Lab Moves / Closeout / Modifications

Laboratory decommissioning is the process whereby all hazardous materials, wastes and contamination are removed from a lab space that is being vacated. Many activities associated with lab moves require a long lead-time and planning is critical to ensure a smooth and successful transition. Not all aspects of preparing a new lab space for move-in are addressed under these guidelines but can significantly impact move schedules so Departments, Project Managers, and PIs are encouraged to work together to ensure a new lab space is compliant and ready for occupancy.

For large moves, the PI or Department should schedule an advisory visit with EHS at least 60 days in advance of the move. EHS can offer advice on deactivation requirements and alert other EHS programs that provide services related to these guidelines.

If a PI abandons a lab and cannot be contacted or otherwise held accountable, the Department assumes responsibility for assuring all decommissioning tasks assigned or required of the PI are completed by other means.

Hazardous material transfer, disposal and decontamination tasks are generally subdivided into three hazard categories (chemical, biological and radiological) due to the specialized procedures and regulations that govern each of these materials. Decontamination includes the cleaning or disinfection of work surfaces and equipment such as bench tops, sinks, storage cabinets, drawers, shelving, fumehoods, and any other surface or equipment potentially contaminated with hazardous material. If renovation or demolition is planned for the vacated lab space, the assigned Project Manager will coordinate additional evaluation and decontamination of inaccessible areas or installed equipment with EHS.

Principal Investigator (PI)

The PI is responsible for ensuring the laboratory is fully decommissioned in accordance with these guidelines prior to vacating the lab. This includes the removal of chemical, radiological, and biological materials and their residues from work surfaces and equipment in all areas where their research was conducted. The PI may delegate tasks to lab staff and colleagues appropriate to their level of training, knowledge, and ability but is responsible for assuring tasks have been completed accordingly.

Lab Manager

A Lab Manager may act as the lab’s point of contact and is responsible for communicating and coordinating decommissioning tasks as assigned by the PI or other lab personnel.

Building Manager

The Building Manager is responsible for facility operations and decommissioning responsibility may include meetings with EHS and Lab Managers to facilitate moves.

Project Manager

The PMCS or CPC Project Manager (PM) is responsible for the overall design and construction of new or renovated lab space. PMs shall notify EHS if a space they are scheduled to demo has not been decommissioned. PMs are responsible for coordinating the evaluation and decontamination of inaccessible areas or installed equipment in vacated labs planned for demolition or renovation. Departments and PIs should work closely with the Project Manager as early in the design phase as possible to ensure room configurations and equipment requirements fit the needs of the end users.

Department

The PI’s Department is responsible for overall support of decommissioning tasks. If a PI vacates a lab and cannot be contacted or otherwise held accountable, the Department assumes responsibility for assuring all decommissioning tasks are completed by other means. In no case shall administrative staff be asked or expected to undertake decommissioning tasks for which they are not fully qualified by training and experience to perform.

Environmental Health and Safety (EHS)

EHS is responsible for advising Departments, faculty, staff and vendors on lab decommissioning requirements that comply with University policy and all applicable standards, laws and regulations. EHS provides or coordinates the various hazardous materials specialized services described in these guidelines.

Moving Company

Professional moving companies provide packing materials and transfer nonhazardous equipment and materials to their new location. The PMCS General Construction Shop also provides nonhazardous equipment and material transfer services.

Hazardous Material Movers

Hazardous Material Movers are vendors who are qualified/certified to transfer hazardous materials and equipment from one location to another in accordance with Federal Department of Transportation (DOT) requirements.

Surplus Property

Surplus Property can transfer nonhazardous material and equipment to their warehouses where they can be sold, reused on campus, or scrapped.

Planning is the most important step in lab decommissioning and should start at least 4 to 6 months in advance of the move date. Planning should include the following:

• Plan research activities so that the Lab Work Termination Date (LWTD) minimizes disruption to research and allows enough time to complete all deactivation tasks. All lab procedures and research must stop by the LWTD.
• Discuss and assign responsibilities and duties. Conduct pre-deactivation meetings so that everyone understands their roles and responsibilities.
• Establish and communicate timing and schedules. Use checklists to track progress.
• Prioritize equipment moves. Prepare to transfer pieces of equipment most essential for research first.
• Consider designating “room captains” to be on hand to direct and assist the movers.
• If applicable, consider transferring surplus chemicals in good condition to colleagues in nearby labs well before the move date or submittal of a removal request to EHS.

