Green Tick: Chemical Safety in Science Education

Chemical Safety in Science Education – an Evaluation

https://chesse.org/

Introduction

Chemical Safety in Science Education (CheSSE) is a web-based resource,  which is intended to provide concise, up-to-date information for science/chemistry teachers, heads of schools and science teacher educators. It is a three-year Erasmus+ Programme of the European Union, co-funded by the Universities of Helsinki, Ljubljana, Oslo and Stockholm. The current version is in English, but the intention is to translate it into the languages of the partner institutions with EU legislation as a guiding theme. The resource gives useful advice on using chemicals in schools. Although science teachers from non-EU countries could adopt the materials as checklists about their practice, they would be especially valuable in the EU.

The target audience is science/chemistry teachers, to help them  to develop their competence in handling chemicals and managing laboratories. Although principally aimed at chemistry, this resource does also refer to other laboratory hazards, from electricity to trip hazards. CheSSE may also be of use to heads of schools, for instance to show that chemistry teachers really do need several chemical storage cabinets. Teacher educators could certainly use it when working with their trainees, so that they become aware of good practice. Those supporting or controlling the use of chemicals in science or chemistry education may find it enlightening. Agencies with an interest in this area are invited to register with the organisers.

There are six main sections, discussed below. To some extent, such a division is bound to be arbitrary, but plenty of internal hyperlinks are provided to overcome any problems that arise.

Responsibilities, routines, and training

This section is the longest of the sections and is divided into three main sub-sections, each of which is further sub-divided.

The first sub-section is on Legal responsibilities and discusses the responsibilities of the employer and how these are delegated to teachers or others with suitable qualifications. The employer has ultimate responsibility for the health & safety of both students and staff and the employer’s representative for this is the school principal. Taking responsibility involves documenting a systematic approach to health & safety, ensuring that staff and students receive adequate training and – often forgotten –  that sufficient time and other resources are devoted to chemical safety. CheSSE also acknowledges that most principals will not have a science background themselves, so will need to delegate the role, and that such individuals must be given the time, training and, most importantly, the authority to do the job effectively.

The resource makes the rarely-acknowledged point that chemistry teachers have an extra, non-pedagogical role when compared with most teachers and this requirement needs to be documented and adequate resources provided. It points out that both teachers and students must co-operate with the employer to ensure safe working and emphasises that teachers must inform the employer about any shortcomings in the arrangements.

There are links to two templates, with an encouragement to modify them to satisfy local conditions. One lists some over twenty safety tasks, covering training, risk assessment, chemical handling, etc. Although useful, some schools may struggle to accomplish all the tasks. The other template is a suggested formal contract between employer and employee, in which the employee agrees to take on some of the safety tasks and the employer reduces their teaching load by an agreed amount of time, or provides additional remuneration.

The sub-section on Chemical safety routines emphasises that a school needs to document how it manages safety when using chemicals. This may require a change of mindset amongst staff, but will help when inducting newcomers. CheSSE realistically acknowledges that developing a systematic approach from scratch may seem overwhelming, but provides some possible strategies. There are eight routines suggested and a total of 21 templates or checklists provided, mostly as easily-modifiable Word documents. Some routines cover only a small part of a teacher’s work, e.g. records of the use of chemicals prone to theft. Others are relevant for almost every lesson, e.g. records of risk assessments. The routines and checklists largely complement each other; for instance, whilst Routines for inspection and maintenance tells you what to do and when to do it, the corresponding checklist tells you what to look for and allows the outcome to be easily recorded.  Most of the templates begin with a statement, to be deleted when finished, that the template should be adapted to local conditions.

