COUNTY OF ALBEMARLE
Draft Safer Chemical Management Procedure
Review and comment on the Safer Chemical Management Procedure, to be implemented under the County’s Environmental Management Policy
Messrs. Tucker, Foley, Davis, Shadman, Mullaney
Ms. Temple, Ms. Check, Ms. Carter
LEGAL REVIEW: Yes
June 4, 2008
ACTION: X INFORMATION:
In 2005, due to the County’s implementation of the Environmental Management Policy and to an increased stakeholder interest in the types of products routinely used by the County, the Building Services, General Services and Parks and Recreation Departments began testing and using safer alternatives to traditional synthetic cleaning products, pesticides and herbicides. They have significantly reduced the volume of synthetic products used on grounds and in facilities, and have replaced many of these products with green certified and organic alternatives. In addition, they have made significant strides toward implementing safer chemical management practices.
In June, 2007 the Board directed the County Executive to work with the Superintendent of Schools to create an internal County committee to develop a policy to further implement safer chemical management practices. Shortly thereafter, the Safer Chemical Committee (“SCC”) was formed and has held nine meetings since June 2007, developing the Safer Chemical Management Procedure (“Procedure”) (Attachment A). It is intended for the Procedure to become a component of and implemented under the County’s and Schools’ respective Environmental Management Policies. The implementation in the Schools is subject to direction by the School Board. It is scheduled for School Board consideration in July.
Goal 1. Enhance Quality of Life
Goal 2. Protect Natural Resources
The Procedure is a draft operational procedure intended to be implemented as a component of the County’s overall Environmental Management Policy, and promotes the use of non-chemical methods and safer product alternatives in day-to-day County operations and activities in lieu of using traditional, synthetic products. The Procedure advocates replacing traditional and synthetic chemicals with non-chemical methods and less-toxic product alternatives. Implementation of the Procedure shall be managed at the department level. In summary, the Procedure stipulates: 1) custodial products be certified by Green Seal™, Green Guard™ or Environmental Choice™ (See Attachment B), or meet outlined criteria; 2) high-touch surface areas (e.g. bathrooms, kitchens) be routinely sanitized or disinfected as deemed appropriate by the manager overseeing custodial operations, and that disinfection occur as soon as practicable in response to a blood-borne pathogen event or viral outbreak, or as directed by the Department of Health; 3) chemical usage be eliminated when practicable and feasible in grounds management; if chemicals must be used, then organic or biological-based alternatives be used, with 5 outlined exceptions; and 4) the County implement a formal integrated pest management (IPM) program by August 2008 for the management of indoor pests (See Attachment C). Additionally, sections 3(F) and 3(G) of the Procedure provide a waiver process for situations requiring the use of a product that does not meet the specifications and criteria of the Procedure, or for emergency situations. Lastly, the Procedure requires an annual audit to be conducted by the Environmental Compliance Managers, with a report of the annual audit being provided to the Board for their review and information.
Environmental, Health and Safety Benefits
Implementing the Procedure will support the County’s commitment to continual environmental improvement and to safety. For example, Green Seal™ requires that its products in undiluted form not be toxic to humans, not contain carcinogens, and not contain any ingredients known to cause reproductive toxicity or skin or eye irritations. Green Seal™ certified products cannot contain substances that contribute to the production of photochemical smog, tropospheric ozone, and must not exceed thresholds outlined in the Green Seal Standard (GS-37) for volatile organic content. Please see Attachment B for a more detailed description of green certified programs and their requirements.
The administration of routine disinfection was a point of much discussion, research, and some contention within the Committee. Both school division and local government buildings have historically been routinely disinfected, specifically “high touch” surface areas in restrooms and nurses’ stations in schools. Two committee members voiced concern regarding this practice, and suggested that the County routinely and thoroughly clean, but only disinfect in the case of a blood-borne pathogen incident, or in response to a viral outbreak such as MRSA. Their concern is based on the idea that employee and student exposure to the disinfecting chemical could result in short and/or long-term adverse health effects. The majority of the Committee, however, supports the continuation of routine disinfection in the aforementioned areas based on the following considerations: 1) several peer-reviewed journals (Attachment E) reveal health benefits from disinfection; 2) the products used in both school and local government buildings are diluted so that they have a Hazard Materials Identification System (HMIS) health rating of one (“Slight Hazard: Irritation or minor reversible injury possible) according to the Material Safety Data Sheet (MSDS); 3) the products are used according to the label, after hours, and with the appropriate personal protective equipment; and 4) the School Health Advisory Board recommends the continuation of routine disinfection. The School Division is researching the use of another disinfectant with an HMIS health rating of zero (“No Significant Risk to Health”). The majority of the Committee recommends the continuation of routine disinfection allowed at the discretion of custodial supervisor, and as written in the draft Procedure as Option “A”, whereas two Committee members support Option “B” (See Attachment A, pg. 2).
The Committee believes that complete implementation of the Procedure can occur by January 1st, 2009. This approximate six-month time span would allow the various departments to phase out existing products that do not meet the Procedure specifications. It is important to note that the affected departments are currently only procuring products that meet the standards outlined in the Procedure. In addition, departments have in large part already made many product substitutions and have begun implementing some non-chemical-using practices.
Since the Committee last met, the County Attorney’s Office has reviewed the draft procedure, making clarification and process recommendations, but no substantive changes.
The budgetary impacts of implementing the Procedure are categorized into ”Local Government” and “School Division” separately, and are further broken down into the functional areas of grounds management, custodial operations and Integrated Pest Management (IPM). Please see Attachment D for a more detailed budget estimate. A budget range is presented with the low end representing the use of a traditional pre-emergent in lieu of corn gluten and continued use by custodial departments of a disinfectant with a health rating of 1. The high end represents the use of corn gluten as a pre-emergent and a switch to a disinfectant with a health rating of 0. Further research is required in order to determine the effectiveness of corn gluten as a pre-emergent, and the costs associated with the two health ratings for disinfectants are presented to illustrate the cost difference in using a product with very low toxicity as compared with a completely non-toxic option. For purposes of estimating the 5-year budget impact, a figure of 3% has been added to each year to account for inflation. The estimated budget impacts below include costs “above and beyond” existing operational budgets required to operate these programs. While there are clearly increases expected in hard costs in order to implement the Procedure, the “soft” benefits in the areas of environmental, health and safety protection should be significantly weighed.
The Committee estimates that Local Government would need to spend between $24,572 and $49,398 in FY09 to implement the Procedure. The 5-year budget range for FY09-FY13 is estimated to be $126,220 - $258,061.
The Committee estimates that the School Division would need to spend between $72,669 and $100,430 in FY09 in order to implement the Procedure. The 5-year budget range for FY09-FY13 is estimated to be $352,409 - $465,693.
Staff requests that the Board review the draft Procedure and provide comments to the SCC. Once the Procedure is finalized it will become a component of and implemented as part of the County’s Environmental Management Policy.
Attachment A – Draft Safer Chemical Management Procedure (SOP-CHEM-01)
Attachment B – Green Seal, Green Guard, and Environmental Choice Information
Attachment C – Integrated Pest Management (IPM) Information
Attachment D – Budget Impacts
Attachment E – A Summary of Peer-Reviewed Journals and Staff Research on Disinfection
Return to regular agenda