Required Plans and Permits for Starting a New Laboratory

A lab move, unlike other operations, demands a thorough understanding of both hazardous materials and transportation regulations. Everything must comply with EPA, OSHA, DOT, and IATA requirements, as well as any other regulatory agencies involved. It is recommended to inquire with your local regulatory agencies about what is required of your lab throughout the transition. Hiring a consultant to advise on the project's logistics is another way to ensure your operations at your new laboratory stay on track. 

Municipality Dependent Lab Permits

• Recombinant DNA (rDNA) – If you or your company does any work using or manipulating recombinant DNA in the city of Cambridge, you may require an rDNA permit. The Cambridge Recombinant DNA Technology Ordinance, which is overseen by the Cambridge Biosafety Committee, establishes regulation of university and commercial facilities that participate in rDNA research (CBC). The National Institute of Health (NIH) Guidelines for Research Involving DNA Molecules are the foundation of Cambridge's ordinance.
• Compressed Gas Storage – Permits may be required by your local Fire Code, to store, transport on site, dispense, use, or handle compressed gases in excess of certain quantities. Be sure to check with your local fire department or environmental agency to confirm if this is required for your facility.

• Wastewater Discharge – A permit may be required if you discharge pollutants into a municipal storm sewage system, depending on the pollutant. It is recommended to inquire with your state EPA agency to be sure of your obligations.

OSHA-Required Lab Plans and Permits

• Flammable Liquid Storage – If a new facility will be utilizing and transporting flammable substances, an operational permit is needed. It's important to remember that each county has its own set of permit requirements.
• Contingency Plan – Large quantity generators (LQGs) of hazardous waste require contingency plans. Organizations use contingency plans to identify possible sources of risk and build strategies so these hazards can be avoided. Various agencies, including OSHA and local regulatory agencies, require the development of these plans.
• Emergency Action Plan – These plans are to provide direction to facility administrators and emergency responders should an emergency occur. These plans should detail the response to various types of emergencies.
• Chemical Hygiene Plan – This is a written program that outlines the rules, processes, and responsibilities for protecting employees from the health risks posed by hazardous chemicals handled in the workplace.
• Exposure Control Plan – An Exposure Control Plan is intended to be used to address inquiries about bloodborne pathogens and ensure that exposure control measures are in place. OSHA Bloodborne Pathogens Standard requires you to prepare an Exposure Control Plan if you expect to be exposed to blood or other bodily fluids in the lab.
• Hazard Communication *NOT HAZARDOUS COMMUNICATION* – OSHA requires employers to develop and implement a documented hazard communication plan. This requirement is in place to guarantee the standard is followed in a methodical manner. The documented plan must detail how you intend to meet the standards, it typically aligns with the Chemical Hygiene Plan in laboratories.

Other Permits and Requirements

• EPA ID Number – Generators of RCRA (federal) hazardous waste are issued federal EPA ID Numbers. If you or your company produces more than 100 kilos of RCRA hazardous waste or 1 kilogram of RCRA acutely hazardous waste every month, you must get a federal EPA ID Number.
• Controlled Substances – Before managing controlled substances, you must first get a DEA permit. Look up a chemical on the DEA's "List of Controlled Substances" to check whether it's a drug. If your chemical is on the list, record the Schedule number and drug code because you may need it on the application.

EHS programs, permits and plans represent the basic foundational compliance elements needed for your organization. However, it must be emphasized that they represent the minimum requirements for you to get started on Day 1. Further EHS buildout will be required for a complete and sustainable EHS compliance program. To assist with this process, Triumvirate Environmental will coordinate with clients to formalize a schedule and timeline for applicable project milestones. Clients should communicate a target date to complete all deliverables and an application permit should be submitted within the first 60 – 90 days of this agreement and kickoff meeting. To learn more about our lab and facility services, please click below.