Some schools may find that there is not sufficiently detailed explanation (e.g. on the storage of bromine liquid). Some routines may require significant modification in line with national practice (e.g. on the checking of fume cupboards). The Template for risk assessment is sensible and appropriate for the school situation. Whilst giving some guidance on how to complete the template, schools would benefit from some completed good-practice examples involving typical school scenarios. The Hazardous Waste Storage Decision Tree is clever and useful, but not quite complete in that it ignores the possibility that schools may wish to dispose of bottles of inorganic chemicals not in solution. It is easy to quibble with particular details in the templates, but this sub-section is comprehensive and undoubtedly one of the strengths of the whole project.

There is a Checklist for fume cupboards. However, the checklist itself, and the website more widely, use the terms ‘fume hood’ and ‘fume cupboard’ indiscriminately. The term ‘fume hood’ is not mentioned in the European Standard EN 14175 Fume Cupboards, which only uses the term ‘fume cupboard’. In some quarters, the term ‘fume hood’ is used for a device that does not comply with the standard, but it is very unlikely that such a device would give adequate protection in some situations likely to arise in schools.

The third sub-section on Chemical safety training is much shorter than the other two, but follows a similar pattern. It acknowledges that chemistry teachers will have learnt something about chemical safety as part of their own education, but that that is not the same as learning about chemical safety in a school context. Any UK teachers who come across the website might be puzzled by reference to teachers’ HSE training – this refers not to the UK’s Health & Safety Executive, but to the teacher’s own health & safety in education training. There is discussion of training in handling hazardous chemicals, in following the school’s chemical safety routines and in managerial roles for particular tasks. Training may be by self-study, but the resource emphasises the necessity for time to be allocated for all this training. Finally, there are suggestions for the safety training of students.

Risk assessment and substitution

This section is much shorter than the previous one, comprising only two sub-sections.

The sub-section on Risk Assessment emphasises that it is aimed at the school laboratory and science classroom and acknowledges the existence of non-chemical hazards, but does concentrate on the chemical ones. It rightly points out that you cannot achieve a risk-free environment, but should aim to achieve adequate control over the risks. It explains briefly the difference between hazard and risk and discusses types of hazard, but gets slightly confused, perhaps because the authors are not writing in their native language, when they refer to ‘potential hazard’ when they mean ‘potential risk’. Precautionary measures are discussed and the resource makes the important point that you always need to consider using a chemical or procedure presenting a lower risk. When documenting a risk assessment, CheSSE sensibly suggests that the level of detail should be proportionate to the level of risk. After guidance on what to include, there are links to the templates for both the routine and the record system for risk assessment referred to previously. Ready-made risk assessments, e.g. in textbooks, may be valuable in saving time, but they do need to be reviewed, and perhaps adapted, to the situation in a particular school.

The other sub-section, on Substitution, explains that this means replacing chemicals or procedures with less hazardous ones, including those less hazardous to the environment. Restricted or prohibited chemicals, such as Substances of Very High Concern (SHVC) under the European Chemicals Agency (ECHA) classification, should be avoided, but the resource points out that these are not necessarily well known to textbook authors! Substitution may simply involve using a more dilute solution. Other examples are provided.  There are links to the ECHA Authorisation List, its Candidate List of substances of very high concern for Authorisation, and its Substitution to safer chemicals document, although teachers may find these rather overwhelming.

Labelling, storage, and waste management

The third section has three sub-sections. Although quite short, they should prove to be a useful, time-saving resource for schools.

The sub-section on chemical Labelling points out that purchased chemicals will be already labelled, so the guidance here is aimed at schools producing their own labels, mainly for solutions. There is sensible guidance on what needs to be included on a label and a link to the ECHA Classification and Labelling Inventory. Most of this is irrelevant to schools, so the resource has produced its own list of 22 chemicals that schools use – the common acids, alkalis and salts, and hydrogen peroxide, but not, for instance, acid/base indicators. Clicking on each name generates a display of the hazard pictogram, signal word, hazard statements (H-statements) and precautionary (P-)statements at different concentrations. Only those P-statements likely to be relevant for secondary schools are included. For each concentration, the school can then produce a label for that solution by clicking on the ‘generate label’ tab. Once opened, schools would be able to copy the label into a Word document, customise it to their own situation, e.g. by adding the school’s name or extra precautions, and print it on a standard label sheet. Schools are likely to find this very useful.

