THE BIG PICTURE
Schools frequently utilize hazardous products similar to those found in industrial settings, both for educational activities and maintenance tasks However, unlike industrial facilities, many schools lack proper chemical management and health and safety systems to effectively select and oversee these hazardous materials Consequently, schools often possess highly toxic, reactive, and potentially explosive substances without the necessary protocols for safe usage, storage, and disposal This leads to significant unmanaged stockpiles of hazardous materials, which pose unnecessary exposure risks to students and staff.
When evaluating the costs associated with hazardous material management, it's essential to consider not just the initial purchase price but also additional expenses that arise post-purchase These costs encompass various factors, including disposal fees, regulatory compliance expenses, training for safe handling, and potential liability costs.
Potential liability for property damage, environmental contamination or personal injury
The hidden costs associated with managing hazardous materials are directly linked to the volume and level of hazard of the substances purchased Alarmingly, many hazardous products utilized in schools, along with their associated health risks, are entirely unnecessary and can be eliminated.
This Guide assists schools in addressing these problems through Toxics Use Reduction (TUR)
Toxics Use Reduction (TUR) is a key component of Pollution Prevention strategies aimed at minimizing or eliminating pollution at its source, rather than addressing its effects after it has occurred TUR emphasizes the reduction of toxic and hazardous chemicals and materials, promoting safer alternatives In cases where the elimination of a toxic substance is not feasible, it is essential to manage it in an environmentally responsible way.
Definitions: Hazardous Product, Waste, Material
This Guide draws the following distinctions:
Hazardous Product – Any hazardous chemical which the school has purchased and is using or is storing with the intention to use.
Hazardous Waste – Any hazardous chemical that the school is not intending to use in the future and/or which has been designated as waste.
Hazardous Material – Any hazardous chemical usable or unusable stored and/or managed by the school This category includes both hazardous products and hazardous wastes.
Why Implement TUR Strategies in Schools?
Reduce the health and safety risks associated with exposures to hazardous products for students and school staff.
Limit the environmental impacts of hazardous materials used and disposed of by the school.
Lower the financial costs and legal liabilities associated with the storage, use and disposal of hazardous materials
How to Implement TUR Strategies?
Review your hazardous materials management systems and processes to find ways to eliminate hazardous products or minimize their toxicity and quantity Consider key questions and potential opportunities for improvement in your approach to hazardous materials management.
Question Opportunity Possible Solutions Examples
Why is this hazardous product being used, is it necessary?
Another method may eliminate the need for using a hazardous product.
Equipment or technology changes or modifications.
Equipment Modification: replace a solvent-based parts cleaning system with an agitating water- based parts washer.
Technology Modification: use cut out lettering for signs instead of painting them with a solvent- based paint.
Does the activity truly require chemical use? A safer alternative product or process may exist.
Product or process substitution Product: Use a water-based product instead of a solvent- based product – e.g., paints, adhesives.
Process: Use a video demonstration of an experiment with a hazardous chemical instead of the entire classroom doing the experiment.
Are there no possible alternative processes or products?
Use the hazardous product efficiently and safely.
Process or procedure modifications Process: Use a product dispenser that enables custodians to obtain accurately diluted cleaning products
Procedure: Create a policy to use product at recommended dilution rate and not to mix with other products.
Are there ways to eliminate the generation of unnecessary waste and releases to the environment?
Improve your housekeeping and maintenance of hazardous products and equipment.
Inventory control, proper storage system, leak detection, spill prevention, and employee training.
Products: Implement a written or computerized inventory system to track your hazardous materials.
Equipment: Maintain chemical storage equipment to prevent spills.
How to Develop and Implement TUR Strategies at Your School?
There are three distinct stages to toxics use reduction in your school:
To enhance safety in schools, the first stage involves reducing hazardous material inventories by identifying and removing stockpiles of unused or unsafe substances It's essential to assess the remaining hazardous materials to evaluate their necessity and toxicity, determining if they can be eliminated or replaced Prioritizing this process by focusing on the most hazardous products will help streamline efforts Aiming to reduce inventory levels to normal operating quantities for one to two academic years is a recommended goal for effective management.
Stage 2: Establish a system for managing hazardous materials that cannot be eliminated
The system would include student and staff training, and established procedures for hazardous product use, storage, tracking, disposal as well as emergency response procedures.
Why Implement TUR in Schools?
