A Chemical Hygiene Plan: High School Version
by David Dougan MSc.

Chemical Hygiene Plan: High School Version is the result three years of research concerning how schools managed and use chemicals. The author, David Dougan, is an industrial hygienist and a chemistry teacher at the Maine School of Science and Mathematics. He has received numerous awards for his efforts to reduce the use of hazardous chemicals in school settings. These include: semifinalist for Maine Teacher of the Year, The Maine State School Board Award, the Presidential Award for Excellence in Science Teaching and the EPA Region 1 Citizen Action Award. As a consultant Mr. Dougan has audited over 400 schools throughout New England and has supervised the removal of over 100 tons of hazardous waste.

The Chemical Hygiene Plan consists of 135 pages and includes many useful lists, such as the EPA waste lists, select carcinogen list, reproductive toxin list and a list of nonhazardous chemicals. The CHP details a review process to reduce the purchase of high-risk chemicals.

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What is a chemical hygiene plan (CHP)?

The Chemical Hygiene Plan is required by the Laboratory Standard which was published in 1990 and became effective in 1991. The Standard was issued by the Occupational Safety and Health Administration in response to laboratories and laboratory workers who felt the Hazard Communication Standard was inappropriate for laboratory settings. The Standard is performance based and is designed to control employee exposure in the laboratory setting.

Does the standard apply in all states?

Most states require compliance with the Standard. You can determine if your state requires a Chemical Hygiene Plan by using the OSHA links on this site to find your state's OSHA equivalent agency.

Whose responsibility is the CHP?

The employer is responsible for the development, implementation and review of the chemical hygiene plan. In most school settings the superintendent is the responsible party but he can delegate the development of the plan.

How about CHPs in schools?

The Laboratory Standard applies to school employees who work in laboratory settings. This would include science teachers, lab assistants and custodians. The Standard does not apply to students. However, we recommend that you develop a CHP that applies to both students and staff. Where differences occur in procedures, they can be incorporated into a single document.

What type of training should the chemical hygiene officer have?

The chemical hygiene officer (CHO) should be trained in chemical health and safety. The CHO must be familiar with the Laboratory Standard, risk recognition and control, hazardous waste regulations, proper storage of chemicals, the care and use of persona l protective equipment and engineering controls. As the CHO is responsible for implementing the CHP he needs to be aware of the legal ramifications of his position.