The sub-section on Storage emphasises the need to store chemicals securely, not to store excessive amounts and to appropriately dispose of those no longer needed. It is suggested that five or six separate storage cabinets will be needed, some of which should be separately ventilated. These cupboards should be checked from time to time for damage, especially hinges, which should be checked for corrosion. The location of each chemical would be recorded in the Chemical Inventory. Considering how many templates are provided on this website, it is surprising that, whilst there is a suggested Routine for updating the chemical inventory, there is no template for an inventory already populated with the chemicals commonly found in schools. Any such template would require considerable modification for any particular school, but it could be a labour-saving exemplar of good practice.

There is a discussion about the principles of safe storage: storing liquids below eye-level, keeping incompatible chemicals apart, etc. The special storage problems of particular chemicals are considered and a scheme for storing them in six cabinets is suggested. This discussion then realistically acknowledges that many schools will not have the space or money to provide so many cabinets, and explores possibilities for co-storage. It also notes that, if taste-testing of foodstuffs is to be carried out, such foods should be stored separately from other chemicals and not tested in laboratories.

The title of the final sub-section, Waste management, makes it clear that this is about more than merely waste disposal. It explains the Waste Hierarchy. Management involves preventing waste production in the first place, through smaller-scale working, substituting less hazardous chemicals or recycling rather than disposal. Waste can sometimes be made safer, by neutralisation, dilution, precipitation, etc. However, schools will sometimes still need to dispose of hazardous waste and should understand how different wastes are classified in law. There is a useful table showing how to do this. The resource suggests the provision of Waste Disposal Stations, with five different containers for chemicals and three others, although prior discussion may be needed with contractors about what they will be expecting to collect. A hyperlink takes you to the previously-mentioned Hazardous Waste Storage Decision Tree.

Legislation

In six sub-sections, this section deals with the legislation about those chemicals relevant to schools. Five of these relate to EU legislation and the sixth to national legislation, which may be more restrictive than EU requirements, but cannot be less so.

The first sub-section gives an Overview of European Chemicals Legislation. It explains the underlying principles behind EU legislation:

  • Prevention is better than repair;
  • Preventing risks to public health, safety and the environment should take precedence over economic interests (the precautionary principle); and
  • The person who causes pollution is responsible for paying for the damage (the polluter pays).

It explains the difference between EU Regulations (binding regulations directly applicable throughout the EU) and EU Directives (equally binding but implemented through national regulations throughout both the EU and European Economic Area, EEA).

The next sub-section discusses Legislation for Classification and Labelling of Chemicals, the CLP Regulations. Using the example of sulfuric acid, it explains the components of a label. Hazard pictograms are described and then how the hazard class is arrived at and how this leads to the inclusion of particular H-statements on the label are explained. H-statements and P-statements are numbered according to type and have specific wording in all EU and EEA languages, which cannot be freely translated.

When a chemical is first supplied, Safety data sheets (SDS) must be provided, by the supplier, on paper or in electronic form (but not just on a website). The components of the SDS are tabulated by the resource. The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is an attempt to adopt common criteria across the world. Finally, there are hyperlinks to the relevant CLP and GHS legislation, although these could be overwhelming.

The third sub-section is about Legislation Restricting the Use of Chemicals. Restrictions may be because of their effect on health or the environment, or because of their potential for making explosives or illicit drugs. The former category is controlled by the REACH (The Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation. The use of certain Substances of Very High Concern (SVHC) requires authorisation from the European Commission, with the aim of gradually replacing them with less dangerous substances or technologies. Although the difference between the Authorisation and Candidate Lists is explained, examples that are relevant to schools would have been useful. The discussion of potential precursors for explosives or illicit drugs includes the steps that must be taken in order to be able to purchase them. Schools often have legitimate uses for some of these chemicals and are required to control access to them. A few examples of such chemicals likely to be found in schools is given, but a more detailed list would have been helpful. Finally, there are hyperlinks to the relevant legislation.

