Laboratory Close-out Procedure

Table of Content

Overview and Applicability

Principal Investigator Responsibilities

Time line:

Laboratory Close-out checklist

Contact: Lab Close-out Coordinator, call 335-8501 or ehs-contact@uiowa.edu (link sends e-mail)

Forms:

Overview

All laboratory rooms, chemical storage areas, or areas where hazardous equipment or materials are used or stored need to be cleared by staff from the Environmental Health & Safety Office (EHS) before being assigned to new occupants or scheduled for renovation activities. The Principal Investigator (PI) and the PI’s department are responsible for ensuring that the space is cleared of hazards prior to the transfer to the next occupant, and that all biological, chemical and radiological materials are removed prior to vacating the space. All remaining equipment, including biosafety cabinets and storage cabinets, must be properly decontaminated, as well as all surfaces, such as counters, drawers, floors, fume hoods, etc. In addition, all unwanted lab equipment, supplies, electronics, and furniture are also to be removed following proper cleaning or decontamination.

Applicability

The following procedures are to be followed whenever laboratories, chemical storage areas, or areas where hazardous equipment or materials have been used will be vacated, whether due to a PI leaving the institution, relocating or terminating laboratory research activities, or a renovation project is scheduled. Note that this also applies to any hazardous materials that belong to the PI who is leaving, but are stored in a shared-use or storage space (e.g., flammable liquid storage cabinets, refrigerators, cold rooms, freezers, or stock rooms) that belongs to the department or another PI.

EHS should be notified three months prior to the anticipated departure. Once notified, EHS will provide additional guidance and assistance during a pre-close-out inspection that is intended to identify any safety issues that may need to be addressed.  

Principal Investigator (PI) Responsibilities

As the PI, you are responsible for the safe operation of your laboratory.  This includes leaving these facilities in a safe condition when you vacate the premises. This guideline outlines your responsibilities in the Laboratory Close-Out Process.
The close-out process should be divided into three stages. The time frame referenced below can be reduced, if you are acting on short notice.

  • Three months before you move
  • One month before you move
  • At moving time

Time Line:

Three Months Before Moving Out

Review and complete a Lab Close-out Notification and submit it to the EHS Lab Close-out Coordinator by mail (100 EHS), email (ehs-contact@uiowa.edu (link sends e-mail)) or fax (335-7564). In addition provide a copy to your Department Administrator.

  1. Upon receipt of your close-out notice, the EHS Lab Close-out Coordinator will accompany you and your department’s administrative representative or other responsible party in a tour of your laboratory.
  2. The EHS Lab Close-out Coordinator will then help you address any safety issues identified during the lab tour. As a team we will jointly develop a close-out plan that is customized to your lab. We will agree upon target dates for critical process steps.
  3. Review the following close-out checklist items. General points are covered to help you safely and efficiently vacate your lab spaces. Where needed, more consultation will be provided by EHS.

Thirty Days Before You Move

  1. Review your lab space to be sure all hazardous and unknown materials have been identified and no new ones have been created while preparing to vacate the space. It is productive to repeat this step of the process, because identifying and disposing of “unknowns” is a major cost in laboratory close-outs.
  2. Seek assistance from the EHS Lab Close-out Coordinator in planning the safe transfer to your new lab and removal of any high hazard materials (violently reactive chemicals, toxic gases, etc., as identified during the chemical disposal process).
  3. Follow-up on the status of time-critical close-out steps such as radioactive and chemical waste collection, special equipment moving arrangements, posting of your new laboratory for biological or radioactive materials, etc.
  4. If there were previous occupants in your new lab space, visit that space to ensure that no equipment or materials remain.
  5. Verify that all modifications in your new space will be completed before your move.
  6. No equipment used with radioactive materials should be moved if external removable contamination is present. You and your radiation workers can perform wipe and meter surveys to assure this for smaller items. EHS Radiation Safety staff will provide this service for major pieces of equipment including freezers and refrigerators. Contact the EHS Lab Close-out Coordinator to arrange this service.