Transportation of chemical, radiological or biological agents, including dry ice, are subject to rigorous state and federal shipping requirements for which the person offering the material for shipment, or carrying the material, is personally liable. Failure to comply with these rules can result in substantial civil and criminal penalties for the individual. Consult with EHS for guidance on the shipment of hazardous materials off campus. Radiological materials can only be shipped through EHS Radiation Safety.

• Lab Work Termination Date: The Lab Work Termination Date (LWTD) is a deadline for all laboratory research activity to stop and has a major influence on the timing of many decommissioning tasks. The Department and PI should meet at least four months in advance to select and agree on research termination dates that are both practical and realistic.
• Chemicals: Large moves may require the removal of significant quantities of chemicals that will not be transferred to the new lab space or reused. EHS is responsible for removing unwanted chemicals from labs and has limited resources. Large-scale lab clean outs should be scheduled at least 60 days in advance with EHS.
• Radiological Materials: New lab space must be ready to receive the transfer of radiological materials from the decommissioned lab. Inspection and approval from EHS Radiation Safety is mandatory and should be scheduled at least 60 days in advance.
• Building Demolition or Reclassification: Vacated lab buildings that used licensed radiological materials and will be demolished or repurposed as non-lab use must undergo a formal closure process as mandated by the Texas Department of State Health Services before the building demolition can begin. This closure process can take up to a year to complete. The Project Manager should consult with the EHS Radiation Safety for additional information and cost estimate.
• Biological Materials: Any research at the new lab space that utilizes biological agents classified as BSL1 or above must be approved in advance by the University’s Institutional Biosafety Committee. Animal related research must also be pre-approved by the Institutional Animal Care and Use Committee. The EHS Biosafety Officer should be contacted at least 60 days in advance to assist with IBC or IACUC approvals.

EHS should be kept appraised of move schedules and locations to ensure quick emergency response should a spill or other problem arise.

• Provide emergency contact numbers and emergency procedures to vendors responsible for transporting hazardous materials.
• Preplan the move route to minimize use of congested, restricted or sensitive areas and aid the vendor in identifying their location when communicating with emergency response personnel.
• Know where emergency notification and response devices are, including fire alarms, safety showers, eyewash stations, etc.
• Do not move hazardous materials during off-hours to ensure emergency response personnel are available if needed.
   
• Use freight elevators rather than passenger elevators whenever possible.
• Follow the guidance in the EHS Transporting Hazardous Materials on Campus guide.​

In general, PIs and lab staff are responsible for packing their labs. Movers generally provide all boxes, packing materials, labels, etc., although in some cases, movers may also provide packing services as well. Nonhazardous materials, equipment and furnishings will be transported either by a professional moving company or the PMCS General Construction Shop. Depending on the size and location of the move, a vendor that specializes in the packaging and transportation of hazardous materials may also be used to move chemicals and lab equipment. Lab personnel can pack and transport personal items themselves if desired.

With few exceptions, vendors are not allowed to handle or transport controlled substances, select agent toxins, radiological or biological materials. Contact EHS for more information.

All storage guidelines and codes must be followed during the move.

Keep storage cabinet doors closed and gas cylinders properly secured. Provide proper segregation, secondary containment, and storage of hazardous materials throughout the move process. Do not use fume hoods for chemical storage.

All miscellaneous items and debris must be removed, recycled or disposed of properly. For larger moves, coordination of these activities with the Building Manager or Department may be necessary. Transfer only essential items that will be used in the new lab and leave nothing other than permanent fixtures and designated furniture (if applicable) in the deactivated lab space.

All hazardous materials and residues must be removed from lab equipment that will be disposed or resold as surplus property. Do not open (disassemble) internal compartments of equipment for decontamination. If the internal compartments of a piece of equipment are contaminated with chemical, radiological or biological material, label or tag the equipment as potentially hazardous and contact EHS for further assistance.

Contact Surplus Property as soon as practical to arrange for the transfer of surplus equipment. Prior to transfer of equipment, follow the procedures on the Lab Equipment Decontamination Form.

• Equipment must be emptied, drained and cleaned of all chemical or radiological residues and disinfected of any biological materials.
• A certificate of disinfection from the University’s contracted vendor is mandatory for Biosafety Cabinets (BSCs).
• A terminal radiation survey and defacing of radioactive labels by EHS Radiation Safety is mandatory for any equipment that was used with radiological materials.
• Prior to disposal, fluids such as pump oil must be drained and submitted to EHS for disposal as chemical waste. Contact the Facilities Service Center by calling (512) 471-2020 to have fluids, such as refrigerant, removed from the equipment.
• Lab equipment, such as ovens, furnaces, heating mantles, hot pads and mitts may be insulated with asbestos and cannot be resold. Contact the EHS Asbestos Program for evaluation and disposal of these items.
• Other potential hazardous components such as mercury thermometers or manometers must be removed for disposal through EHS.
• Sealed radioactive sources in liquid scintillation counters and other equipment must be removed by EHS Radiation Safety prior to disposal or surplus. Radiation Safety will arrange shipment of the source to the buyer for equipment that will be resold.
   
