Lab Decommissioning Q&A: Industry Expert, Craig Sasse
Below, you can find all your burning lab decommissioning questions answered by industry expert, Craig Sasse. For more information on lab decommissionings, contact us, or check out our downloadable lab decommissioning checklist in the link below.
How long should a decommissioning take?
It can vary. For a one room area, it could be a matter of several days to likely no more than a week or a week and a half. On a multi-building facility, it may take several months. Generally you'd like to start planning not less than 45 to 90 days prior. That's putting things in a bit of a crunch to make sure people or vendors are available to provide quotes and execute the work in a timely fashion and give yourself some breathing room to manage the logistics. Many times these processes start a year prior to moves or decommissioning of space.
How much does a lab decommissioning with Triumvirate cost?
The costs are generally site specific. Are you dealing with 1000 feet or 10,000 feet? What are the materials being used? Do you have materials that require disposal as part of it? Are there specific means and methods required for decontamination? What are your lease obligations? Is it essentially a brief letter or do you require a decommissioning plan to be reviewed prior? Do you require a decommissioning report at the conclusion?
What is needed to decontaminate a lab to be changed to a food lab?
It depends upon the work that has been conducted there before. The future intended use is always a concern. For instance if you had large quantities of metals being managed as pigments, dyes or as part of research and your changing that use for food production or food research, you'll have quite a bit of concern about making sure your surfaces and systems are adequately clean. A scenario in that sense would likely involve some laboratory analytics of wipe samples from surfaces for particular targeted contaminants of concern. If you had a very astringent procedure prior where you're handling materials in a clean fashion, you may not have such a concern with the shift to food management.
The level of effort could vary between the previous use and the intended use. Do you know if your lab space is continued to be used as lab space or is it going to be converted into child care or health care where you would have pretty particular sensitive population occupying that space. It may raise a concern. If you know it's going to be demolished and rise as part of new construction activities, the level of effort may not be as great.
What is the best lease language to have for decommissioning? Is there correct requirement to have the decommissioning certified by a practicing industrial hygienist? What other language do you recommend?
That lease language has changed dramatically over the past three to five years. In many times, old leases have unsophisticated language. The current leases are typically looking at a performance standard associated with the ANSI standard. It presents a process but it doesn't necessarily indicate the actual number that needs to be achieved for any particular material. A certification from a certified industrial hygienist who is knowledgeable and active is important for these documents.
I'm not an attorney but I have looked at quite a few of lease obligations and saw performance standards that are not overly specific but talk about performance standard. Certifications by professionals are important. You don't want to have a lease that's boxing you in too much and limiting the activities or being too prescriptive.
What cleaning methods do you use to wipe down a chemistry lab, a biology lab or mixed use lab space
Generally we're using industrial detergents for chemical decontamination, either DZ7 or just industrial degreasers. It depends upon the materials used and it's always identified specifically to materials used. Are you using an appropriate disinfectant for biological used areas, which is going to be sufficient to essentially kill the biologics that were may be present. It varies.
You would want to make sure and verify that the cleaning method is appropriate for each area where it's going to be used. In many times, there's metal decontamination also that would require the use of specific process or it could involve mercury decontamination or other esoteric materials that have specific procedures that are required. That's where you have to really engage with more specific scenario and with someone who is knowledgeable on those issues.
Regarding Triumvirate's services, do clients need to employ their own CIH or does Triumvirate provide CIH service for decommissioning?
At Triumvirate, we do have a Certified Industrial Hygienist. He carries a certification and has an obligation to maintain that license. We do provide that service here at Triumvirate. We also perform decontamination as part of larger decommissioning projects where other CIH or other organizations are engaged to verify and assess conditions.
When do you suggest decontaminating an area used for EtBr?
We've encountered that residual ethidium bromide. What we have is this. I’m trying to recall the specifics, which we utilized. If it's not extensive and it's light, depending upon the surface, how porous it is. Even a simple wash can be sufficient as long you don't have a lot of permeation and penetration into the substrate.
We have had extensive areas where we have encountered that contamination. I don't recall offhand but if you can provide your e-mail, we can get you that particular cleaner that we utilized. That will be one of those areas where you want to be able to define what those chemicals and what the particular concerns are at your facility to be able to make sure that you're utilizing appropriate means and methods.
To make a lab inactive is there any documentation needed?
To my knowledge, there's no particular document that's required. For your facility and for allowing unrestricted use in that space, it's probably a good idea to understand and document what conditions are. For instance if you're closing it, locking the doors and you're not allowing people into that space, it could sit dormant. If it's going to be utilized for office space or contractors and workers are going to enter that space to perform other activities, it’s probably a good idea to understand what the conditions are in that laboratory space. If it's going to be reused for similar lab space, it's essentially a transition. What's the next intended use of the lab? I guess this is one of the questions that need to be answered to guide you.
When providing a space closure and report; can you give examples of people who can be considered as qualified individuals?
Generally it's the Certified Industrial Hygienist. Sometimes it can be a professional engineer or other times it may be someone who has a particular expertise for instance an RSO, dealing with radioactive material management or other professionals specific to processes that are being conducted. Other times, it may be a particular individual who has knowledge about a potent compound or it may be an internal resource from a particular researcher who has knowledge for a particular piece of equipment or space. It varies but generally the backstop is a Certified Industrial Hygienist. Many times that CIH will rely upon other professionals to provide guidance for particular materials.
What is needed to document a lab decommissioning after lab is closed due to acts of nature, for example, hurricanes?
If chemicals have been spilled to the environment through a catastrophic event, there could be release reporting to regulatory agencies that may be required. In flooding for instance, if you have chemicals that were washed out of the facility or the facility is completely flattened, it depends on how much material may have been stored? What was being stored?
Generally the driver would be what kind of liability may have been triggered. It may be either an analysis to a phase one property transfer to look at the environment and the surrounding area. If it was, for instance, a flooding event, you may need to establish what contaminate residuals may have been present on interior surfaces and assess for those particular materials on surfaces. It would be, let's say at a minimum, we'd want to understand the contaminant, assess for them and document their absence on surfaces.
How do you clean a fume hood?
In a fume hood, primarily you are looking at what materials were handled within it. Hopefully, there's a reasonable understanding of what was being conducted. What the research was and the materials being handled in the fume hood. For instance if you have just organic solvents, the expectation would be that there isn't high probability that you'll have contaminants present. If you're managing metal powders, chromium pigments, cadmium or metals of that nature, you may be conducting wiped samples and laboratory analysis looking for those particular materials. You need to understand if residuals are present.
In our experience, we've seen generally pH high or low and presence of oxidizers, which are generally limited to the throat nearest to the top of the fume hood essentially. When it is detected in that area, it is generally the worst case area. When you assessed further downstream of the fume hood, usually after elbows or the phoenix valve, the contamination quickly diminishes.
We have had systems were it was throughout the duct work. The contamination was throughout the duct work and into the fan housing and also resulted in contamination of HVAC systems. Again it's specific to your organization and facility and hopefully you have well-designed and thoughtful engineering controls that can manage these materials appropriately. Unfortunately, it depends on what was being conducted in that particular fume hood.
For more information on lab decontaminating practices, check out our lab decontamination checklist in the link below.