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Lab Decommissioning: Is Your Lab Liable?

This webinar focuses on laboratory decommissioning and the associated liability, providing guidelines for effective planning and management. Attendees will learn about decommissioning requirements, corporate liability considerations, and methods to mitigate risk during laboratory relocations, closures, or renovations. Key topics include regulatory obligations, assessment procedures, and the importance of thorough documentation to manage potential liabilities.

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Laboratory Decommissioning Is your laboratory liable? This webinar will educate attendees on liability drivers and lessons learned from 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 • csasse@triumvirate.com • Craig Sasse has been employed at Triumvirate for over 6 years and has worked as an environment consultant for over 19 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? What are your decommissioning requirements? Our experiences decommissioning laboratories. Information to plan and manage your laboratory decommissioning.
This will help manage… • Relocations • Internal moves • Renovations • Closure
Where to start? Determine closure obligations. Prepare a plan. - Review lease - Assemble team - Compile information Key events. - Stop research - Permits & license termination - Move chemicals & equipment - Last day of occupancy Allow time to assess/decontaminate… Notify landlord, vendors, employees, etc.
Considering Lease Obligations • No regulation or regulatory guide. • Termination obligations are case-by-case. • Lease obligations can be ambiguous. • The Lessee/Lessor meaning of “clean” can be different.
Considering Corporate Liability • Organizational real estate divestiture policy – if any • Legacy issues • Risk tolerance and cost constraints • Industry
The American National Standard/AIHAZ9.11–2008 • 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. • Consistent with industry real estate practices. Managing Risk
Decommissioning Process Areport limits potential liability when occupying, leasing or leaving space. Due Diligence Schedule Decommissioning Reporting
Due Diligence • 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
Scheduling • Coordinate the end of occupancy, • Determine last date of occupancy and research • Researchers responsibilities • Equipment – vendors, decontamination and special handling • Systems – vendors, contractors, landlord, etc. • Licensing and permits termination and securing at new location - radioactive materials can be up to 45 days for processing.
Decommissioning • Bench Tops, Drawers, Cabinets • Floors and Walls • Chemical Storage Areas • Cold Rooms • Animal Care Area • Rad. Use Areas • Biosafety Levels • Wastewater System • Fume Hood Ductwork • Lab Equipment – BSCs
Persistent Contaminants • 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
Reporting • Visual inspections and photographic documentation • 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. The schedule drives many activities. Define lease and corporate decommissioning obligations. Research, license, equipment, wastes, debris 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