://www.environmentaldefence.ca/toxicnation/artist/index.htm http://www.c2e2.org/arts_workshop_05/princeton_pdf.pdf http://www.uic.edu/sph/glakes/harts1/HARTS_library/substitutes.tx ht t p://ww w . watoxics.org/safer-products/choosing-safer-products-art-and-cra ft-s upplies h ttp ://w ww . deq.utah.gov/Schools/appendix1_resources_contacts.htm 4-41 Chapter 4 – Put Your SC3 Program Into Action ROLL OUT YOUR G EN CURRICULUM RE How do we incorporate green curricula into our classes? Curriculum changes can start small and evolve over time. A teacher may decide to introduce a few experiments or activities gradually in their class(es) as they have the time and resources. Depending on the changes made to the curriculum, it may be necessary to modify chemical purchasing practices, and/or purchase new equipment. One way to introduce a curriculum is by conducting a “pilot” to refine the techniques in one class before implementing the green curriculum in other classes. For example, a large school with multiple chemistry c lasses may want to roll out the new curriculum in a single class instead of changing practices in all classes a t the same time. In a small school with only one class targeted for a green curriculum, a pilot may consist of going forward with a subset of the planned lab changes instead of implementing the full curriculum for the class term. Pilot ing a green curriculum can help your department to: Adjust the quantities of chemicals being used; Test new equipment and chemicals; and G et feedback from students. Once you determine when As a new curriculum is implemented, remember to keep track of changes to show the a new curriculum will begin, benefits associated with ‘greening’ your teaching metho ds. For example, try to track the give a heads-up to the following : school’s purchasing agent. You don’t want to buy T he amount of chemicals used each class term; chemicals that you’ll be phasing out! The number of harmful or hazardous chemicals no longer used/purchased; The amount of waste generated; and The costs or cost savings for each class term. Using dif ferent chemicals and chemical quantities may require a shift in purch asing procedures. By working w ith your SC3 Team, teachers, administrators, and purchasers, you c an align chemical purchasing with green curriculum changes. Remember to factor in disposal costs when considering the purchase price of chemicals. The cost of disposal for unneeded chem icals is likely to be greater than the savings from buying in bulk. Tip: Look to Teachers Who Have Adopted a Green Curriculum There is a lot to be learned from those who have already tried someth ing new. The SC3 Team may be able to help by identifying teachers at other schools w ho are willing to share lesson plans and lessons learned in rolling out green curricula in their classrooms. You could also post an inquiry at an online discussion forum for teachers. 4-42 Chapter 4 – Put Your SC3 Program Into Action Summary As you went through this chapter, you worked through a list of six (6) activities and projects to help you successfully put your SC3 program into action. Here, in summary, is the list of them: Activity # Description P rogram gram Management Management 1. Begin to put your SC3 program into action; 2. Establish and modify existing chemical management procedures; and 3. Train appropriate groups on responsible chemical management. Project # Special Chemical Management Projects 1. Perform an inventory of all chemicals and chemical products; 2. Secure a chemical cleanout p rofessional; and 3. Implement a gree n curriculum. This fourth chapter helped you to carry out your SC3 program and undertake some vita l chemical management projects. The next section (Chapter 5) will assist you in continuing to evalua te and sustain your SC3 p rogram. Not e: We plan to add more activities and projects to this C hapter in the future. If you have questions about this chapter that you would like to discuss, refer to the SC3 Web site’s "Where you L ive" page for the app ropriate contact for your state that can help you. The SC3 Web site is an excellent source of additional info rma ion, as are the resources listed at the end of thi t s document. 4-43 Chapter 4 – Put Your SC3 Program Into Action Additional Tools and Examples This section of the chapter contains helpful links to conduct further research, a sample RFP, and exhibits and worksheets to help you work toward getting your SC3 program in place: Click on the “Resources ” section of EPA’s Schools Chemical Cleanout Campaign Web site and then go to “Developing a Chem ical Management Program ” for additional help on: Regulatory Requirements: o http://w ww.epa.gov/epaoswer/osw/conserve/clusters/schools/resources. htm#regs Chemical/Disposal Inventories: o http://www.epa.gov/epaoswer/osw/co nserve/clusters/schools/resources.htm#inventory Worksheet # 4-1 Identify Low Cost, Quick Fixes to Chemical Management Situations 4-2 Identify SC3 Priorities for the First Year 4-4 Measuring Behavioral Change 4-7 SC3 Training Topics by Targets Audience 4-9 Post-Inventory Evaluation of your Chemical Management Situation 4-10 Chemical Disposal List E xhibit # Title 4-11 Sample RFP 4-12 Vendor Qualifications 4-13 Sample Price Quote 4-14 Examples of Cost Saving Techniques 4-44 Chapter 4 – Put Your SC3 Program Into Action Worksheet 4-1: Identify Low Cost, Quick Fixes to Chemical Management Situations Issue/Area of Need Solution What is Needed 4-45 Chapter 4 – Put Your SC3 Program Into Action Worksheet 4-2: Identify SC3 Priorities for the First Year Activity Resources Needed Priority Makes Progress Toward which Goals 4-46 Chapter 4 – Put Your SC3 Program Into Action Worksheet 4-4: Measuring Behavioral Change Original Behavior Behavior After 3 Months of Desired Behavior Benefit/Improvement (before program) Implementation 4-47 Chapter 4 – Put Your SC3 Program Into Action Works heet 4-7: SC3 Training Topics by Target Audien ce Training Target Audience Topics Teachers Custodians Administrators Purchasers Students 4-48 Chapter 4 – Put Your SC3 Program Into Action Worksheet 4 -9: Post-Inventory Evaluation of your Chemical Managem ent Situation Question Status Action Taken How many chemical containers are: 1) Unlabeled? 1) 2) In poor condition? 2) 3) Expired? 3) 4) No longer used or essential? 4) 5) Unsecured? 5) How much of the following chemical do I use every year? Given the amounts above, how many years worth of chemical do I currently have? 4-49 Chapter 4 – Put Your SC3 Program Into Action Worksheet 4-10: Chemical Disposal List Chemical CAS Exp. A mt. & Si ze of Type of Amount Concentration Container for 4-50 Chapter 4 – Put Your SC3 Program Into Action Exhibit 4-11: Sample RFP All RFPs should go through your legal department and be ABC Regional Education Unit tailored to meet your 123 Main St. specific requirements . Anyw he re, PA 16412 Hazardous Chemicals Collection and Disposal 2005-2006 BID SPECIFICATIONS 1. Scope of Services The Contractor shall provide all of the following services wh e required for all gen er erating sites: ♦ Identification – The Contractor must be able to identify and dispose of all known and unknown hazardous waste chemicals. If an unknown chemical is not identified, it shall be considered as “hazardous” for the purposes of transportation and disposal. ♦ Packing – The Contractor m ust sort and packa ge all waste chemicals according to USDOT, USEPA, OSHA and PADEP regulations. ♦ Transportation – The Contractor will provide all proper transportation, labeling, manifests, and documentation according to all state, USDOT and USEPA regulations. ♦ Treatment and Disposal – The Contractor shall provide or arran e w g ith a subcontractor, as approved by the Intermediate Unit, for the proper treatment and disposal of all hazardous waste chemicals. The first options would be to recycle, refine, or recover the waste for reuse so that new raw materials are not required and so that waste pollutants never reach the land, the water, or the atmosphere, and resources are conserved. The second option would be to treat the waste to reduce its toxicity and its potential for harming the environment. The third option is disposal by landfill or incineration with proper disposal of the residual ash. No wastes should be directly landfilled except those without specific available treatment technology. The Contractor shall also submit a chain of custody form for each hazardous chemical, including a Certificate of Destruction, Disposal, or Recycling. The Contractor shall be required to provide compliance histories for the disposal facilities as well. The chain of custody form shall be sub tantially in the form attached to this s bid specifi ation. c ♦ Reconciliation – The Contractor must provide a manifest sheet for each hazardous waste removed from each site within 60 days of removal (PCB and Dioxin wastes may require additional time). The Contractor shall also provide accurate invoicing that is generator site specific. Invoicing shall include: o All materials used at each site. o All applicable labor and transportation fees. o Transportation and disposal fees. ♦ Compliance with Laws – The Contractor, in the performance of the obligations of this bid specification and award, agrees to comply with all applicable federal and Pennsylvania regulations, specifically including regulations of the Pennsylvania Department of Transportation and the Pennsylvania Department of Environmental Protection. 4-51 Chapter 4 – Put Your SC3 Program Into Action The Contractor will only pickup the chemicals that are listed on the enclo sed school inventory lists. No addi tional add -ins are to be collected and disposed of. If chemicals a re picked up and disposed of that are not on the lists the cost fo r those chemicals will be the res ponsibility of the Contractor. The Contractor will schedule all of the pickup at the participating schools in the most efficient s manner possible, so that extra transpo rtation costs are not incurred f rom backtracking. Pickups shall be scheduled with the principal that is provided on the school in ven tory lists. 