Safe Methods of Use: An Approach to Compliance
There are many schools and ways of handling the approach to documentation of Safe Practice. This note is chiefly to assist new or less experienced technicians find their way through what might seem to be a minefield but also may help other technicians examine what is current practice in their school and perhaps help in tidying up some lax practices. Certainly consult with your Head of Department as you work through this subject. A possible area of conflict with teachers is where the teacher likes to do practicals without giving sufficient notice for you to prepare everything, there is no one easy answer to dealing with such situations and some tact may be required especially if it is the HoD that is the main culprit.
Worksafe states that SMUs as such are not directly required under the regulations.
However, Regulation 18.4 requires that the persons handling a hazardous substance in a laboratory must be provided with the following information:
- Procedures to prevent the contamination of any equipment, clothing or part of the laboratory
- Procedures to ensure persons in the laboratory are not exposed to the substance
- Disposal requirements
- Actions required in the event of an accident or accidental exposure.
The Safe Method of Use (SMU) appears to address each of these matters.
If a SMU is not available a teacher may need to have up to 4 documents open during the practical to satisfy the Worksafe Requirements.
STANZ is of the view that it is Best Practice to have a written SMU for each procedure likely to be performed in a school which involves:
- Chemicals with any HASNO (Hazardous Substances and New Organisms) codes as defined by EPA (Environmental Protection Agency).
- Sharp instruments,
- Mains powered electrical items.
While noting that the ultimate responsibility rests with the Teacher conducting or supervising the practical Activity we realise that the technician in the school may be the person with the best grasp of the hazards associated with the activity and therefore the best person to guide the initial development of the individual SMU’s.
We recommend that as far as possible Technicians and Teachers should use an Approved Template similar to the Suggested Template provided by Koha Education which is available with appropriate attribution (footnote or similar).
This advice is intended for technicians at schools where there is not a previously established set of SMU’s for Standard experiments. It is not compulsory to follow this route if your School’s practice meets the Worksafe requirements by a different method.
Note that the responsibility lies with the teacher/HoD. Technicians are employed to assist and should not be getting stressed out about SMU paperwork unless supported by your HoD etc. to assist in this AND you feel competent to do so.
To assist technicians a number of SMU’s on the Suggested format are available on the STANZ Website, though STANZ cannot accept responsibility for any errors these may contain.
Here is a possible sequence of steps involved in preparing a SMU for school use that STANZ considers to be BEST PRACTICE; it is NOT compulsory to follow this.
- Prepare a Safety Data Sheet (SDS) summary for any chemical with HASNO codes; this will generally be a summary of the manufacturer’s supplied SDS which hopefully will be less than two pages long (most schools will have these already on file).
- Prepare a CHEMICAL SMU from the document in 1; at least checking the current HASNO codes from the EPA Website.
- Ensure the following are covered:
- Significant hazards as identified by the HASNO Codes.
- First aid actions.
- Disposal requirements.
In practice it might be possible to reduce the actual number of these required as for example one Chemical SDS could cover all 0.1M solutions of Copper compounds except the nitrate (nitrates usually require their own SDS).
These Chemical SMUs might be laminated and go out with the chemical each time the chemical is supplied (may need several copies of some for dilute acids etc.). Projecting an electronic copy is the practice at some schools the teacher can highlight particular points as necessary.
This document may suffice for experienced teachers with a different procedure provided they are doing the Risk Assessment in a way that can be recorded and checked.
- A PROCEDURAL SMU is prepared for each practical activity based on the Chemical SMU. This is where the teacher’s input is necessary. The Procedural SMU will contain
- Equipment list.
- The method; at least a reference to a textbook or “Google doc” etc.
- (Optional) Science summary where this might help the Biology teacher run a Chemistry practical.
- Clean up and disposal procedures.
- A Section of four boxes on the other side of the page suggest these are colour coded so the teacher knows where to find the information. see examples on STANZ Website
- Significant Hazards.
- Mitigation measures and actions.
- First aid actions include phone numbers.
- Disposal procedures and actions if a spill occurs (may need to distinguish between a minor spill that the teacher can probably handle unaided, and a major spill which will require extra help and may entail evacuation of the laboratory.)
A draft Procedural SMU may be prepared by a technician who feels able to do this else a teacher or group of teachers prepare the document using the Chemical SMU, their previous experiences of performing the practical, checking the student instructions are as fool proof as possible. The document is peer reviewed, printed, laminated etc. according to school policy. The document is reviewed from time to time in the light of past experience, reclassification of chemicals and similar.
These SMU’s don’t necessarily need customising. It is a matter of whether these are being used as the sole risk assessment tool or just a procedural tool. The Code of Practice[i] does not specifically state that the SMU must relate to each individual class of students; however the Health and Safety at Work Act requires the management of risk. While not all chemical HANO Classes require a SMU e.g. E.g 6.1E and 9.2D it would seem to be good practice to prepare one for consistency, teachers will get used to looking for relevant information and will find it in the same place if the template is used.
At some schools the SMU’s may have become a bit of an amalgamation of laboratory procedure, safety data sheet, and risk assessment. Perhaps it is better to use the individual components at such schools? Possibly the experience of the teacher will guide the technician in how much material to make available for the teacher. By Years 12 and 13 the school may decide to set less stringent requirements. However Disposal may be far more relevant as less common chemicals are used.
- Now the teacher is required to perform a Risk Assessment each time before carrying out the practical. This is where they will take into account: the individual situation which would include at least the points below:
- The need to go through the safety procedures before the chemical is dispensed. (Consider how the chemical will be dispensed; clear clean- up procedures first aid actions).
- Any known health conditions of the students.
- The mood of the class at the time – time of day, what the class were doing just before the lesson.
- Is a demonstration a better / safer way of making the teaching point?
- Review the safety equipment in the laboratory, is it correctly positioned, spill kits topped up.
- This Customisation is required for each class, each time the practical is performed we recommend that the documentation contains reference to the customisation that the individual teacher has made in light of the Risk Assessment they have carried out. A safety briefing to the class before any equipment is issued is an integral part of the Assessment so the students are pre- warned of possible hazardous situations that might arise. The initial introduction to the Laboratory (early each year) will have identified the location of safety equipment and so on for that teaching space.
The above is based on current guidelines as set down by the COP but these may change with the introduction of the new SAFETY AND SCIENCE document.
[i] References to the Code of Practice will be updated once the new Safety and Science is gazetted.