Laboratory Cleanout Guidelines
INTRODUCTION
When research laboratories within Harvard University plan to a move or modification, considerations for contractor liability, environmental, safety may be necessary. The purpose of this procedure is to establish a systematic approach for lab clean outs in order to minimize potential personnel exposures, chemical spills, excessive disposal costs associated with the discovery of unknown or high hazard chemicals and undue delays in contractor activity. In this role EH&S is committed to be a University resource and a conduit for reducing risk and providing a safe working environment for all.
DEFINITION
A lab-clean out is defined as an activity involving "non-routine" waste pickup request of stock (unused) chemicals for disposal.
Lab clean outs are typified by internal relocation of research personnel from one lab space to another within the University or evacuation of lab space as a result of a re-location of appointment outside the University. EH&S personnel are responsible for determining non-routine clean outs. This determination involves an EH&S evaluation of the lab space including:
- Volume and quantities of chemicals to be removed or transferred,
- The discovery or identification of Potentially Unstable Compounds or unknown chemicals.
LAB CLEANOUT TIMELINE
A successful laboratory clean out requires the cooperation and effective communication between facility managers, faculty representatives, laboratory personnel, EH&S representatives, hazardous waste disposal vendors. This process may require coordination with construction/ demolition contractors. The lab clean out process requires lead time of at least one (1) month to effectively prepare, coordinate and accomplish the clean out and removal of biological, radiological and hazardous chemical waste. A full timeline of all required actions is described below.
Additional Environmental and Safety Considerations: At the end of this lab clean out process there may still be remaining EH&S concerns related to equipment, asbestos containing materials, sink neutralization tanks, residual contamination in exhaust systems and ductwork, etc. EH&S will work with facility managers to identify and remediate the remaining potential hazards.
ROLES & RESPONSIBILITIES
Facility Managers or Research Operations Managers (ROMs) are front line contacts regarding impending construction, renovation and other related physical plant and laboratory personnel changes. Facility Managers and Research Operation Managers are responsible for the following:
- Distributing Lab Clean Out Guideline Checklist to the laboratory Faculty Lab Representatives
- Alerting the EH&S Hazardous Waste Coordinator regarding the evacuation.
- Posting of contractor communication signage
Principal Investigators of each lab appoint faculty Lab Representatives. Faculty Lab Representatives may be Safety Committee Members, Research Operation Managers (ROMs), lab personnel or members of the Faculty. The Faculty Lab Representatives are responsible for the following:
- Notifying the Facility Manager/ Department Director of their planned departure or move
- Following the Lab Clean out Guideline Checklist given to them by the Facility Manager or ROM.
- Arranging meetings with the EH&S Hazardous Waste Coordinator throughout the course of the move (see timeline for specific details).
- Following any additional guidance or direction as determined with the EH&S Hazardous Waste Coordinator.
EH&S Hazardous Waste Coordinator is the point of contact responsible for scheduling and coordinating hazardous material clean out and removal activities prior to an evacuation of laboratory personnel and commencement of contractor activity within an area. The EH&S Hazardous Waste Coordinator is responsible for the following:
- Making an appointment to visit and assess the space, once contacted by the facility manager or ROM.
- Notifying other disciplines within EH&S (radiation, biohazard, industrial hygiene) to schedule and coordinate lab clean out activities related to each the disciplines.
- Speaking with the Faculty Lab Representative to evaluate their progress toward completion of tasks set forth in the lab clean out guidelines checklist.
- Assessing the scope of clean out in order to determine timeline and physical resources necessary to perform the lab clean out the area.
- Ensuring the accuracy of, signing and maintaining files for the Department Of Transportation (D.O.T.) manifests, Land Disposal Restrictions (LDRs) and Hazardous Waste Profiles.