2. Ven dor Qualifications Bids are designed to achieve the best price for a common co mmodity. However, due to the short and lon g term liability of the hazardous w aste generator, vendor q ualifications become a prerequisite. An y RFP for lab pack service s shall include several qualifying requirements. Failure to comply with any of the required qualifications for any time during the contract shall result in termination of the contract. Insurance A q ualified vendor must submit proof of the following insurance: ♦ Contractor’s Pollution Insurance –Contractor shall have coverage of at least $2,000,000 that provides coverage for the services contemplated in the bid specifications. ♦ General Liability Policy – Contractor shall have coverage of at least $1,000,000 occurance/$2,000,000 aggregate. Contractor shall have XCU. ♦ Contractor’s Liabilit y – Contractor shall have coverage of at least $2,000,000. ♦ Automobile Policy – Contractor shall have coverage of at least $1,000,00 0. MCS90 enclosed. ♦ Professional Errors and Omissions Liability – Covers errors the contractors may make – applicable to unknown identifications; Contractor shall have coverage of at least $1,000,000. ♦ Workmen’s Compensation Insurance – Covers all workers; Contractor must have coverage of at least $500,000 (federal minimum). ♦ Transporter Pollution Liability – Covers cost of spill cleanup during all modes of transportation; Contractor must have coverage of at least $5,000,000 (DOT requirement). ♦ Pollution Legal Liability Insurance – Covers immediate environmental damage to the disposal site; Disposal Facility must have coverage of at leas t $2,000,000. ♦ Environmental Impairment Liability – Covers long term environmental damage to the disposal site; Disposal Fa cility must have coverage of at least $5,000,000. ♦ Indemnification – Contactor shall provide indemnification to the Intermediate Unit and assume full responsibility and liability for all chemic als, including but not limited to spills, transportation, treatment and disposal, whether handled by the Contractor or its subcontractor. The ABC Regiona l Edu cation Unit shall be named as additional insured for all policies. 4-52 Chapter 4 – Put Your SC3 Program Into Action Training A qualified vendor shall have the following training: ♦ Chemical Technicians – All on site employees must have 40 Hour Health and Safety Training complying with 29 CFR 1910.120(e)(3)(i). This is an OSHA standard for lab pack work. Your organization may already have an RFP template you can use ♦ Truck Drivers – All drivers must have the to get started! This will ensure y ou appropriate training required in 29 CFR 177 and include references to all 383. These are DOT standards for Hazardous appropriate legal and/or regula tory Material Transporters. clauses. Compliance History All bidding vendors must submit a detailed history of all citations for the last 5 years, including: ♦ USDOT Compliance History – A track record of highway safety; ♦ USEPA Complianc e History – A record of environmental safety; ♦ OSHA Compliance History – A record of employee safety; and ♦ TSDF Compliance History – A record of inspections by state agenc ies and corrective action taken. Referen ce to citations for the purposes of this provision shall include information concern ing all notices of violation, civil penalties and assessments, criminal actions, and similar deta iled history. Permits All bids mus t include all applicable permits for transporta tion, storage, and treatment for all disposal facil ities including the final landfills. Subcontractors All subcontr actors used must be listed and fulfill all vendor qualification requirements. 4-53 Chapter 4 – Put Your SC3 Program Into Action Hazardous Chemicals Collection and Disposal 2005-2006 Price Breakout Colby Lake $ Colby Valley $ Copeland Central $ C arlisle $ E ast Middletown (2) $ Ellston County Vo-t ech School $ Ft. Langley $ General Marston $ Ginley $ See Exhibit 4-3 for more details on Hay Creek cleanout costs you may want $ qualified profes sionals to estimate. Mapleville $ McDouglas $ M erriweather $ N orth Cumberlan d $ Northea st Gains Academy (2) $ Newton $ Sage City $ Upland Marshal l $ V an Buren $ TOTAL PRICE: $ 4-54 Chapter 4 – Put Your SC3 Program Into Action CHAIN OF CUSTODY/MANIFEST FOR HAZARDOUS CHEMICAL DISPOSAL G enerator School District Name and Building Address: Description of the Hazardous Chemicals (Use ad ditional pag es as necessary): Name of Chemical No. of Type of Total Description Containers Container Quantity Generator School District Certification: I hereby declare that the contents of this consignment are fully and accurately described on the above by proper shipping name and are classified, packed, marked, and labeled, and are in all respects in proper conditions for transport by highway, rail or w ater according to applicable international and national government regulations. Printed/Typed Name Signature Date: Transporter Acknowledgment of Receipt: I hereby declare that all of the materials identified hereinabove, except such discrepancies as noted hereinafter, have been received by me for proper disposal in accordance with applicable international and national government regulations. I certify to the generator that the contents of this consignment will be transported to a permitted or licensed facility for destruction, or recycling as permitted by applicable law and regulations Printed/Typed Name Signature Date: Discrepancy Indications Space (if none, write “None”): Subcontracted Transporter Acknowledgment of Receipt: I hereby declare that all of the materials identified hereinabove, except such discrepancies as noted hereinafter, have been received by me, from the contracting party identified hereinafter, for proper disposal in accordance with applicable international and national government regulations. I certify to the generator and transporter that the contents of this consignment will be transported to a permitted or licensed facility for disposal, destruction, or recycling as permitted by applicable law and regulations. (Use additional pages, if necessary). Contracting Party Name and Address (Please identify the individual agent or employee of the Contracting Party): Printed/Typed Name Signature Date: Discrepancy Indications Space (if none, write “None”): Disposal/Recycling Facility Acknowledgment of Receipt: I hereby declare that all of the materials i dentified hereinabove, except such discrepancies as noted hereinafter, have been received by me for proper disposal and/or recycling in accordance with applicable international and national government regulations. I certify to the generator that the contents of this consignment will be disposed, destroyed, or recycled as permitted by applicable law and regulations, in accordance with this facility’s permit or license. Printed/Typed Name Signature Date: Discrepancy Indications Space (if none, write “None”): 4-55 Chapter 4 – Put Your SC3 Program Into Action COMPLIANCE REPORT FORM Compliance Background. (Note: Copies of specific documents, if applicable, must be made available to the Intermediate Unit upon its request.) List all documented conduct of violations or enforcement actions identified by the USDOT, USEPA, OSH A, PADOT, PADEP, pursuant to applicable law and regulations, terms and conditions of an operating permit or plan app roval or order by Cont ractor o r any rel ated part y, using th e follo wing for mat grou ped by source and location in reverse chronological order. Attach additio nal sheets as n ece ssary. See th e de finition of " documented conduct" for further clarification. Plan Approval/ Nature of Type of Status: Litigation Dollar Operating Documented Enforcement Existin g/Continuing or Amount D ate Location Perm it# C onduct Action Cor rected/D ate Penalty $ List all inciden ts of deviations of the USDOT, USEPA, OSHA, PADOT, PADEP regulati ons, terms and conditions of an operating permit or plan approval or order by Contractor or any related party, using the following format grouped by sour ce and location in reverse chronological order. This list must include items both currently known and unknown t o the Dep artment. Attach additional sheets as necessary. See the definition of "deviations" for further clarification. Incident Status: Litigation Plan Approval/ Existing/Continuing Or Date: Location Operating Permit# Nature of Deviation Corrected/Date CON TINUING OBLIGATION. Contractor is under a continuing obligation to update this form using the Compliance Rev iew Form if any additional deviations occur between the date of submission and the Intermediate Unit’s actio n on the Contractor’s b id. 4-56 Chapter 4 – Put Your SC3 Program Into Action Definitions: "R elated Parties" shall be the applicant and any general partner, parent, or subsidiary of the applicant or permittee for a plan approval or operating permit including a general plan approval and general operating permit. "Documented conduct" shall mean any activity that occurred at a source owned or operated in Pennsylvania by the Contractor, permittee or a related party within 5 years prior to the date of submission of the com pliance review form identified as a violation of the environmental laws, the regulations, a plan approval, permit or order issued by USDOT, USEPA, OSHA, PADOT, or PADEP. The term includes, but is not limited to, activities which are described in or the subject of the following: All Notices of Violation issued by the PADEP, USEPA, or OSHA or any other authorized enforcement or regulatory agency in Pennsylvania against the Contra ctor, permittee or related parties; All administrative orders, civil penalties, permit suspensions or revoca tions, and civil p enalty act ions iss ued by t he PAD EP, USEPA, or O SHA or any other authorized enforce ment or reg ulat ory agency in ennsylvania a ainst the Contractor, pe P g rm ittee or re lated pa rties; All c onsent decrees, conse nt orders and adj udicatio ns, cons ent order and ag reem ents, consent assessments, letter agreements, stipulations or other settlements between the PADEP, USEPA, OSHA, or any other authorized enforcement or regulatory agency in Pennsylvania aga inst Contra ctor, permittee or related parties; All Pennsylvania court proceedings, including proceeding before the s Environmental Hearing Board, involving Contractor or related parties; All