Schools in states that are governed by OSHA regulations are required to have a Chemical Hygiene Officer (CHO) to support, guide, and train their staff (29 CFR § 1910.1450(e)(3)(vii)). Prudent practice, as well as following the suggestions of science education associations, encourages all schools with hazardous chemicals to have a CHO. This person is usually appointed by their position within the science department and not necessarily their qualifications.
As of August 2024, 23 states and territories have Occupational Safety and Health Administration (OSHA)-approved state plans:
- Alaska
- Arizona
- California
- Hawaii
- Indiana
- Iowa
- Kentucky
- Maryland
- Michigan
- Minnesota
- Nevada
- New Mexico
- New York
- North Carolina
- Oregon
- Puerto Rico
- South Carolina
- Tennessee
- Utah
- Vermont
- Virginia
- Washington
- and Wyoming
The (CHO) must be qualified by training or experience to develop, review, and execute the school’s Chemical Hygiene Plan (NYSED, 2015; Roy, 2009). This training is not provided in teacher or administrator prep programs. This is especially true in science teacher preparation programs as science safety understanding is expected, not taught. There are few, if any, courses that prepare educators to serve in this position. OSHA’s laboratory standard does not describe the necessary training or experience needed to become a qualified Chemical Hygiene Officer. Instead, it is assumed that the appointed CHO will have the proper knowledge and understanding to safely guide their schools (Sigmann, 2018).
How are schools expected to provide a safe environment for their students and staff when they do not know the necessary qualifications for the person who will oversee safety and compliance in their science laboratories?
In an era of standards, college readiness, and accountability, science lab safety is often overlooked.
As an example the Morris Hills Regional District has taken a teacher’s duty and reassigned it from hallway supervision to saving the district time, money, and resources. The CHOs in the district have a strong background in laboratory chemistry and have the understanding to perform the job with excellence. During its journey, the district has become more compliant and safer. The district has set the standard for laboratory safety in New Jersey, helping other schools to develop protocols for Chemical Hygiene Officers in their schools. Administrative staffs are not prepared to support their teachers and students so they can provide a compliant and safe environment for their students.