The next sub-section is relatively short, dealing with Waste legislation. It focuses on the Waste Framework Directive and, to some extent, repeats what is in the Waste management sub-section. It explains that the purpose is to ensure that waste is managed without endangering health or causing harm to the environment and again refers to the Waste Hierarchy. It gives a hyperlink to the Waste Framework Directive, but stresses that schools need to consult both national and local legislation because, in this area, such legislation can be more stringent that the EU Directive.

The penultimate sub-section, on Occupational health & safety legislation, is less directly related to chemicals than the previous ones. The employer is required to assess whether hazardous chemicals are in use and ensure that employees are given sufficient time and training to use them safely. They must also designate sufficient employees, with sufficient time and resources, to prevent and protect employees from occupational risks. In addition, employees are under an obligation to protect their own health & safety by co-operating with their employer on such matters. This would include using equipment and chemicals correctly, and also informing employers about any deficiencies in the situation. There is also a requirement for health surveillance, but this depends on national legislation. Again, there are hyperlinks to the relevant legislation.

The final sub-section is about Nationally-specific legislation. The aim is that this will provide a summary of national laws and interpretations of laws that differ from the general EU legislation. This will be elaborated upon in the national versions of the CheSSE website, but was not available for this evaluation.

Green Chemistry

At the time of the evaluation, this section had not been populated, but it is intended to do so in 2023.

Checklists and tools

The final section contains nothing new. It simply lists, and provides hyperlinks to, the various routines, templates and similar documents mentioned in earlier sections. For instance, clicking on the Routines for inspections and maintenance tab reveals a list of hyperlinks to two templates and three checklists previously considered. This will be useful to teachers who recognise that they have seen something about a particular topic but cannot remember exactly where it is on the website. It would probably be of even more use if it has a similarly consolidated list of EU legislation.

Conclusion

Chemical educators in the contributing nations will understand the needs of science or chemistry teachers in their own country and presumably will have tailored this resource to their requirements.  The English language version would be of use in English-speaking EU member countries, especially the Irish Republic, but it is not clear whether the English version will be retained after translation and, if so, what will happen to the sections on national legislation. In principle, it could be used in the UK, because most of the relevant pre-Brexit legislation is still in place, or has been replaced by compatible legislation, and that is likely to remain the case. However, UK teachers would probably expect much more detailed guidance of the sort that they receive from CLEAPSS (in England, Wales and Northern Ireland) or SSERC (in Scotland). To some extent, CheSSE offers a partial replacement for their services.

It would help users if there were examples, or additional or more varied examples, of the application of some of the guidance in the school science/chemistry context. Within the sub-section on Risk assessment, there is discussion of a relatively trivial example of hazard, risk and exposure concerned with a hot evaporating dish and the flame of a Bunsen burner. This is useful in emphasising that not all hazards encountered in chemical laboratories are chemical in nature, but one or more further examples actually involving chemicals would help schools. Examples could include bad practice, with a suitable commentary. Biology and physics teaching use chemicals, but there is no reference to biological stains or radioactive chemicals. It is unclear how this resource will be kept up-to-date, as legislation changes and memories of the development work fade.

These reservations are minor blemishes on a resource that provides authoritative guidance on good practice when teaching science or chemistry in secondary schools. They may perhaps give a pointer for future development. Effective implementation is likely to require training but, even if this is not available, this resource will still prove useful as a standard showing what schools could and should be doing. I would have no hesitation in recommending its use.

Evaluator

Dr T. P. Borrows, MA, PhD, CSci, CChem, FRSC;10 November 2022

Member (and former Chair) of the ASE Health & Safety Group, former teacher of science/chemistry, former school adviser/inspector, former Director of CLEAPSS.