There are many reasons for implementing toxics use reduction (TUR) in schools:
Children are more vulnerable to toxic substances due to their high metabolism and rapid tissue growth, making them more susceptible to harmful chemicals than adults The "safe" concentration limits set in the 1970s were primarily based on adult exposure in an eight-hour workday, and many chemicals used in schools lack established exposure limits To effectively protect children from the adverse effects of these harmful chemicals, it is essential to minimize their use whenever possible.
Non-compliance with regulatory standards can lead to significant financial penalties for schools Various state and federal laws mandate that educational institutions safeguard students from hazardous chemicals Regulatory bodies, including the Department of Environmental Protection and local fire departments, often collaborate with schools to enhance their environmental and safety practices, but they also possess the authority to impose fines for violations.
Toxics use reduction helps schools save money Purchasing laboratory and other chemicals in bulk is a common practice believed to be a money-saver Staring in mid-
In the 1990s, schools in the state started disposing of decades' worth of unused chemicals at clean-out costs reaching up to $30,000 per school Although smaller quantities of these chemicals could have been more expensive to buy initially, the expenses related to storage, management, and disposal would have been avoided Clean-out efforts across Cape Cod revealed that over 90% of these products had never been opened, indicating they should never have been purchased in the first place.
Enhancing the school environment significantly boosts student performance Implementing strategies to reduce toxic substances leads to improved indoor air quality and decreased chemical exposure Research indicates that these environmental enhancements positively impact both student health and academic success.
Stage 3: Establish a purchase review system that guides the quantity and toxicity of products allowed to be acquired in the future.
In order to develop and implement this program, we highly recommend taking the following Five Steps To a Healthier School:
To effectively manage hazardous materials in schools or districts, it is essential to assemble a dedicated team led by a coordinator This team should include representatives from all departments that utilize hazardous materials, ensuring comprehensive oversight If an existing environmentally focused team is in place, their responsibilities can be expanded to encompass these critical issues The team will then proceed to implement necessary steps for effective management and safety.
Establish program goals and objectives, and a schedule to implement them.
Conduct a baseline assessment using the provided checklists to evaluate your use of hazardous products and the management systems for hazardous materials in your building cleaning, maintenance, and curriculum practices.
Work with each department to evaluate the Baseline Assessment findings to set priorities and develop a plan
Conduct an annual evaluation of your plan and track your progress This evaluation can be used to determine next steps
Many schools struggle to maintain chemical safety due to a lack of follow-up on initial efforts While the initial clean-out of hazardous materials is crucial, it must be accompanied by a sustainable system for inventory control and purchasing In Massachusetts, some schools quickly replenished their chemical inventories to previous levels after their clean-out, as they lacked effective screening processes for the quantity and toxicity of new products Consequently, their initial progress in chemical safety management was not sustained.
How Can Statewide Contracts Help You?
The Operational Services Division (OSD) serves as the central purchasing department for the Commonwealth of Massachusetts, tasked with establishing and managing statewide contracts (SWCs) for the state While OSD does not directly procure products or services, it sets the terms and conditions and negotiates pricing for eligible entities, who are responsible for placing orders and making payments using their own budgets.
Public schools can utilize Statewide Contracts (SWCs) without any application process, making state contractors automatically available to them Numerous school systems, municipal departments, colleges, and universities throughout the state are already leveraging SWCs for their procurement of products and services These existing SWCs offer schools essential tools for the efficient and safe purchasing, management, and disposal of chemicals.
What are the Benefits of Using SWCs?
BARE NECESSITIES
This section of the Guide explores four areas of your school’s activity that are covered by state and/or federal regulations:
Hazardous Waste Management and Disposal
Universal Waste Management and Disposal
Statewide contracts and contractors can serve as important resources for achieving compliance and implementing best management practices However, please remember that:
All laws and requirements listed in the Guide place the ultimate responsibility for compliance on the school (and not on the contractor)
The Guide features a list of approved statewide contractors, but schools have the flexibility to select additional suppliers for products and services beyond those listed This means that schools are not limited to the statewide contractors and can explore other options that may better suit their needs.
This Guide offers summaries of regulatory and legal information to assist you in your compliance efforts; however, it is not a substitute for the technical resources mentioned throughout the Guide, particularly in the resources section of each chapter.