summary, misdemeanor, or felony convictions, or pleas of guilty or pleas of no contest that have been entered in Pennsylvania against Contractor or related parties pursu ant to any environment laws or regulations; and Any al suspension, revocation or denial of reissua nce of an y operating p ermit issue d to the Contractor or related parties pursuant to the environmental laws or regulations. "Deviations" shall mean all a ctivities that o curred at a source ow ed or operated in Pennsylvania by the c n Contractor, permittee or related party within the 5 years prior to th e date of subm ission of the compliance review form that has not been formally documented by the PADEP, USEPA, OSHA or another authorized enforcement or regulatory agency in Pennsylvania which otherwise did not conform to the application law or regulations promulgated thereunder, plan approvals, permits or orders of the PADEP, USEPA, or OSHA. The identification of a deviation on a compliance review form does not constitute a waiver o f a defense to liability under the law for the activity disclosed. The term includes, but is not limited to, the following: All unauthorized, accidental releases or emergency releases of hazardous chemicals into the chemical A pilot program in Lansing, Michigan incorporated contr acti g in your RFP. n purchasing, future performance-based contracting clauses to encourage chemical cleanout professionals to find ways to minimize costs, while management. providing other chemical and resource lifecycle services. Negot t di ia e sposal rates by Lower disposal rates Qualified school personnel in the Fort Worth, Texas’ comb ining multiple cleanouts. and reduce cost for Independent School District collected smaller amounts of lab packing, la bor, waste from all district schools prior to one large consolidated and transportation. disposal to save on transportation costs and negotiate a lower disposal rate per drum of hazardous waste. Identify agency assistance for No-cost removal of The Illinois Emergency Management Agency has launched remo val of radioactive wastes. radioactive a program to help schools safely dispose of radioactive chemicals. materials. IEMA officials collect the materials and send them to a radioactive waste disposal facility. The Illinois program is one of several around the country; other states include Connecticut, Colorado and Vermont.7 Research your chemical Reduced packing and Rochester City School District, New York environmental management regulations to transportation costs. personnel talked to regulators about the amounts and types i dentify potential ways to lower of chemicals that could be legally and safely transported by costs. the school district to a proper disposal facility. Learn more about the Illinois Em ergency Management Agency’s Orphan Source Recovery Program--High 7 School Initiative: http://www.state.il.us/iema/publications/pdf/Radiation_In_Schools.pdf 4-60 CCChhhaaapppttteeerrr 555 --- SSSuuussstttaaaiiinnn YYYooouuurrr SSSCCC333 PPPrrrooogggrrraaam m m What can I do to sustain my program? Congratulations! Your SC3 program is off the ground and you are doing good things. Now the challenge is to sustain that success. An important part of maintaining a safe learning environment is to continue to follow responsible chemical management policies and procedures, and periodically evaluate program progress and make adjustments, as necessary. This chapter focuses on ways to keep your program current and ensure that those involved in chemical management continue to do the right things. The activities to sustain your SC3 program are: Activity Activity # # Description 1. Evaluate and measure your program’s progress, methods, and capabilities; 2. Keep chemical management policies and procedures up-to-date; 3. Conduct periodic training; 4. Communicate progress and success to keep enthusiasm and awareness high; 5. Maintain relationships with partners; and 6. Estimate staffing and funding requirements and continue to look for new funding sources for ongoing SC3 activities. Key to Sustained Success: Maintaining Chemical Inventories No school wants to find itself in a situation requiring a significant chemical cleanout. A key to preventing a potentially dangerous chemical situation in your school is to keep tabs on the chemicals your school buys, stores, uses, and disposes. One way to do this is to keep your school’s chemical inventory system up-to-date with information regarding: Location; Quantity; Condition; and Age of every chemical at your school. You should periodically check that all components of your inventory are up-to-date and that the people managing it are functioning efficiently and effectively. In addition to preventing a potential costly cleanout, a comprehensive chemical inventory can help your school make more cost-effective and healthy purchasing decisions, as well as indicate if school policies are being followed. Finally, you should check to see that the school is continuing to evaluate the need for the chemicals and alternate ways of doing business. 5-1 Chapter 5 – Sustain Your SC3 Program ACTIVITY 1 – EVALUATE AND MEASURE YOUR PROGRAM’S PROGRESS, METHODS, AND CAPABILITIES After initially putting your program into place, you should be prepared to evaluate the goals, strategies, and activities you originally developed for your program to determine if they need to be revised or expanded. You should evaluate all aspects of your SC3 program. This includes, but is not limited to: Evaluating how well you are doing according to your performance measures; Determining how effective your approach to designing a program has been; Analyzing how well your strategies have worked in undertaking each activity; Identifying any success factors; and Recognizing the obstacles you have faced. You can use the worksheets you created in Chapter 2 (Worksheet 2-1 SC3 Activities and Performance Measures to Reach Program Goals and Worksheet 2-2 SC3 Progress Report) and record progress made. If goals are on track or ahead of schedule, communicate this message of success to program participants to sustain the momentum of your program. Where you find that your actual results are behind your desired results, you should address the issues in more detail. To do this, Worksheet 2-4: Identifying Potential Obstacles and Solutions can be used to see if you and your team prescribed actions to prevent or remove obstacles. You should work with your team to evaluate how to deal with any existing obstacles and get progress back on track. It may be necessary to create a new plan to identify potential obstacles and solutions. Tip: Use Software to Track SC3 Activities Remember that EPA provides a valuable software tool that gives school districts the ability to evaluate and manage different aspects of their school safety and health issues, including chemical management. The Healthy School Environments Assessment Tool (HealthySEAT) is downloadable for use by school districts to perform analyses at the school and district levels and easily manage school specific conditions and progress. Visit the Healthy SEAT Web site at http://www.epa.gov/schools1/healthyseat/index.html In addition to evaluating the progress of your program, we recommend that you periodically review the goals you and your core team created. Evaluating the capabilities and objectives of your program is something that you should do on an annual basis, at a minimum. For existing program goals, some helpful resources to review and use are the following worksheets from Chapter 2: Worksheet 2-1: SC3 Activities and Performance Measures to Reach Program Goals; Worksheet 2-2: SC3 Progress Report; and Worksheet 2-4: Identifying Potential Obstacles and Solutions. As your team evaluates school conditions and as the SC3 program matures, your team may want to set new goals. For example, some programs initially focus on only one or two aspects of the chemical management lifecycle, such as Purchasing and Storage, but once they address these topics, they are ready to move on to new challenges. Revisit your original evaluation of the school’s chemical management situation (see Chapter 1 Worksheet 1-1: Evaluating Your School’s Chemical Management Situation, Policies, and Procedures) and determine how and where to expand your program’s capabilities to address issues identified at the time. If you are adding new goals, you can 5-2 Chapter 5 – Sustain Your SC3 Program use Worksheets 2-3 SC3 Staffing Plan and 2-5 SC3 Labor Cost Estimate to prepare budget requests, and assign new tasks to team members. Also remember that: New performance measures may be necessary to better track progress toward your goals; and Many aspects of your program will be subject to changes of one type or another. Your experiences should give you greater knowledge of and familiarity with the proper handling, use, and disposal of chemicals to make the school safer. This, in turn, should help you to shape and refine program goals to create a program that can sustain success over the long term. ACTIVITY 2 – KEEP CHEMICAL MANAGEMENT POLICIES AND PROCEDURES UP-TO-DATE To determine that chemicals in your school or district are being handled in the best possible way, we suggest that you and your team regularly evaluate your chemical management policies and procedures. Staying current with best practices and From your core SC3 Team, assign one or two people to methods should help avoid potential risks and cleanouts in the future. In addition, we take the lead on reviewing believe that someone on the team should keep current on state and federal and updating policies and regulations regarding the purchase, use, storage and disposal of the chemicals in your procedures for responsible inventory. school chemical management. How can I keep my chemical management policies and procedures up-to-date? The long-term success of your SC3 program depends on being able to keep responsible chemical management policies and procedures up-to-date. Chapter 1 of this Workbook provides a worksheet for evaluating school conditions and practices that may need to be addressed by an SC3 program (Worksheet 1-1: Evaluating Your School’s Chemical Management Situation, Policies, and Procedures). You may want to perform this Whenever you update SC3 self-evaluation activity at least once a year to improve your program and catch policies and procedures problems before they pose health and safety risks – make these SC3 self- ask: “who needs to know evaluations a part of the way you do business. about these updates?” Then let them know! Advances in school chemical management are likely to occur, so it’s a good idea to keep up-to-date on new approaches that you may want to incorporate in your school’s SC3 policies and procedures. Visit the SC3 Web site periodically for new tools and information, and consult your state's environmental agency to check if there are new or revised regulations. Also, use team members, partners, and other available resources with knowledge of chemical requirements to ensure that chemical procedures at your school or district are aligned with all appropriate regulations. 