• Contact your Department for assistance and guidance on removing equipment from your equipment inventory.

Inspections and documentation help ensure that all lab deactivation tasks have been successfully completed and may serve as evidence during regulatory inspections.

EHS has developed a standard checklist to aid Departments and PIs with deactivation completion inspections. The checklist should be used during a final joint walk-through inspection attended by the Department and PI or PI’s representative after all deactivation tasks have been completed and the lab space is ready for turnover.

Postings: After the lab has been closed out, EHS will post a green “lab clearance” posting on the door.

Lab Deactivation Procedures

Hazardous material transfer, disposal and decontamination procedures are described in this section.

The PI and lab personnel are responsible for coordinating and scheduling proper removal of all hazardous materials from the space being vacated. The function of Departments and other entities involved in a lab move are generally to support and assist the PI.

Removal of Unwanted Chemicals and Hazardous Wastes from Labs

As a first step, users must determine which chemicals are no longer needed in their research and identify chemicals that will be transferred to the new lab. EHS encourages lab staff to donate chemicals that are in good condition to fellow researchers and to start the chemical waste removal process for removing unwanted chemicals well in advance of a lab move.

Develop a reasonable timeline based on the Lab Work Termination Date (LWTD) in order to ensure that all activities can be completed prior to vacating the space. The WTD should allow enough time prior to the move date to ensure safe packaging and removal of all equipment, chemicals, wastes and miscellaneous items.

• Remove all unwanted research or reaction residues remaining in experimental equipment such as flasks and beakers, and prepare these materials for proper disposal. All wastes must be properly labeled, segregated, and stored per standard procedures prior to removal. DO NOT move chemical waste to another lab.
• Tag waste mixtures as soon as they are generated. Submit removal requests for tagged mixtures throughout the move planning process. Do not wait until the move is completed.
• Contact the EHS chemical waste program 60 days in advance of the LWTD for special handling advice or service if you have non-returnable gas cylinders, unstable chemicals, reaction residues or unknown chemicals and wastes.
• Samples may create special difficulties as often they are archival materials and information regarding the composition may be limited. Determining which samples are no longer needed and submitting removal requests, must be completed 45 days in advance of the LWTD.
• Make unwanted but usable chemicals available to colleagues. This process should be completed prior to submitting the request for chemical waste disposal. Lab occupants should keep chemicals secondarily contained and properly segregated during this process, and must not leave them in an unsecured area.
• Once all usable chemicals have been removed by other researchers, contact EHS at least 45 days prior to the LWTD to schedule a laboratory leanout. However, if the lab has decided which chemicals are no longer needed, the request can be submitted earlier. Upon receipt of the request, EHS will review their workload and staffing, and schedule the cleanout.
• One week before the move date, submit removal requests for any remaining waste generated in the period preceding the LWTD.

Transporting chemicals within the same building (small scale moves)

For small scale, short distance moves within the same building, the requirements for transporting chemicals is similar to storing them. Containers need to be in good condition and tightly sealed, materials kept in compatible groups, adequate secondary containment provided, and necessary protective equipment such as lab coat, safety glasses, and appropriate gloves used during their handling, packing, and transportation. PPE must be worn in conjunction with appropriate street clothing (long pants or equivalent that completely covers legs and ankles, non-perforated shoes that completely cover feet).

• Lab personnel may move chemicals from within their building if the chemicals are segregated according to storage groups.
• Do not seal the boxes tightly so they can be easily inspected.
• Label each box with the contents and destination.
• Preplan the move route to minimize use of congested and public areas.
• Know where emergency notification and response devices are, including fire alarms, telephones, safety showers, eyewash stations, etc.
• Use freight elevators rather than passenger elevators whenever possible.
• Follow the guidance in the EHS Transporting Hazardous Materials on Campus guide.

Transporting chemicals to a new building (large scale moves)

Labs should utilize the services of a certified hazardous material moving company when transporting a large volume of chemicals between buildings. The vendor will properly segregate, package and transport the chemicals to their new location and have all of the necessary materials and equipment to respond to an emergency if necessary.

