CL7/98

To the Management Authority of each Second Level School

Disposal of Unwanted Chemicals

1.Purpose and background

1.1The Department has been made aware by teachers and schools of concerns about the gradual accumulation, over a period of years, of unwanted chemicals which are no longer required for school work and also of chemicals in containers on which the labels are no longer present, and cannot be identified.

1.2The purpose of this circular is to update schools on the initiative which is underway to assist schools which have stocks of unwanted chemicals. (The Department's previous circulars M34/96 and M43/96 refer.) This circular also advises schools on action which they may currently need to take and the additional assistance which may be available to them in dealing with the issue.

1.3This initiative is of course without prejudice to the responsibility of schools themselves to manage their own stocks of chemicals and ensure the safety of students, staff and property.

2.Manuals re safety in Science

2.1In October, 1996 the Department published a manual 'Safety in School Science: A Code of Practice" and issued it to all schools. It contains general guidelines (not necessarily definitive in all cases) for best practice in school science including a section on laboratory organisation and management which deals with matters such as storage, stock control and waste disposal.

2.2At the same time, the Department published a manual which it commissioned from Forbairt titled "Safety in the School Laboratory: Disposal of Chemicals". This manual gave detailed guidelines on the disposal of individual chemicals which are commonly found in School Science Laboratories. The manual explains how most of these chemicals may be safely disposed of in schools in accordance with the instructions given.

3.Chemicals which cannot be disposed of locally

3.1The manual commissioned from Forbairt identified 19 chemicals which cannot be disposed of by schools, without outside assistance of disposal experts. A Questionnaire report form was issued to all schools to identify the scale and spread of such chemicals and determine the nature of further assistance which could be given to schools to deal with the problem.

3.2Schools were asked to identify and report by 7 February 1997 on the amount of certain chemicals which may be commonly found in school science laboratories, which (A) are no longer needed in the school and (B) which could not be disposed of in accordance with the Forbairt manual. Schools were also asked to quantify stocks of unlabelled/unidentified chemicals in the report.

4.Forbairt Help Line

4.1A help line for schools was established as part of the 1997 In Career Development Programme to advise schools and teachers on the proper disposal of chemicals. The Help Line was operated by Forbairt on 20-24 January 1997.

4.2Forbairt reported that it was contacted by over 160 schools and that:

  • the majority of schools with which it which had contact, had successfully implemented the recommended disposal methods
  • a number of schools had the mistaken impression that the Department was advising schools to discontinue the use of the listed chemicals
  • some schools apparently had in their possession, chemicals which were not included in the advice manual and should not have been in a school laboratory for current curricular purposes.

5.Analysis of School Returns

5.1It is appreciated that the task of reviewing and classifying chemical stocks was a demanding one and a significant number of schools were unable to complete their reports about unwanted hazardous chemicals by the closing date. In the end 478 schools submitted reports.

5.2The Curriculum Development Unit of City of Dublin Vocational Education Committee has now carried out an analysis of the 478 returns made by schools. The key results of this analysis is attached as an appendix to this circular.

5.3The analysis of the reports goes a considerable way in defining the issue which is clearly multi-faceted and requires a range of responses at school and Departmental levels. It is evident from the reports that certain schools have not been in a position to address the issue of local disposal of unwanted chemicals for a variety of reasons. There would also appear to have been some misunderstanding about stocks of chemicals which are still relevant for curricular purposes; it would be envisaged that such chemicals should in the normal way be stored safely by schools for future use.

5.4The analysis gives quantitative information on chemicals held in schools which must be carefully and safely stored/managed by schools until used or safely disposed of whether locally or otherwise. It also shows that there is a significant problem of unlabelled chemicals held in schools which also must be safely stored until identified and/or safely disposed of as necessary. A copy of the computerised data base printout of your school's return is attached to the CDU report (where such return was received).

6.The Way Forward

6.1While the responsibility for storage and disposal of chemicals and safety issues rests with schools under the Safety, Health and Welfare at Work Act 1989 and the Chemical Agents Regulations 1994, the Department is prepared to assist schools in dealing with the problem. Any such issues can only be finally resolved by action by schools themselves.

6.2Where problems exist in schools it is probable that the matter is one which will be resolved over a period on a phased basis by schools. It is essential of course that chemicals be safely stored pending use or disposal. Appropriate action should of course be taken by schools in regard to any urgent issues.

6.3The Department now proposes that the following strategy be adopted.

  • Schools should review their chemicals stocks, with a view to safe storage pending any further action.
  • Schools should review stocks to identify chemicals which should be safely stored for future use.
  • Schools should review stocks and dispose of unwanted chemicals which can be safely disposed of locally in accordance with the guidelines already given.
  • The Department proposes to arrange briefing sessions to further assist and advise responsible teachers on disposal/storage issues as above. It is provisionally indicated that this series of one-day sessions will be held in regional venues on 3rd, 6th and 7th April, 1998. Further details about arrangements for individual schools will be communicated shortly (by CDU).
  • The Department will facilitate and advise schools in obtaining information on safe disposal guidelines in regard to chemicals not included in the original manual.
  • Following the completion of the review schools should finalise lists of unwanted chemicals which cannot be disposed of locally
  • The Department in consultation with relevant interests and authorities will assist/advise schools in the disposal of unwanted chemicals which cannot be disposed of locally
  • The Department in consultation with relevant interests and authorities will assist/advise schools in dealing with unlabelled chemicals.

6.4 The Department intends to further consult with school management, staff and the responsible authority to help further progress this initiative.

Con Haugh,

Principal.

27th February, 1998.