5-3 Chapter 5 – Sustain Your SC3 Program ACTIVITY 3 – CONDUCT PERIODIC TRAINING Chapter 4 provided guidance on how to develop a chemical management curriculum and train those involved in the use and disposal of chemicals. To sustain the progress your program has made in changing attitudes and behaviors regarding responsible chemical management, we believe it is important to periodically train new school personnel and students, and conduct refresher training for those who have already been trained. Your team will need to periodically update the curriculum developed as part of Program Management Activity #3 in Chapter 4 so that it is current and reflective of the most current best practices. The SC3 Team should conduct periodic refresher training that focuses on the most important principles and practices. Just like the initial training, you can conduct refresher training in formal or informal settings and you can tailor the training to meet the needs of your target audience(s). What should our training program look like over time? In launching your school’s SC3 program, your team likely developed instructional materials and conducted initial training for those involved in chemical management. You should periodically update the training program, as well as train new teachers, facilities personnel, and students to reflect new approaches and regulatory requirements. Even if they have already received training elsewhere, it will probably be a good idea for them to learn about the specific requirements in your district. For those who have already been trained, we suggest that you conduct “refresher” training on the most critical topics. Refresher training is most appropriate for teachers and facilities personnel who already went through the initial training when your school launched its SC3 program. You should provide practical information that staff can Informal training can be easily incorporate into their daily activities. A good way to develop ‘refresher’ very effective. Look for training material is to take a look at the initial training and focus on emphasizing opportunities to “piggyback” the most important topics. You may also want to address areas where you have onto existing training forums seen difficulties arise since the last training. Take into consideration any lessons or convey reminders when learned and feedback you may have received after holding the initial training staff and teachers are sessions. Most importantly, you should keep training information consistent and actually using, storing and disposing of chemicals. up-to-date to ensure that your target audiences are practicing responsible chemical management. 5-4 Chapter 5 – Sustain Your SC3 Program Key to Sustained Success: Ongoing Training Efforts The Science Safety Project Committee of the Maryland Science Supervisors Association has developed a Science Safety Manual. The committee manual guides schools in making instructional decisions that would support improved performance for all students. The Manual communicates clearly the best safety practices in the science classroom and laboratory and provides guidelines for School Science safety, including guidelines for managing, handling, and disposing of hazardous chemicals. Read more at: http://www.mdk12.org/instruction/curriculum/science/safety The Kentucky Department of Education, in cooperation with the Center for School Safety, the State Fire Marshall, the Department of Health, Kentucky Occupational Safety and Health Program, the Kentucky Science Teachers Association, and a private laboratory safety consultant, created a CDROM- based tool. The CD promotes best practices, current information, and readily accessible resources and recommendations related to safety issues in the science classroom and laboratory. The CD also includes both professional and regulatory standards specifically for Kentucky teachers and students and provides practical resources for creating and maintaining a science safety plan, including a chemical management component. As discussed in Chapter 4, students can have a role in responsible school chemical management too. Educating students generally centers on three areas: safety, chemical lifecycle management, and pollution prevention. Student chemical safety training primarily involves setting ground rules at the beginning of a course regarding the proper handling of chemicals. Common topics include: Raising awareness of hygiene, handling, and emergency procedures; Learning to properly use Personal Protective Equipment (PPE); Recognizing common safety symbols; Understanding materials safety data sheets; and Responding to a chemical accident. It is also important to involve students in the concepts of overall chemical life cycle management and pollution prevention. Some examples of topics to discuss with students are: The benefits of purchasing and using less hazardous and/or toxic chemicals; Safe storage practices; Designing experiments in a way that use smaller quantities of chemicals; and Proper disposal procedures. On those days in which chemicals are in use, teachers can give helpful reminders when describing the daily lesson. This kind of informal training is cost-effective and easily incorporated into school operations. Your team should refer back to the specific training content identified for target audiences (See Exhibit 4-7) to get an idea of what topics to include in refresher courses. 5-5 Chapter 5 – Sustain Your SC3 Program ACTIVITY 4 – COMMUNICATE PROGRESS AND SUCCESS TO KEEP ENTHUSIASM AND AWARENESS HIGH Communicating SC3 accomplishments is a great way to bolster commitment to responsible chemical management. If you have a good story to tell, you should convey it in public forums, school staff/management meetings, and widely circulated newsletters. Is communicating program progress important to sustaining success? Absolutely. Initial SC3 communications efforts aim at getting people involved. Once a school’s SC3 program is up and running, the challenge is keeping people involved and maintaining good habits regarding responsible school chemical management. A successful program is important to sustaining management support. It might be beneficial to retain detailed information regarding your program, in case a change Consider maintaining a “days in management or budgeting occurs. Some examples of information to keep as without a chemical problem” sign records might be: in the teachers’ lounge. Most industrial plants prominently Yearly progress reports; display similar signs as a daily reminder and to instill pride in Performance measures; making the work environment Expenditures and other budgetary data; and safe. Inventories of equipment and supplies. Having documentation of how your program functions and what it has accomplished is good for instances where you should “sell” the effectiveness and benefits of your program. Maintaining contact with local media outlets and community members should also give you an opportunity to announce any changes or successes in your school or district. In addition, we recommend that you continue to cultivate good relationships with current partners to keep them committed to providing expertise and assistance. Furthermore, if you find that your program’s needs aren’t being met or you’ve expanded your program’s capabilities and developed new needs, it may be necessary to find and involve new An effective way to partners to provide support (e.g., a local university may be helpful to your school’s efforts sustain senior to develop a new chemistry curriculum). You should refer back to Chapter 2 for management backing is guidance on approaching potential partners and acquiring their support. to give them a chance to speak with the media during publicity events. 5-6 Chapter 5 – Sustain Your SC3 Program ACTIVITY 5 – MAINTAIN RELATIONSHIPS WITH PARTNERS Open communication and frequent recognition are key for encouraging partners to continue assisting your school’s SC3 program. Keeping partners aware of, and new partners involved in, your school’s plans will help them understand the next steps in improving your program and how they can provide expertise and resources to ensure progress is made in keeping your program up-to-date. How do I maintain an effective ongoing relationship with my partner? As we’ve mentioned before, it is possible that your school will not have all the expertise or the time to undertake the different aspects of chemical management. Therefore, it is likely that partnerships will be important to sustaining your SC3 program year after year. In Chapter 2 Activity 7: Enter into Partnerships (page 2-15), we briefly outline some of the factors your SC3 Team should consider to keep your partner relationships healthy. Consider the following recommendations to help maintain an effective working relationship with your partner(s): Keep open lines of communication. Staying in contact with your partner is very important as the program progresses. Agree on how often you should meet or have phone calls. It is especially important to communicate with partners well in advance concerning upcoming events with which they should be involved. Be sure to keep partners updated about any changes that may affect your school’s SC3 program, including priorities, budgets, or roadblocks, as a partner may be able to fill a need when it arises. Re-evaluate