At Moving time

  1. Although staff that works with hazardous materials should know how to clean up small hazardous materials spills, it is recommended that items are moved during normal business hours so that others are available to assist in the event of a spill or accident.  In some departments/buildings, Building Emergency Teams (BETs) have been established that may be able to advise in such situations.  However, note that team availability will vary, so it is advisable to contact the BET leader to inform him/her of the planned moved so the team can act accordingly.
  2. Provide secondary containment for biohazardous materials, chemicals, and radioactive materials during transport (even when moving only a short distance).
  3. Do not transport hazardous materials without someone present who is capable in providing assistance.
  4. Never transport hazardous materials on public roads, unless the materials are packaged in compliance with DOT regulations, e.g., packaged by a person trained for this purpose, in proper containers that are correctly labeled, etc.
  5. Wear appropriate personal protective equipment for the materials being handled (e.g., safety glasses or goggles, lab coat, gloves, closed-toe shoes, etc.)
  6. Have boxes, plastic bags and containers for broken glass, etc., ready and available before you begin.
  7. Post any required warning signs (radioactive materials, biohazard signs, etc.) in your new lab location.
  8. Review the location of safety showers, eyewashes, fire extinguishers, and all available means of exit from the laboratories and the building.
  9. Review your old lab space. Do any materials remain in the space that need to be removed?

Final Steps

  1. Notify the EHS Lab Close-out Coordinator that the lab space is ready for a close-out survey by signing and sending the Lab Close-out Certification (either fax to 5-7564 or scan and email to ehs-contact@uiowa.edu (link sends e-mail).
  2. The EHS Lab Close-out Coordinator will meet and review the Lab Close-out Certification form with the PI (or representative). If the form has been satisfactorily completed, EHS staff will also sign the form and provide a copy to the department administrator.
  3. After all forms have been completed, the laboratory space will be considered clear of hazardous materials. The completed and signed Lab Close-out Certification form and any Equipment Clearance Record forms will be kept on file in EHS.

