is your laboratory liable? reduce liability with lab decommissioning
DESCRIPTION
This presentation details how to reduce liability through lab decommissioning. The presentation will teach you what factors to look out for when considering your liability as it applies to a decommissioning as well as best practices and the steps you need to take to assure your organization is protected.TRANSCRIPT
Laboratory
Decommissioning
Is your laboratory clean?
This webinar will educate attendees on liability
drivers and issues associated with
decommissioning projects.
1. All lines are muted, use the chat panel for tech issues.
2. Q&A at the end. Type into the “questions” section of
your chat pane.
3. Unanswered questions will be answered via email
after the webinar.
4. Webinar recording and slides will be emailed to you
later today.
Share With the Audience
Meet Your Presenter• Craig Sasse, LSP
• Technical Manager
• Craig Sasse has been employed at Triumvirate for over 6 years and has worked as an environment consultant for over 18 years. He currently specializes in performing environmental consulting to assess and manage environmental liability.
Our Key Message
Thoughtful
decommissioning can
manage potential
liability.
How many of you have upcoming
plans for a laboratory move,
closure, or renovation?
What Will You Learn?
How to begin planning for changes in your laboratory.
Questions and information to guide a good decommissioning.
How clean is clean?
What are industry drivers and expectations?
This will help manage…
• Relocations
• Internal moves
• Renovations
• Closure
• Owned vs. non-owned
spaces
Where to start?Schedule and Logistics…
Due Diligence. Unused
chemical & equipment disposal.
Stop research. Movers, riggers, venders.
Assessment. Remediation.
Assess for
remaining EH&S
concerns. Finalize closure.
Decommissioning report
Planning and Scheduling
• Identify all stakeholders
• Identify obligations in lease agreement and in organization
• Financing
• Site specific laboratory information and investigation
Planning and Scheduling
• Coordinate the end of research,
• Equipment handling
• Research material storage needs
• Decontamination logistics
• Vacancy of space
• Licensing, such as for radioactive materials, >45+
days for processing
Considering Lease Obligations
and Institutional Risk• Lease obligations are typically vague• No set regulatory guidance
• Uncertainly if space is “clean”
• Claims when vacating space
• Unexpected costs
• Residual chemicals (surfaces, drains, HVAC, etc.)
• Contractors and worker exposures
• Poor housekeeping
• Unknown or poorly documented decontamination
The American National
Standard/AIHA Z9.11–2008
• Useful framework and process for
effectively performing laboratory
decommissioning.
• Methods are scalable and applicable from
initial planning through reporting.
• Presents methods to document and verify
decommissioning by characterizing
acceptable risk.
Decommissioning ProcessA reports limit potential liability when occupying, leasing or leaving space.
Due Diligence
Interviews
License & Permit
Management
Materials, Plans and Diagrams
Decommissioning
Define Areas and Assess
Equipment, Surfaces,
Infrastructure
Means & Methods
Documentation
Assessment Documentation
Statement of “Acceptable
Level of Risk”
Signed by “Qualified Individual”
What is in your laboratory?
• Inspection
• Interviews
• Permits and Licenses
• Chemical Inventory
• Landlord/Tenant Records
• Incident Reports
• Waste Management
• Flammable Storage Permit
• DEA Controlled Substances Permits
• RCRA Generator Information
• Radioactive Materials License
• Ionizing Radiation Source Registration
• Wastewater Discharge Permit
• Laboratory Animal Use Permits
• rDNA Permits
• Biological Agents Permits
• Potent Compounds
Laboratory Assessment and
Decontamination• Bench Tops, Drawers, Cabinets
• Floors and Walls
• Chemical Storage Areas
• Cold Rooms
• Animal Care Area
• Rad. Use Areas
• BL1, BL2, and BL3 Labs
• Plumbing
• Wastewater System
• Fume Hood Ductwork
• Lab Equipment – BSCs
Remediation
• Consider possibility of deviations
• Hg, metals, EtBr, azides, radioactive, HF, perchlorates,
pH, potent compounds, etc.
• Decontamination procedures are clear and
appropriate
• Discovery of hidden collection of chemicals
• Secure entry pre- and post-decontamination
• Mark decontaminated rooms and equipment
Remediation
• Lab ventilation - local exhaust and
fume hoods
• BSCs – certified
• Sink p-traps
• Wastewater systems – last step
• Decontamination waste
Closure and Reporting
• Visual inspections and photographic documentation
• Layout and before/after pictures
• Document the cleaning protocols
• Assessment sampling documentation with COCs
• Waste disposal documents
• Review of plan requirements, deviations, and QA/QC
• Statement of “Acceptable Level of Risk”
• Signed by “Qualified Individual”
Our Key Message
Thoughtful
decommissioning can
manage potential
liability.
Action Plan
Start with the end in mind.
Schedule, but be flexible.
Define lease and decommissioning obligations.
Licenses and equipment management…
QUESTIONS?
Thank You For Attending!You will receive:
• A recording of this presentation
and copy of this presentation
• A link to a short survey
• A gift to help you get started with
your decommissioning project
Attend other events:
• www.triumvirate.com/training/eve
nts