the partnership and make adjustments. Even if you have not entered into an official partnership agreement, the SC3 Team should plan on periodically meeting with partners to revisit commitments and accomplishments, as well as to share upcoming plans, and to gauge a partner’s continued interest in helping the school. Work with partners to identify additional help. Current partners can be very helpful in reaching out to other potential partners. Talk with your partners about contacts they may have with other organizations that can help your school. Discuss national partnership opportunities. You may find that a partner wants to make a greater commitment to helping SC3 programs. Be sure to inform them of the opportunity to become a national partner with EPA. 5-7 Chapter 5 – Sustain Your SC3 Program Remember, you can look to partners and vendors to provide the following kinds of assistance: Performing a periodic evaluation of your school’s chemical inventory and storage areas (see Chapter 1); Performing, if necessary, chemical cleanout and disposal services (see Chapter 4); Providing information about advances in microscale or green curricula (see Chapter 4); Providing information about new developments in responsible chemical management; and Conducting training and refresher workshops. Key to Sustained Success: Ongoing Partner Assistance The Jefferson County Local Emergency Planning Committee (JCLEPC) provided assistance to Colorado public schools by developing policy guidelines for procuring environmentally preferable chemicals to help curb the use of toxic chemicals in chemistry lab exercises. JCLEPC will also develop training and policy guidelines that can be adopted statewide. The Illinois Environmental Protection Agency’s (IEPA) Office of Pollution Prevention delivers a workshop modeled for science teachers. By sending a teacher to the workshop, the participating school can receive a free pickup of hazardous school waste through the IEPA. The workshops themselves offer information on several issues, including: Methods of teaching with non-toxic and less hazardous materials in science classes; Safe storage practices for hazardous materials; and Procedures for disposing of hazardous materials. 5-8 Chapter 5 – Sustain Your SC3 Program ACTIVITY 6 – ESTIMATE STAFFING AND FUNDING REQUIREMENTS AND CONTINUE TO LOOK FOR NEW FUNDING SOURCES FOR ONGOING SC3 ACTIVITIES To ensure that the different aspects of your program have the support they need, we suggest that you and your team determine the funding and labor costs necessary to maintain your SC3 program on a yearly basis. What kind of funding do I need to maintain my SC3 program? By this time, you have put a well thought out program in place that addresses responsible chemical management. Through this process, you have planned and budgeted SC3 program activities to most effectively and efficiently achieve your goals. By doing this, you have taken proactive steps to minimize the cost of maintaining your program. The purpose of an SC3 program is to make responsible chemical management a part of day-to-day operations in your school. Ideally, there should be a level cost to operate and maintain your SC3 program. Each year, the SC3 program manager should estimate the hours and budget required to do the following: Re-evaluate and update chemical management policies and procedures; Further develop and evaluate the effectiveness of training curricula; Update and evaluate the functioning of the inventory system; and Properly dispose chemicals that are no longer needed. Your school’s budget may not cover all the costs of maintaining responsible chemical management. We have provided examples of methods for potentially procuring funds to sustain your SC3 program: The Local Hazardous Waste Program in King County’s Rehab the Lab program in King County, Washington, offered assistance, free of charge, to King County schools to manage their hazardous chemicals. The cost was $560,000 over a four-year period and was primarily funded by surplus sewer and garbage collection fees. In addition, the state provided matching grants to cover the cost of the initial site audit, collection and disposal costs, and teacher training. Kansas Department of Health and Environment (KDHE) launched Kansas’s Lab Chemical Sweep to offer a free, one-time collection of obsolete or unwanted potentially hazardous chemicals. Funding for the program originated from the $1.00 per ton solid waste tipping fee paid to the state for all waste disposed of at landfills. Remember to keep in mind the costs of any new or expanded SC3 program activities. If you only developed a few components of your program at a time, costs for adding components and improving your program should be considered. 5-9 Chapter 5 – Sustain Your SC3 Program Summary The activities to sustain your functioning SC3 program are: Activity # Description 1. Evaluate and measure your program’s progress, methods, and capabilities; 2. Keep chemical management policies and procedures up-to-date; 3. Conduct periodic training; 4. Communicate progress and success to keep enthusiasm and awareness high; 5. Maintain relationships with partners; and 6. Estimate staffing and funding requirements and continue to look for new funding sources for ongoing SC3 activities. 5-10 Chapter 5 – Sustain Your SC3 Program Additional Tools and Examples Here are some links from the SC3 Resources Web site, where you can find other valuable information and tools: http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/resources.htm General School Resources SC3 Tool Kit Evaluation of Results from EPA's Schools Chemical Cleanout Campaign Protecting Health and the Environment at K-12 Schools, Including Art Programs o Environmental Compliance and Best Management Practices: Guidance Manual for K-12 Schools o Environmental Health & Safety in the Arts: A Guide for K-12 Schools, Colleges and Artisans Healthy School Environment Resources Healthy School Environments Assessment Tool (HealthySEAT) National Institute of Health (NIH) Mad as a Hatter Mercury Abatement Campaign Children's Health Protection Healthy Schools for Healthy Learning Health and Safety Guide for K-12 Schools in Washington Tribal Schools Compliance Assistance Notebook EPA's Schools and Mercury Web site EPA Schools Web Portal Developing a Chemical Management Program General Chemical Management Program Resources: CPSC and NIOSH School Chemistry Laboratory Safety Guide Chemical Management Resource Guide for School Administrators Idaho's Department of Environmental Quality's Waste Management Educational Tools: Chemical Roundup Pollution Prevention Measures for Safer School Laboratories The Los Angeles Unified School District (LAUSD) Office of Environmental Health and Safety (OEHS) Lansing Michigan School District Case Study 5-11 Chapter 5 – Sustain Your SC3 Program Rehab the Lab Colorado Department of Public Health and Environment: Guidance on Chemical Management in Schools Chemical Inventory: Montana DEQ School Labs: Evaluating School Lab Chemicals Florida SC3 The State of Tennessee's SC3 Inventory Procedures Web site Material Safety Data Sheets (MSDS): The NIOSH Pocket Guide to Chemical Hazards Where to Find MSDS on the Internet Regulatory Requirements: A List of State Environmental Departments Occupational Exposure to Hazardous Chemicals in Laboratories EPA's Hazardous Waste Generators Lab Waste at Educational Institutions Environmental Management Guide for Small Laboratories Chemical Use and Management Green Cleaning: EPA's Environmentally Preferable Purchasing (EPP) Green Janitorial Products and Services Green Cleaning Pollution Prevention Calculator Guide to Green Cleaning: Healthier Cleaning & Maintenance Practices and Products for Schools New American Dream Clean Schools Household Products Database Western Regional Pollution Prevention Network: Janitorial Products Pollution Prevention Project INFORM's Cleaning For Health: Products and Practices for a Safer Indoor Environment Association for Professionals in Infection Control and Epidemiology (APIC) Guideline for Selection and Use of Disinfectants Integrated Pest Management: Integrated Pest Management in Schools 5-12 Chapter 5 – Sustain Your SC3 Program National School IPM Information Source Greening Labs and Lesson Plans: Green Chemical Alternatives Purchasing Wizard Green Chemistry Experiments for High Schools Green Your Lesson Plans Least Toxic Chemistry Labs: King County, Washington Green Chemistry Institute: American Chemistry Society National Microscale Chemistry Center Science Safety Information Guides School Nurses: Children's Health: Safe Workplaces and Healthy Working Places, Environmentally Healthy Schools EnviRN The National Association of School Nurses Position Statement on Environmental Impact Concerns in the School Setting Communication Brochures: Chemicals in Schools: Partner for Healthy School Environments Chemicals in Schools: Solutions for Healthy School Environments Public Service Announcements: Is Chemical Safety Part of the Equation? You Work Hard to Keep Your Students Safe from Bullies and Drugs. But What About Chemicals? Presentations: Chemical Safe Schools in Rhode Island (PDF) o PowerPoint Version Improving Chemical Management in Maine Schools (PDF) o PowerPoint Version No More " Methyl Something": Improving Management of Curriculum Chemicals in Schools (PDF) o PowerPoint Version Planning for Environmental Health and Safety Issues in Schools (PDF) o PowerPoint Version 5-13 Chapter 5 – Sustain Your SC3 Program 5-14 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? Your organization can play an important role in addressing a critical health and safety issue facing many schools: chemical management. The United States Environmental Protection Agency has launched a national Schools Chemical Cleanout Campaign (SC3) to address this issue. Critical to the success of local SC3 programs in schools is the contribution of expertise and resources from organizations like yours. Chemicals are found throughout schools, and when handled responsibly, are useful and necessary educational tools. They allow students to conduct experiments in the lab, create works of art in the studio, and restore vehicles in the automotive