Laboratory Close-out Checklist/Items

  • Assess any biological materials you have (e.g., recombinant DNA materials, microorganisms, cells and cell lines, tissues, organs, body fluids, and biologically-derived or –contaminated media) and determine which materials will be transferred to your new laboratory or to another UI investigator. Dispose of the remaining materials, per UI disposal guidelines, e.g., autoclaving and disposing in biohazardous waste containers.
  • Select Agents: Certain biological material and toxins considered Select Agents (see 42 CRF 73.4 and 73.5) cannot be transferred to other university personnel or transported off campus without prior approval from EHS, the Biological Safety Officer, the department of Health and Human Services, and/or the United States Department of Agriculture.
  • Infectious Waste: All waste material meeting the definition of biohazard waste must be managed following the University’s Biohazard Waste Guidelines. Contact EHS at 5-8501 to obtain additional biohazardous waste tub labels. Unless in their original packaging, place all sharps into a sharps container, which then needs to be placed inside a biohazard waste tub.
  • Animal and Human Tissues: Generally, due to potential risks and numerous extenuating circumstances, please contact Environmental Safety staff for guidance prior to the disposal of any animal or human tissue. Call 335-8501.
  • Toxins: Toxins must be handled on a case by case basis. Contact EHS Biological Safety staff for instructions. Call 335-8501.
  • Chemicals can be transferred to other laboratories within the department, or other university departments, with the acknowledgement of EHS and updating the laboratory chemical inventory of the recipient’s location.
  • Chemicals to be disposed of through EHS must be properly containerized and labeled. Labels for this purpose can be found on the EHS website. Proper labeling requires the chemical name of each chemical to be listed on the container. If a container has a mixture of chemicals, each chemical must be listed with its relative percentage. Chemical formulas, abbreviations, or trade names are not acceptable. For any commercial chemical product that is not labeled with its chemical name, a Safety Data Sheet must be requested from the company and supplied to EHS with the chemical.
  • If you have unknown chemicals or high hazard materials, such as peroxidized ethers or violently reactive chemicals, special handling may be required. There may be a fee charged for identification, stabilization and disposal of such substances.
  • Transporting hazardous chemicals, biohazardous substances or radioactive material
  • If transporting containers of biological materials, chemicals, or radioactive materials to another location on campus, place the container in a secondary container that is capable of holding the contents if the original container breaks.
    • Containers must be in good condition, tightly sealed and labeled. An unlabeled container is considered an unknown and cannot be transported.
    • Liquids should be packed in vermiculite or other absorbents such as spill pads, and placed in containers that will not leak if tipped over.
    • Beakers, flasks, etc., must be empty.
    • If transporting materials off campus, you must comply with applicable U.S. Department of Transportation (DOT) regulations. This may require obtaining the services of a specialized contract hazardous materials transportation service.
    • Staff must not transport hazardous materials in personal vehicles; use a University vehicle, if applicable.
    • Gas cylinders may be moved using a handcart equipped with a strap. Cylinders must be securely strapped for transport, regulators removed and cylinder caps replaced.
  • Gas cylinders with a Praxair label attached must be returned to Praxair; call 1-800-283-8348. If a Praxair label is not affixed to the cylinder, please contact the Supply Chain Coordinator at 384-4045.
  • Tubing and regulators that are connected to corrosive or hazardous compressed gas cylinders should be detached using safe procedures such as purging and venting to a hood or ventilated area. Contact the Lab Close-out Coordinator for assistance or directions on this process
  • EHS will pick up lecture bottles; use the online chemical waste pickup request form.
  • Clean and decontaminate all spaces that are being vacated including removing all bench paper and contents of cabinets and any equipment that will be left behind, including shared equipment.
  • Turn off and disconnect all equipment from power supplies.
  • If you have a DEA controlled substance, it must be managed under the requirements of your registration. If you no longer wish to keep the controlled substances in your possession, contact the Iowa Board of Pharmacy Examiners to ensure the substances are properly managed. The IBPE number is 319-929-6067.
  • When you have chemical waste ready for pickup, complete an online chemical waste pickup form: http://ehs.research.uiowa.edu/chemical-waste-pickup-request.
  • Notify EHS of any equipment or procedures that may have contributed to hazardous chemical residues remaining on surfaces (e.g., perchloric acid).
  • Notify EHS of any equipment or areas that cannot be fully decontaminated (e.g., material potentially containing asbestos).
  • If you are an authorized user on a radiation protocol, inform the Radiation Safety Officer (RSO), who will assist in the following:
    • Terminate your radioactive materials protocols
    • Ensure laboratory facilities and equipment are free of contamination
    • Ensure all radioactive materials, radioactive waste, and potentially contaminated equipment or surfaces are properly labeled
    • Dispose of radioactive waste by completing an online request at: http://ehs.research.uiowa.edu/radioactive-waste-pickup-request
    • If the authorized user is leaving the university, return dosimeters, and any borrowed equipment, such as survey meters, radiation protection equipment, and shielding devices to the Radiation Safety Office.
    • Inform the RSO if any radioactive material or survey meter will be transferred to another Authorized User, another location on campus, or to another licensed institution
    • Schedule a final laboratory radiation survey (and bioassay, if appropriate) with the Radiation Safety Office.
  • Empty everything from laboratory storage areas, e.g., refrigerators, freezers, cupboards, etc. and dispose of hazardous materials according to previously-listed instructions.
  • Laboratory equipment or laboratory surfaces that are potentially contaminated with a hazardous material must be decontaminated before that equipment can be removed from the lab. Proper decontamination requires the wipe down of all contaminated surfaces with a cleaning agent capable of removing the contaminant. If equipment contains a hazardous material integral to the operation of that piece of equipment (i.e., oil, mercury and asbestos), the hazardous material must be removed prior to disposal. Some examples of internal parts that may contain hazardous materials are mercury switches, mercury thermometers, transformers, oil pumps, and compressors.

Laboratory Equipment Disposal/Removal:

  • The University of Iowa’s Surplus Stores manages all equipment for disposal or resale. It is the responsibility of the equipment’s owner (the PI) to ensure all hazardous materials have been removed prior to it being released to Surplus Stores. This includes X-ray machines and lasers. Contact EHS for guidance on disposal of these specific items.
  • If you have laboratory equipment that needs to be picked up by Surplus Stores, first notify the EHS Lab Close-out Coordinator of this by completing an Equipment Clearance Record Form and either fax (5-7564) or email the form to: ehs-contact@uiowa.edu (link sends e-mail). As noted on the form, if the equipment has been used with biological, chemical or radioactive materials, it must be decontaminated first. An EHS staff member will assess the status of the decontamination and, if it is deemed appropriately decontaminated, will maintain the signed form and inform Surplus Stores, as needed.