Chapter 1 Integrated Pest Management (IPM)
Integrated Pest Management (IPM) is a comprehensive strategy aimed at controlling pests while prioritizing long-term prevention and minimizing harm to human health, the environment, and non-target species This approach involves accurately identifying pests, monitoring their behavior and population trends, and employing a mix of cultural, physical, biological, and chemical methods when appropriate, to keep pest populations at acceptable levels.
Implementing IPM programs can benefit a school in many ways:
Implementing Integrated Pest Management (IPM) in schools not only addresses pest control but also enhances the overall quality of the school environment By tackling issues like moisture and mold, IPM significantly improves indoor air quality while simultaneously reducing the presence of pests such as carpenter ants and termites.
Implementing prevention strategies like moisture control, sealing cracks, and maintaining sanitation can significantly lower pest management costs for schools These proactive measures not only reduce the reliance on pest management services and pesticides but also lead to long-term financial savings Studies have shown that indoor Integrated Pest Management (IPM) programs consistently provide cost benefits to educational institutions.
Reduced Liability A reduction in the use of pesticides often observed enables schools with IPM programs to reduce the risk of student and staff exposure to potentially harmful chemicals.
All Massachusetts schools, daycare centers, and school-aged programs must comply with the Act Protecting Children and Families from Harmful Pesticides by creating comprehensive indoor and outdoor Integrated Pest Management (IPM) plans.
The Massachusetts Department of Agricultural Resources (DAR), through its Pesticide Bureau, enforces compliance with the Act by inspecting schools and imposing civil penalties of up to $1000 for violations Penalties have been levied against schools, daycare centers, and pest management companies for failing to submit required Indoor and Outdoor Integrated Pest Management (IPM) Plans Violations often stem from the use of prohibited pesticides or the absence of an IPM Plan on file Schools can check their compliance rates by visiting [the DAR website](http://massnrc.org/ipm/).
What are the legal requirements?
The Act Protecting Children and Families from Harmful Pesticides, enacted as Chapter 85 of the Acts of 2000, became effective on November 1, 2000 This legislation amends the Massachusetts Pesticide Control Act (Chapter 132B of the MGL) and specifically governs the application of pesticides in schools, day care centers, and programs for school-age children.
The primary objectives of the pesticide requirements are to minimize children's exposure to harmful pesticides, encourage the adoption of safer alternatives, and ensure that the school community is informed to effectively manage pest issues Additionally, these measures aim to promote Integrated Pest Management (IPM) techniques, reducing unnecessary pesticide use The Department of Agriculture's Pesticide Bureau oversees the implementation of these IPM standards.
The complete text of the IPM law and information on DAR IPM implementation can be found in the IPM Resources section at the end of this chapter or by visiting the link: [http://massnrc.org/ipm/](http://massnrc.org/ipm/).
Your school can measure compliance with the law by completing the below self-assessment checklist for each school building
Have you submitted your Indoor IPM plan?
Have you submitted your Outdoor IPM plan?
Do individuals who apply pesticides on the school property hold valid pesticide licenses?
For indoor pest control, does the school only use those pesticides allowed by law such as baits, gels and dusts?
The school does not use pesticides that are prohibited by the law
The school lists all pesticides intended for outdoor use within the outdoor IPM-Plan.
Does the school ensure that Standard Written Notifications are received by students, parents and staff at least two working days before pesticides are used outdoors?
Does the school post approved signage in conspicuous areas?
Does the school keep records of all pesticide use for 5 years?
Are you aware of the emergency waiver mechanism?
What can be done if you are not in compliance?
The checklist provided highlights key legal requirements If you did not answer all questions positively, utilize the checklist to pinpoint areas of non-compliance and begin taking steps to align with the Act.
If you have a perfect self-assessment result, consult
Type of Pesticides allowed WITHIN school property (indoors) w ithout prior notification
Ready-to-use dust, powder or gel formulations of insecticide applied in areas inaccessible to children and the general public
Insecticidal baits placed in tamper resistant bait stations or in areas inaccessible to children and the general public
Pesticides classified by the United States Environmental Protection Agency as exempt materials under
Rodenticides placed in tamper resistant bait stations or placed in areas inaccessible to children and the general public
Termiticides used only in the presence of an active termite infestation and when non-chemical pesticide alternatives have been determined to be ineffective
When applying any type of pesticide, including baits and termiticides, to the exterior structure of schools, it is classified as an outdoor application, necessitating proper notification and posting For exterior baiting programs utilizing tamper-resistant bait stations, notification is only required for the initial installation For comprehensive guidelines, refer to the complete DAR compliance checklist available at http://massnrc.org/ipm/docs/2005_CPA_Compliance_Checklist.pdf.