shop. However, when chemicals are improperly managed, they can pose risks to students, staff, and the environment, as well as cause lost school days. Potential chemical hazards such as explosives, toxics, and cancer-causing agents can be found in science classes, vocational and trade shops and visual arts studios. Chemicals like formaldehyde, cadmium, and mercury may be present in classrooms or maintenance areas, cafeterias, nurses’ offices, school grounds, and athletic fields. Because you are reading this, your organization most likely has an interest in becoming involved in helping schools responsibly manage their chemicals. By assisting schools with their chemicals, your organization can help prevent fires and spills, protect the environment, avoid lost school days, and most importantly, protect the health and safety of children and school personnel in your community. By partnering with a school, EPA, or state agency, your organization can make a difference in the lives of many. WHAT ARE THE BENEFITS OF BEING A PARTNER IN SCHOOL CHEMICAL MANAGEMENT? Becoming an SC3 Partner is a win-win proposition for you and the schools you assist. Your organization can benefit from becoming involved in school chemical management in the following ways: Benefits to a Partner Organization Organizational pride and satisfaction from improving school health and safety; Enhanced image as a leader in the community; Recognition that comes with being part of a federal campaign that has the backing of EPA and other agencies; Heightened organizational visibility via recognition on high-traffic Web sites, in the media, and at recognition events; and Eligibility for credit for EPA’s Performance Track program (if applicable). More details on the benefits of becoming an SC3 Partner follow. First, let’s examine the value your organization can bring in the growing campaign to improve school chemical management. A-1 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HOW CAN YOUR ORGANIZATION IMPROVE CHEMICAL MANAGEMENT IN SCHOOLS? Many schools or districts do not have the necessary experience and resources to develop and sustain a responsible chemical management program. That’s where organizations like your’s can step up and help make a difference in schools. Your organization can be part of a team made up of schools, school districts, other SC3 Partners, states, EPA and others, all representing a wide variety of expertise and sharing an interest in safe schools. Partners, each with discreet responsibilities, are vital to successfully designing, initiating, and maintaining a comprehensive and responsible chemical management program. The graphic below illustrates the key elements of a successful SC3 program -- these are areas and issues a school or district may require your organization’s expertise and experience to address. Please note the components and functions represented here are in no particular order. While some of these themes may be related, the connections portrayed are random and do not imply any dependency. Examples of activities that current SC3 Partners are performing or participating in include: Conducting cleanouts of outdated, unknown, or unneeded chemicals; Performing chemical inventories; Developing a chemical management plan; Providing technical expertise for unfamiliar processes (e.g., requests for proposals or writing contracts); Establishing a system to track the purchase, storage, and disposal of chemicals; Developing performance goals and measures to gauge chemical management success; Developing and conducting chemical management training; and Recruiting other organizations to become partners and help achieve program goals. A-2 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HOW CAN MY ORGANIZATION BENEFIT FROM PARTNERING WITH A SCHOOL? Your organization is an essential part of a community. By teaming up with a local school or school district and other organizations that care about children, you will be demonstrating your leadership and your concern for that community. There are a number of ways a school or school district may publicly recognize your organization’s efforts to make schools safer: Presenting an award to a partner at a public ceremony or school board meeting; Drafting a press release or contacting local media outlets to inform them of a partner’s efforts; Publicizing a partner’s assistance in a school newspaper or Web site; and Informing the U.S. EPA of a partner’s successful collaboration. Different schools will have different approaches to recognizing partners. Once you find a school to help, your organization can discuss more specifically how the school may publicly recognize your contributions. See Chapter 4, page 4-13 of this SC3 Workbook for an example of a press release a school might use to recognize your organization’s efforts. HOW CAN MY ORGANIZATION BENEFIT FROM PARTNERING WITH EPA? In addition to partnering locally with a school or district, EPA encourages you to consider signing an EPA SC3 Partnership Agreement1. This agreement can echo the terms of a partnership with an individual school, and also define the terms and conditions for participating in other SC3 projects. EPA helps partners find schools and offers guidance on how to work effectively with schools. The agency also offers a number of ways in which it can recognize a partner’s efforts: (1) SC3 INDIVIDUAL PARTNER PRESS EVENT Organizations can sign an SC3 Partnership Agreement (note: a blank agreement is provided at the end of the appendix). This agreement indicates that your organization is committed to promoting responsible chemical management in K-12 schools. EPA will recognize your commitment to promoting responsible chemical management in K-12 schools by presenting your organization with a plaque at a recognition event that will include the press and other media. From left to right: Deborah Edwards, Deputy Director, Office of Safe and Drug Free Schools, US (2) SC3 PARTNER RECOGNITION WEB SITE Department of Education; Jennifer Abril, Director, ChemStewards, SOCMA; Susan Bodine, Assistant Your organization will also be added to the Partners Page on the SC3 Administrator, OSWER, EPA. Web site as an official national partner. Once you have worked with the school or school district and have results to share, those results and successes will be posted on the EPA Web site so other schools, partners, and the public can learn about your achievements. (3) SC3 RECOGNITION EVENTS EPA routinely holds recognition events to recognize schools and partners. In 2007, when the national SC3 program was launched, EPA held two national press events to recognize SC3 Partners. EPA has plans to hold similar events in the coming years. 1 http://www.americanchemistry.com/s_rctoolkit/sec.asp?CID=1819&DID=6828 A-3 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? (4) SC3 PARTNER NETWORK As an SC3 Partner, your organization becomes part of a national network of companies, federal, state and local agencies, and national organizations. These organizations have committed to facilitating responsible chemical management in K-12 schools. Through this network, you have the opportunity to learn about and share best practices and solutions to overcoming barriers and issues in SC3 partnerships, programs, and projects. SC3 Partners will also have the opportunity to build valuable business relationships with other partners. Periodic SC3 Partner meetings that include other partners, EPA, and other agencies will give you a chance to provide input to EPA on the direction of the national SC3 program. (5) TRADE JOURNAL ARTICLES SC3 has placed articles about the program in trade association journals. EPA will work with your organization to incorporate your contributions into similar articles. From left to right: Elin Miller, Regional Administrator, Region 10; Kolin Anglin, President, NAHMMA; Deborah Edwards, Deputy Director, Office of Safe and Drug Free Schools, US Department of Education; Susan Bodine, Assistant Administrator, OSWER, EPA. PRESS RELEASES FOR EVENTS THAT INCLUDED PARTNERS: http://yosemite.epa.gov/opa/admpress.nsf/a7b2ee8e45551c138525735900404444/d42fad48425c6a80852573 7d005f72e0!OpenDocument http://yosemite.epa.gov/opa/admpress.nsf/eebfaebc1afd883d85257355005afd19/c8d3e8745b91ddd6852572a 700523fc3!OpenDocument A-4 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? Once you decide to enter a partnership, there are some key steps you need to take before getting started. Refer to the “How Do I Get Involved in a School Chemical Management Project” section of the appendix for more information on how to get started on helping out schools and districts in your area. Background on EPA’s Performance Track Program EPA’s Performance Track Program recognizes environmental excellence by encouraging facilities with strong environmental records to go above and beyond their legal requirements. The Performance Track program recognizes SC3 partnerships as credit for meeting the renewal requirements. To qualify for membership renewal, a facility (or organization) must meet all of the criteria required for entrance into the program. In addition, the facility must demonstrate good-faith improvement toward meeting its environmental performance goals. Check out the examples below for more information on how partnering with a school can benefit your organization. DESCRIPTION OF A SAMPLE ALTERNATE GOAL INVOLVING SC3 UNDER PERFORMANCE TRACK http://www.epa.gov/performancetrack/program/sample_altcomm.htm EXAMPLE OF ONE COMPANY USING SC3 AS A PERFORMANCE TRACK ALTERNATE GOAL https://yosemite.epa.gov/opei/ptrack.nsf/vRenewalViewPrintView/D5F924FC36CAB985852572F8005C924A A-5 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HHooow H ww DDooo D III GGeeettt G IIInnnvvvooolllvvveeeddd iiinnn aaa SSSccchhhoooooolll CCChhheeem mmiiicccaaalll MMaaannnaaagggeeem M mmeeennnttt PPPrrrooojjjeeecccttt??? Regardless of whether a school or school district has already launched an SC3 program or is simply interested in improving its chemical management situation, you can work with school officials to figure out how to best support their efforts. The first step is to get your management to determine the level of support that your organization is willing to