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Home > Rules & Legislation > Letters from the Commissioner > Informational Letters > Letter 39




TO:                    Superintendents of Schools

FROM:              Susan A. Gendron, Commissioner

DATE:               October 18, 2006

SUBJECT:        Chemicals in Schools: Due Date for Inventories and Update on Management

The Department is providing information relative to chemicals in schools which has been a topic of discussion for the past several years.   The Department of Education regulates chemicals in schools under Chapter 161, “Purchase and Storage of Hazardous Chemicals”, and several other agencies regulate chemicals as well.   Last year, the timelines for compliance with certain rules regarding chemicals in public schools were provided in Administrative Letter #33, dated June 9, 2005.   The Department intends to continue to assist schools with compliance regarding this very important health and safety issue. 

Inventory Forms: The Department is requiring that all public schools electronically submit chemical inventories to the Department by November 15th, 2006, to comply with the legislative mandate and already existing rules.   Please ensure that your middle and high schools with laboratories are inventoried for hazardous chemicals using the form provided on Department of Education and Department of Environmental Protection websites, Lab Chemical Inventory Form. This is the same form that was used last year and it should be used for 2006.  The electronic inventory should be submitted to Ed Antz at: .    In all likelihood, the inventory form will change for 2007 to include other chemicals (art, photo, custodial, etc.) and to address some concerns regarding the present form as the Department continues to improve processes and procedures.

Update on Management: The Department spent considerable time last year in assisting schools with better chemical management.  Specifically, inventories were collected for lab chemicals and these inventories showed that 44 % of middle and high schools with chemistry programs had chemicals with unacceptable risk, according to DEP guidelines.  The Department informed those schools that the chemicals had high risk and then solicited bids for a coordinated statewide disposal effort for those chemicals from hazardous waste contractors.  The prices received were favorable (nearly a 50% reduction from regular rates) and nearly 100 schools signed up for the summer collection program.  Also, the Department presented a status report, drafted by a stakeholders group, to the Legislature recommending that the Department add a position to better assist SAUs with chemical management and that SAUs (or regions of SAUs) hire or acquire services to do the same.  The last legislative session was a short one, so no action was taken with respect to those recommendations.  The Department will request a full-time position this session to help school administrative units better manage chemicals in our public school buildings.  Lastly, the Department will revise Chapter 161 this Fall to update the rules and encourage/mandate the use of less hazardous chemicals (“going green”), whenever feasible.

It is important that schools develop, implement, and make an on-going commitment to programs that promote the safe use, handling, storage, and disposal of chemicals in middle and high schools, which are ultimately under your control.

Please contact Ed Antz, at 624-6886, or e-mail him, at, with questions or concerns.   Thank you and I look forward to working with you as we deal more effectively with chemicals in our schools.