Compressed Gases and Cryogenic Liquids

Limit the transportation of gas cylinders or cryogenic liquids. Make arrangements with suppliers to deliver new cylinders to the move-in location and reclaim existing cylinders from the lab space being deactivated. Timing may vary based on research needs.

Controlled Substances

To ensure proper security and oversight of Controlled Substances, the PI and his/her authorized researcher will need to move Controlled Substances and records. Contact EHS for guidance. EHS will need to inspect and approve proposed storage locations before the actual move. Notify the DEA of any change in address.

Equipment Decontamination

Equipment that is used in conjunction with hazardous material is presumed contaminated unless the users can verify (and certify in writing) otherwise.

• Equipment that will be transported and reused in the new lab should be emptied and thoroughly cleaned by users most familiar with its operation. Cleaning materials and residues should be managed as hazardous waste.
• If lab equipment, such as refrigerators or freezers will be used to transport samples / biologicals, only the exterior surface needs to be cleaned. Lab personnel will add packaging to the interior, if necessary, to prevent breakage. Refrigerators and freezers should be clearly labeled with PACKED WITH CONTENTS if applicable.
• Gloveboxes are typically used to isolate chemicals that react spontaneously with air or water or are otherwise extremely hazardous. The PI and lab personnel must ensure that all materials are properly sealed and removed from a glovebox and that the glovebox is decontaminated prior to removal from the lab.
• Toxic Gas Cabinets: Once toxic gas cylinders have been removed from the cabinets, all plumbing components such as gas lines, regulators, etc., must be purged with an inert gas. A notification with date and sign-off that documents this process must be posted on the face of the cabinet.

Work Surface Decontamination

Good laboratory practice, including appropriate response to spills, dictates that laboratory surfaces and associated equipment is kept in a clean and hazard free condition. When vacating a lab space, thorough cleaning (decontamination) of all chemical use surfaces is mandatory. Surfaces include bench tops, sinks, storage cabinets, drawers, shelving, fume hood surfaces and any other surfaces potentially contaminated with hazardous material. Surfaces and equipment do not include areas or installed (fixed) equipment that requires demolition to access and clean such as fume hood exhaust ducting and lab vacuum system piping.

The most common decontamination method is thorough cleaning with detergent, e.g., Alconox and water, however, the PI and lab personnel must use their working knowledge of the specific materials used in the lab to select the appropriate decontamination method. Examples include highly toxic material such as ethidium bromide, water reactive or unstable compounds and corrosives. For large moves, the Department or PI may elect to hire a vendor that specializes in facility decontamination. These vendors typically provide standardized cleaning certificates for surfaces or equipment included in their scope. A copy of the certificate for equipment decontamination (such as a fume hood) should be posted on the equipment and all originals maintained by the Department.

The new lab space must be ready to receive the transfer of radiological materials and equipment, such as scintillation counters and lasers, from the lab being deactivated. Inspection and approval of the new space by the EHS Radiation Safety Office is mandatory and the PI should schedule at least 60 days in advance of the move. Additional requirements related to the use of radiological materials are found online at EHS Radiation Safety

Removal of Unwanted Radioactive Materials and Wastes from Labs

• All radioactive materials and wastes must be properly transferred or disposed. Submit pick-up requests by email at least three weeks in advance to radstaff@austin.utexas.edu.
• Discard unwanted radioactive materials in appropriate waste containers and log all entries.
• Identify and properly package all radioactive waste for disposal. Labeling and packaging procedures will not differ from those normally used. All radiation symbols and the word “radioactive” must be completely defaced. Rooms, facilities, and equipment must be decontaminated, such that they meet the standards for uncontrolled areas.
• When final radiological contamination surveys have been completed, Radiation Safety will remove postings from rooms and equipment.​

Transporting Radioactive Material

• Radioisotopes must be packed and transported on campus by designated lab personnel only. With few exceptions, vendors are not allowed to transport radioactive materials.
• Appropriate shipping paperwork must be completed by the Radiation Safety Office for transport of radioactive materials to other campuses.
• Pack radioactive materials in break-resistant secondary containers with enough absorbent material to absorb twice the amount of liquid in the container. Label the secondary container with the isotope, activity, and assay date.
• Depending on the circumstance, Radiation Safety may require additional oversight and safeguards including accompanying the materials during transfer. Radiation Safety must be consulted prior to the transfer of any radioactive materials.​