provide. The next step is to identify a school or school district that could use your assistance, and determine the kinds of projects in which your organization can play a role. EPA can help you identify schools in your area, offer guidance on how to work with schools on SC3 projects, and recognize skills and resources within your organization that would be useful to a school’s chemical management program. WHAT WHAT ARE ARE SOME SOME THINGS THINGS TO TO THINK THINK ABOUT ABOUT WHEN WHEN APPROACHING APPROACHING MANAGEMENT? MANAGEMENT? Before approaching a school or school district, you will likely need to get management approval. Your management will need to decide whether school chemical management is an area in which it would like to volunteer staff time and expertise. If the answer is ‘yes,’ then you will want management to focus on the types and level of support your organization is willing to offer (e.g., time, money, resources); this will allow your organization to approach a school with a clear idea of what it is willing to do in an SC3 partnership. Regardless of the method you choose to approach and inform your management, there are a few topics you may want to cover with them: The The ways ways your your organization organization can can benefit benefit from from getting getting involved involved in in SC3; SC3; The The benefits benefits to to the the school, school, school school district district and and community; community; The The various various ways ways your your organization organization can can help; help; and and The The level level of of investment investment your your organization organization could could make make in in SC3. SC3. There There are are a a few few different different ways ways that that an an organization organization can can support support a a school school or or school school district district in in SC3: SC3: Provide Provide assistance assistance through through a a single single project project with a defined start and end date, such as a chemical cleanout or a training; Provide ongoing sustainable support to the school through activities such as yearly responsible chemical management training for teachers and other staff; or Be available only in the event of an emergency or natural disaster. Your organization may choose one or more of these paths over time. Regardless, any level of assistance your organization can provide will help to improve school safety. Once your organization has decided to get involved in school chemical management, it’s time to identify a school or school district to help. Partnering with EPA to Address Chemical Management in Schools When approaching your management regarding getting involved in school chemical management, consider how becoming a partner in EPA’s national SC3 program might be of interest to your organization. Refer to Part 1 of this Appendix, Why Become Involved in School Chemical Management?, for a listing of the benefits of partnering with EPA. A-6 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HHooow H ww DDooo D III GGeeettt G IIInnnvvvooolllvvveeeddd iiinnn aaa SSSccchhhoooooolll CCChhheeem mmiiicccaaalll MMaaannnaaagggeeem M mmeeennnttt PPPrrrooojjjeeecccttt??? HOW HOW DO DO I I GET GET STARTED? STARTED? Your organization may have an existing relationship with a school(s) that you can use to help the school get started with responsibly managing its chemicals. In addition, you should contact the EPA SC3 Account Manager responsible for your region to enlist their help in finding a school or school district with which to work. The table below provides a listing of EPA SC3 Account Managers to contact for answers to questions about SC3 and how your organization can get involved with a school on an SC3 project. Please refer to the SC3 Web site for the most up to date account manager contact information1: http://www.epa.gov/epawaste/partnerships/sc3/live.htm contact information1: http://www.epa.gov/epawaste/partnerships/sc3/live.htm. EPA Points of Contact on the Schools Chemical Cleanout Campaign (SC3) By Geographic Region Kristina Meson Eileen Naples Cyndy Merse Rhonda Minnick Meson.kristina@epa.gov Naples.eileen@epa.gov Merse.cynthia@epa.gov Minnick.rhonda@epa.gov 703-308-8488 703-308-0216 703-308-0020 703-308-8771 EPA Region 1 EPA Region 4 EPA Region 2 Connecticut Alabama EPA Region 3 New Jersey Maine Florida Delaware New York Massachusetts Georgia Maryland Puerto Rico New Hampshire Kentucky Pennsylvania US Virgin Islands Rhode Island Mississippi Virginia 7 Tribal Nations Vermont North Carolina West Virginia Tribal Nations South Carolina District of Columbia 6 Tribal Nations EPA Region 6 EPA Region 10 EPA Region 5 Arkansas Alaska Illinois Louisiana Idaho Indiana New Mexico Oregon Michigan Oklahoma Washington Minnesota Texas Pacific Northwest Ohio 65 Tribal Nations Indian Country Wisconsin 35 Tribal Nations EPA Region 8 EPA Region 7 Colorado EPA Region 9 Iowa Montana Arizona Kansas North Dakota California Missouri South Dakota Hawaii Nebraska Utah Nevada 9 Tribal Nations Wyoming Pacific Islands 27 Sovereign Tribal Over 140 Tribal Nations Nations 1 You may also contact Kristina Meson, SC3 National Program Manager, by phone at (703) 308- 8488, or by email at meson.kristina@epa.gov. A-7 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HHooow H ww DDooo D III GGeeettt G IIInnnvvvooolllvvveeeddd iiinnn aaa SSSccchhhoooooolll CCChhheeem mmiiicccaaalll MMaaannnaaagggeeem M mmeeennnttt PPPrrrooojjjeeecccttt??? In addition to the above contacts, there is a SC3 contact in each region who knows about schools that can use your assistance. The contact information for each region can be found at the “Where You Live” page on the SC3 Web site: http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/live.htm HOW HOW WILL WILL EPA EPA AND AND MY MY ORGANIZATION ORGANIZATION WORK WORK TOGETHER? TOGETHER? EPA will work with you to answer your questions and help your organization get involved in a school SC3 project that fits well with your capabilities. EPA provides information resources and guidance on various chemical management topics on the SC3 Web site. You can also contact an EPA Account Manager or a regional SC3 lead for help with the following: Identifying Identifying schools schools which which may may need need assistance; assistance; Brainstorming Brainstorming ways ways your your organization organization can can assist assist a a school; school; and and Forming Forming teams teams to to make make the the project project a a success. success. When you contact the EPA SC3 Account Manager or a regional SC3 lead, there are a few questions they may ask to assess how your organization can be of greatest assistance to a school (see below). Some of these questions are good ones to pose to your management as you brainstorm how the organization will get involved in SC3: Potential Questions When Considering A School Chemical Management Project 1. Where is your organization located? 2. Has your organization ever worked with a school or school district? If so, might you want to work with them again? 3. What type of expertise can you offer to a school? a. Chemical inventory? Cleanout? Disposal? b. Providing chemical management training? c. Providing emergency chemical management services to a school or school district? A-8 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HHooow H ww DDooo D III GGeeettt G IIInnnvvvooolllvvveeeddd iiinnn aaa SSSccchhhoooooolll CCChhheeem mmiiicccaaalll MMaaannnaaagggeeem M mmeeennnttt PPPrrrooojjjeeecccttt??? Potential Questions When Considering A School Chemical Management Project d. Writing contracts or request for proposals for school cleanouts? e. Enlisting other partners/building a partnership team? 4. Does your organization belong to another EPA program such as Performance Track or the National Partnership for Environmental Priorities? Communicate openly with EPA about the types of assistance your organization can provide and any reservations that you may have. EPA SC3 Account Managers and regional SC3 leads are skilled at matching a school’s needs with an organization’s capabilities, and in finding other partners to complement your organization’s role on a school project. If your organization decides to become an EPA Partner, you will be asked to sign an SC3 Partnership Agreement2. This agreement simply indicates that your organization is committed to promoting responsible chemical management in K-12 schools, and does not impose specific requirements upon your organization. EPA will recognize your commitment to promoting responsible chemical management in K-12 schools by presenting your organization with a plaque at a recognition event that will include the press and other media. EPA will also add your organization to the Partners Page on the SC3 Web site. HOW WILL EPA HELP MY ORGANIZATION? Once your organization reaches out to EPA and expresses an interest to get involved in an SC3 project, EPA will do a variety of things to arrange an SC3 project that matches your expertise and resources with a school or school district: 1. EPA will form a team to help you find a school. At a minimum, the team will include your organization, EPA SC3 Account Managers, and regional SC3 leads. State agencies and other SC3 partners (refer to the SC3 Web site: www.epa.gov/sc3 and click on “Partners”) may join the team as well. 2. Once a school is identified, the team will: Identify an SC3 Champion at the school or school district who will generate support within the school or school district and, possibly, the community (the champion will likely be your primary point of contact within the school); Determine the scope of the project; and Assist in defining roles and responsibilities. 2 http://www.americanchemistry.com/s_rctoolkit/sec.asp?CID=1819&DID=6828 A-9 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HHooow H ww DDooo D III GGeeettt G IIInnnvvvooolllvvveeeddd iiinnn aaa SSSccchhhoooooolll CCChhheeem mmiiicccaaalll MMaaannnaaagggeeem M mmeeennnttt PPPrrrooojjjeeecccttt??? 3. EPA can then help to: Attend (possibly through conference calls) initial meetings with the school; and Put you in contact with other organizations that have conducted or facilitated an SC3 project. 