Remember that IPM programs are meant to be dynamic and continually improved as the conditions in your building change.
How can Statewide Contract (SWCs) help?
A statewide contractor can assist you in meeting these and other legal requirements and can also provide a number of additional benefits:
The listed contractor can help you create an Integrated Pest Management (IPM) plan by providing essential documentation, including details about the types of pests present, suggested monitoring strategies, and recommendations for suitable pesticides.
Environmental Protection Agency (EPA) Registration Numbers, recommended treatment and management strategies, as well as assist you to fulfill the filing, notification and recordkeeping requirements of the law.
The contractor has been pre-approved by the state All statewide contractors have successfully met general IPM standards established by DAR.
You can skip the bidding process; simply review contractor profiles and their "school scores" in the Guide, then gather price quotes from the contractors that interest you.
All contractors as part of the SWC are required to deliver an annual training to customers Look at the profiles to see which of them have recently provided training
You can work with the contractor to design the training for your school.
06/30/05 w/two 12-mo options to renew
All pest species inside the structure of the building and immediately outside if they pose a possible infestation problem Specific focus is on indoor pests.
All aspects (i.e supervision, labor, materials, and equipment) for the surveillance, trapping, and pesticide application components of a pest management program
Ability to provide specific recommendations for pest prevention
Provide technical assistance to develop IPM plans
Education and training for building occupants
Qualifications Appropriate insurance (General liability, motor vehicle and worker’s compensation)
Demonstrated ability to provide technical assistance to develop IPM plans for a school or facility of specific size
How to use this contract?
When engaging with a contractor, it's essential to discuss adherence to the Integrated Pest Management (IPM) law, as mandated by the Massachusetts Pesticide Act Following the 2000 amendments, all contractors must meet the updated IPM requirements when working in schools Initiate a conversation about these requirements and encourage the contractor to propose effective compliance strategies.
TOWARDS A HEALTHIER SCHOOL
Accessing Statewide Contracts on Comm-PASS
The new Comm-PASS system enhances your ability to search for contracts by contract number, streamlining the process to effortlessly find the contracts you need To locate a specific contract, simply follow the steps outlined in this guide.
1) Go to www.Comm-PASS.com
2) Select the "Search" menu option
3) Access the "Search for a Contract" page
4) On the “Search for a Contract” page:
Under "Document Number" enter the contract number found in a shaded box at the top of each product/service record in this Guide
5) Click on the search results link that appears above the search form
6) On the following page click on the "eye- glasses/view" icon
7) On the contract "Summary" page access vendor contact information by clicking on "Vendors" tab and OSD
Searching for All Statewide Contracts in a
To easily locate all active statewide contracts within a specific category, utilize the consistent three-letter code system employed by OSD and its designees This numbering convention allows for straightforward identification of contracts related to particular products or services Simply follow the designated steps to access the desired information efficiently.
1) Get to the “Search for a Contract” page on Comm-PASS following the steps above.
2) On the “Search for a Contract” page Under "Document Number" enter one of the three-letter codes from the table below Under "Document Status" select "Active"
Code Category Description Code Category Description
ANI Live Animal ITC IT Hardware
CLT Clothing/Toiletries ITS IT Software & Services
ENE Energy/Fuel/Utilities ITT Telecommunications
FAC Environ Services LAW Safety/Enforcement/Protection
FAC Facility Maintenance/Repair MED Healthcare
GRO Food/Groceries OFF Office/Recreation/Education
HSP Healthcare PRF Professional Services
HSS Human/Social Services VEH Vehicles/Transportation/Road Maintenance
Do not use the “Back” button of your browser Instead use the “breadcrumb” links that appear at the top of the screen just underneath blue Comm-PASS main menu.
Comm-PASS makes a distinction between solicitations and contracts Here are what these terms mean in the “Comm- PASS parlance”:
A solicitation refers to a Comm-PASS record linked to a Request for Response (RFR), Request for Proposal (RFP), or similar document that invites vendor participation Vendors are permitted to submit their responses while the solicitation is open, but they are unable to do so once it has closed.
A contract serves as a Comm-PASS record linked to agreements made with vendors for the supply of goods or services While the contract is active, it can be utilized for purchasing; however, once it becomes inactive, purchasing is no longer permitted.