Equipment and Work Surface Decontamination

• Equipment and work surfaces associated with radioactive material use must be thoroughly decontaminated and surveyed prior to the move date. Lab personnel most familiar with the equipment and material use are responsible for decontamination. Radiation Safety personnel will conduct the final release survey.
• Radiation Safety, working in conjunction with the manufacturer, will assist with the removal and reinstallation of radioactive sealed sources in equipment such as scintillation counters. If applicable, and with the pre-approval of Radiation Safety, equipment with intact sealed sources may be transferred by trained individuals familiar with the specific equipment and manufacturer’s requirements.
• -80 degree freezers should be moved with contents in place whenever possible as long as ice within the freezer does not melt. Freezers should be labeled “PACKED WITH CONTENTS” if applicable. The exterior surface of the freezer must be decontaminated and pass a release survey prior to transfer.
• If -80 degree freezers cannot or should not be moved fully packed, the users are responsible for unpacking and transferring contents.​

Radiological Contamination Closeout Surveys

• A final contamination survey that encompasses all surfaces and equipment designated for radioactive material use is mandatory.
• All radiological decontamination work must be completed by the lab prior to performance of the survey. The PI and lab staff should use the Lab Work Termination Date (LWTD) to estimate when decontamination tasks will be completed and schedule a final survey with Radiation
• Radiation Safety will return and remove or deface warning signs, stickers and labels upon successful completion of the survey.

Research at the new lab space using biological materials must be reviewed by the Institutional Biosafety Committee (IBC). Animal related research must be reviewed by the Institutional Animal Care and Use Committee (IACUC).

Laboratories which currently utilize biological materials must notify EHS Biosafety Officer prior to terminating work to ensure that the laboratory has been decontaminated and that the biological material has been secured or properly disposed. If the PI intends to cease work, he or she must notify EHS at least 60 days prior to the set departure/closing date. This will allow the Biosafety Officer time to consult with the PI and perform a walk-through of the lab to provide recommendations on the most expeditious way to prepare for the move and the final termination of the biohazardous work in the lab.

Removal of Unwanted Biological Materials and Wastes from Labs

• Account for all specimens stored outside the lab room. Specimens stored in a cold room or an incubator in an adjacent tissue culture room should be autoclaved or disposed through EHS.
• All biological waste such as used sharps containers or biological waste boxes must be disposed of and the storage areas for the biological waste cleaned with a suitable disinfectant prior to moving day.
• Submit biological waste for removal to EHS using the Biological and Sharps Waste Request form (PDF). Biological waste can also be autoclaved and disposed as regular waste following the appropriate procedures.
• Lab personnel should notify EHS if an unusually large amount of waste, such as discarded samples, will be disposed to potentially schedule a non-routine pick-up. Waste labeling and packaging requirements will not differ from those normally used.
• Lab personnel must remove or deface all biohazard stickers and signs after the lab has been decontaminated.​

Transporting Biological Materials

• With the exception of materials stored in -80 degree freezers, biohazardous materials must be packed and transported on-campus by designated lab personnel only. Vendors are not allowed to transport these materials. Follow the guidance in the EHS Transporting Hazardous Materials on Campus guide.

Tissue Culture Transfers

Users should transfer cultures to back-up incubators prior to beginning the procedures listed below.

• If applicable, transportation and reconnection of incubators will be done in two stages so cultures can remain in back-up incubators until incubators in the new lab space have been installed and activated.
• Schedules should include detailed timing of disconnecting, draining, and reconnecting incubators.
• Users will drain and decontaminate incubators, and prepare them for moving.
• CO2 tanks should be in place in the new lab space and ready for connection to incubators.
• Users will be responsible for refilling incubators with water at the new lab space.​​​

Biosafety Cabinets (BSCs)

Biosafety cabinets must be disinfected and certified by the university’s contracted vendor prior to the move date. The vendor must also certify any new or reinstalled BSCs at the new lab space prior to use. Users are responsible for removing all materials from BSCs and cleaning the work surface prior to disinfection by the vendor.

Equipment and Work Surface Decontamination

• Interiors and exteriors of equipment, including laminar flow hoods, and all work surfaces must be properly decontaminated and disinfected by lab personnel. Chemical disinfectants applied to the surface must be allowed enough contact time to inactivate potential contamination prior to final wipe down.
• Contents of refrigerators and freezers must be transferred to ice chests and transported to the new lab by the users.
• -80 degree freezers should be moved with contents in-place whenever possible as long as ice within the freezer does not melt. Freezers should be labeled with PACKED WITH CONTENTS. If, in the opinion of the lab users or mover, the freezers cannot or should not be moved fully packed, the users are responsible for transferring contents to dry ice chests and transporting to the new lab.​