4. EPA will be available to you throughout the project if you have questions or need support. When the project achieves a significant milestone or after the project is successfully completed, the team—especially EPA-- will help you gain local and national recognition by posting your accomplishments and successes on the SC3 Web site. 5. Your organization may be eligible to receive an award (note: An enforcement screen will likely be needed to qualify your organization as an award recipient). HOW SHOULD I APPROACH THE INITIAL MEETING WITH A SCHOOL OR SCHOOL DISTRICT? It depends. If you find a school or school district has already evaluated or begun to evaluate its chemical management situation, school officials will not need background on the merits of establishing an SC3 program. Instead, consider speaking with them about how your organization’s experience and expertise could help them. If a school has not addressed its chemical management situation or launched an SC3 program, it may be more appropriate to discuss the merits of undertaking projects to improve school chemical management. In this section we provide you with tips to handle either situation. When you begin working with a school, it will be important to gauge how far along the school is in developing and implementing an SC3 plan. In your initial discussions with school officials, listen carefully to how your organization can best address their needs and then be prepared to offer suggestions. If a school is unsure about how to proceed, discuss potential approaches, referring them to the graphic below to get an idea of how developed their chemical management program may be. Let school officials know how your organization can help with any or all of the “steps to a safer school…” A-10 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HHooow H ww DDooo D III GGeeettt G IIInnnvvvooolllvvveeeddd iiinnn aaa SSSccchhhoooooolll CCChhheeem mmiiicccaaalll MMaaannnaaagggeeem M mmeeennnttt PPPrrrooojjjeeecccttt??? For schools that are not familiar with the importance and benefits of responsible chemical management, the initial meeting gives your organization the opportunity to provide the school with some background on the topic and convey how you can help. We suggest that you tie your service efforts to tangible benefits, such as: Saving money on purchasing and disposing of chemicals; Reducing the use of dangerous chemicals in schools; Preventing dangerous and costly spills and releases, resulting in school days lost; Reducing liability and loss of public confidence; and Making the school safer for students and staff. In your initial discussions with a school or school district, refer to the following graphic which illustrates the key elements of a successful SC3 program. Point out to the school those areas and issues that your organization’s expertise and experience may address. Please note the components and functions represented here are in no particular order. While some of these themes may be related, the connections portrayed are random and do not imply any dependency. A-11 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HHooow H ww DDooo D III GGeeettt G IIInnnvvvooolllvvveeeddd iiinnn aaa SSSccchhhoooooolll CCChhheeem mmiiicccaaalll MMaaannnaaagggeeem M mmeeennnttt PPPrrrooojjjeeecccttt??? As you prepare for the initial meeting, keep in mind that some schools or school districts may: Require more information on developing or improving an SC3 program, which EPA provides in other parts of this Workbook. You can find other resources on the SC3 Web site. Be somewhat skeptical about why your organization wants to get involved. Keep it positive and focus on the ways your organization can improve the school’s chemical management situation. Be somewhat cautious about going into detail concerning their chemical management situation. Have competing priorities and may not want to start tackling this issue right away. Have a chain of command and may need to get approval from people not at the meeting. This may take some time. Need to be reassured that they will be working with a team to ensure the success of the project. A-12 W Whhhyyy W BBeeecccooom B m meee IIInnnvvvooolllvvveeeddd iiinnn SSSccchhhoooooolll CChhheeem C m miiicccaaalll M Maaannnaaagggeeem M m meeennnttt??? HHooow H ww DDooo D III GGeeettt G IIInnnvvvooolllvvveeeddd iiinnn aaa SSSccchhhoooooolll CCChhheeem mmiiicccaaalll MMaaannnaaagggeeem M mmeeennnttt PPPrrrooojjjeeecccttt??? BACKGROUND ON HOW SCHOOLS OPERATE Perhaps you are a parent of a K-12 student and are familiar with the school at which your child attends. If you do not have ties to a school in your area, however, it may not be immediately apparent how schools operate. Working with schools and school districts may present challenges that are not found when working with other in stitutions. Some things to keep in mind include: Schools are operated and managed at a local level; Schools are governed and influenced by a complex set of institutions (which means that it may take longer than expected to arrange and carry out a project); Schools have unique priorities, standard operating procedures, and challenges; and Schools may not realize that they have a chemical mismanagement problem or may want to avoid the appearance that they are not protecting their students adequately. HOW HOW SHOULD SHOULD I I FOLLOW FOLLOW UP UP AN AN INITIAL INITIAL MEETING MEETING WITH WITH A A SCHOOL? SCHOOL? We We recommend recommend that that you you follow follow up up the the initial initial meeting meeting with with a a school school by: by: Answering Answering questions; questions; Providing Providing additional

Environmental hazards

All malfunctions of equipment, the maintenance of which, is necessary to pre vent such releases; All other deviations of the environmental laws, regulations, terms or conditions of op erating permits or plan approvals a nd ord ers of a ny state or federal enfo rcement agency by the Contractor or any related party, whethe r or not th ese devia tions have been doc um ented. I, ______________________________ _____ ______, being d uly sworn a ccording to the law depose and state, under penalty of law as provided i n 18 Pa. C.S. §4944, that I am the representative of the Contractor, identified abo ve, authori zed to make this affidavit. I further state that the information provided with this form, after reaso nable inq uiry, is true and complete to the best of my belief and that there are reasonable procedures in place to insur e that documented conduct and deviations are identified and made part of the complia nce revie w info rm ation contained in the Compliance Review Form. *** 4-57 Chapter 4 – Put Your SC3 Program Into Action Exhibit 4-12: Vendor Qualifications Checklist Vendor Name: Ensure that your vendor meets all applicable Federal, State and Local requirements before selecting. The Vendor: 1) Can pack the chemicals? 2) Can transport the chemicals? 3) Can treat and dispose of the chemicals? 4) Can reconcile the chemicals? 5) Carries all of the proper insurance? 6) Has chemical technicians that have proper training and certifications? 7) Has truck drivers that have proper training and certifications? 8) Can provide acceptable USDOT compliance history? 9) Can provide acceptable USEPA compliance history? 10) Can provide acceptable OSHA compliance history? 11) Can provide acceptable TSDF compliance history? 12) Has all the appropriate permits for transportation? 13) Has all the appropriate permits for storage? 14) Has all the appropriate permits for treatment and disposal? 4-58 Chapter 4 – Put Your SC3 Program Into Action Exhibit 4-13: Sample Price Quote Re: Disposal of My High School’s Waste Our company is pleased to submit a detailed quotation for the mana gement, transp ortation and disposal of the hazardous materials located at My High School. G iven our und erstanding of the scope of work per the chemical inventory that was provided us, we present the following Price Estimation to complete this project. This estimate specifies the following services to be carried out and the requirements to be met: Materials will be classified and marked with a label giving the chemical name or composition, or the MSDS must be available. The cost fo r marking each container is $XX.00 Materials will be segregated by c ompatibility, ha ard class and disposal requirements. The cost z for segregation of materials is $XX.00. Lab packing materials into drums and/or DOT approved over packing containers. The cost of lab packing each drum is $XX.00. Lab packs will be labeled to meet state and federal regulations. Completion of appropriate documentation, manifests, and shipping documents. The cost for preparing these documents is $XX.00. Lab packs will be transported to our facility for storag e/transfer/processing for final disposal. The cost for these services is $XX.00. Materials that are not included in this price quote include: radioactive materials, shock sensitive compounds, biological wastes, explosives, and pressurized cylinders and/or gases unless otherwise stated in the attached Price Estimation. This proposal is valid for 45 days from the issue date. 4-59 Chapter 4 – Put Your SC3 Program Into Action Exhibit 4-14: Examples of Cost Saving Techniques Technique Type of Cost Real World Example Savings L everaging a household Transportation and The Tennessee Department of Environment and h azardous waste (HHW) labor. Conservation used an existing contract to do HHW c ollection event for chemical collection and facilitate simultaneous cleanouts of school d isposal. labs. U se a knowledgeable partner to Packing, labor, The Northwest Tri-County Intermediate Unit i n Pennsylvania he lp i dentify s ubstance(s) that transportation, and leveraged the State environmental agency to review can b e safely disposed of without disposal. inventories and denote items that could be safely disposed . a hazar dous waste contractor. Work with a partner organization Disposal (lower rates) In Iowa, in the early stages of their chemical management to tak e advantage of an existing efforts, the Metropolitan Waste Authority partnered with EP A dispo sa l c ontract. Region 7 to use existing chemical management services. Incor porate performance-based