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lab closeout procedures
Laboratory Close Out Guidelines
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Principal Investigator Responsibilities
As a Principal Investigator
at Vanderbilt, you are responsible for the safe operation of your
laboratory or suite of laboratories. This includes leaving any and
all of these facilities in a safe condition when you vacate the
premises. This guideline outlines your responsibilities in the Laboratory
Close Out Process.
The Close Out process should
be divided into three stages (the time frame referenced below can
be compacted, if you are acting on short notice):
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Approvals:
These guidelines
have been approved by the following individuals:
- Dennis Hall, Associate Provost for Research University Central
- Lee Limbird, Associate Vice Chancellor for Research
- James May, on behalf of Radiation Safety Committee
- Ken Brigham, on behalf of Institutional Biosafety Committee
- Wallace LeStourgeon, on behalf of Environmental Affairs Committee
- Tom Oeltmann, on behalf of Chemical Safety Committee
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Three Months Before You Move
(or as early as possible in the process)
- Review and complete a Laboratory Close
Out Notification. Mail or fax to Vanderbilt Environmental
Health And Safety (VEHS) Lab Close Out
Coordinator (see address and identification of Coordinator
at the end of the following check lists) with a copy to your Department
Administrator.
- Upon receipt of your close out notice, the VEHS
Lab Close Out Coordinator will accompany you and your department's
administrative representative or other responsible party in a
tour of your Laboratory.
- After the tour of your lab(s), the VEHS
Lab Close Out Coordinator will help you address safety issues
identified. As a team we will jointly develop a close out plan
customized to your lab(s). We will agree upon target dates for
critical process steps.
- Review the following close out checklist. It covers general
points to help you safely and efficiently vacate your lab(s).
Where needed, more consultation will be provided by VEHS.
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Laboratory Close Out Checklist
- Assess the biological materials (recombinant DNA materials,
microorganisms, cells and cell lines, tissues, organs, body fluids,
and biologically-derived or -contaminated media) and determine
which materials will be transferred to your new laboratory or
to another Vanderbilt investigator. Dispose of the remaining materials
as you would have during the course of experimentation. For example,
solid materials (including petri dishes and microfuge tubes) should
be autoclaved and disposed as regular trash or they should be
collected (in VUMC) by Environmental Services for autoclaving.
Liquid materials may be decontaminated by preparing a solution
of 1 part household bleach to 9 parts liquid waste. Mix the contents
gently and let sit for at least 30 minutes. This decontaminated
solution may now be disposed in the sink. Liquid waste may alternatively
be autoclaved in vented containers on the liquid cycle of the
autoclave. Once cool, the liquid may be flushed down the sink.
Laboratories without the use of an autoclave or those outside
of VUMC should consult with the VEHS Lab
Close Out Coordinator to determine the appropriate method
of disposal.
- VEHS has developed a
Chemical Redistribution Program for unopened or usable chemicals. In the Program,
Chemicals collected through the waste collection program or donated
by laboratories that are still usable are made available to all
Vanderbilt researchers and faculty, free of charge.
- Label unmarked or unclearly labeled containers as soon as they
are located. Identification and disposal of unknown substances
is one of the most costly close out activities, with average disposal
fees of approximately $500 per vial or container. If true unknown
chemicals or radioactive materials remain, segregate them for
identification during waste collection.
- All chemicals that are not transferred to the
Chemical Redistribution Program or to your new Vanderbilt
laboratory must be disposed of through VEHS. No chemicals should
be disposed of by pouring them into sinks or other drains or by
evaporating them in hoods. It should be noted that chemicals include
lubricating and other oils, containerized gases, and pharmaceuticals.
Contact the VEHS Lab Close Out Coordinator for assistance in disposing
of your chemicals.
- Due to Department of Transportation (DOT) shipping requirements
that may apply, it is imperative that the VEHS
Lab Close Out Coordinator be notified if any chemicals, biological
materials, or radioactive materials are going to be transported
off Vanderbilt property. This notification should be made as soon
as possible so that special arrangements can be made, if necessary.
(Note that VEHS can be contacted with any transportation questions
for transfer of these materials off Vanderbilt property or for
transfer within Vanderbilt property.)
- Separate any rad/biological, chemical/biological, rad/chemical
mixed waste from other wastes. Be sure that the mixed wastes are
addressed in inventories for inclusion in waste disposal planning.
- Usable radioactive materials you will not use for continuing
research may be transferred to other Principal Investigators approved
for radioisotope use, as outlined in the
Vanderbilt Radiation Safety Policies and Procedures Manual.
Contact the VEHS Lab Close Out Coordinator
with any questions about this process.
- All radioactive materials that are not transferred should be
disposed of through VEHS. Contact the VEHS
Lab Close Out Coordinator with any disposal questions.
- Hazardous materials, including radioactive, biological, or
chemical materials, must not be moved in compromised containers.
This is one of the major causes of spills.
- Check beneath hoods, in shared labs and equipment and in freezers,
refrigerators or cold rooms for biological agents, chemicals or
radioisotopes that might easily get left behind. Look for old
supplies from past lab staff and students. Many labs have inherited
chemicals that must also be identified and disposed of before
moving to the new location.
- Gas cylinders and lecture bottles that are no longer used should
be returned to the supplier. You may be paying a demurrage charge
for cylinder rental while the cylinder is in your possession.
- Tubing and regulators connected to corrosive or hazardous compressed
gas cylinders should be detached using safe procedures such as
purging and venting to a hood or ventilated area. Contact the
VEHS Lab Close Out Coordinator for
assistance or direction on this process.
- Notify the VEHS Lab Close Out Coordinator
of any cylinders of corrosives that have been in your lab more
than six months after initial use.
- All biological safety cabinets require
VEHS Biological Safety Section evaluation to determine required
decontamination, even if they are not moved. The equipment must
be certified again after the move to ensure filter integrity.
Make arrangements for this work in advance to allow contractors
to meet your schedule.
- Have damaged equipment (i.e., frayed wires, missing guard)
scheduled for repair during the move, accomplishing the repair
during lab downtime.
- Other broken equipment, such as refrigerators, may be discarded.
However, equipment that could possibly be contaminated with radioactive,
chemical or biohazardous material must be decontaminated and checked
first.
- If a Liquid Scintillation Counter is to be discarded or shipped,
contact the manufacturer well in advance to arrange to have any
internal standard sources removed.
- Look at the area you will be moving to. Determine where will
you place your large equipment and cabinets? Are electrical outlets
where you need them? Are there special facility needs (e.g., 220
volt electrical outlets) that should be addressed prior to occupancy?
You should never attempt to address these issues on your own.
Contact the VEHS Lab Close Out Coordinator
for information on the proper procedure to address these issues.
- Contact the VEHS Lab Close Out Coordinator
for planning assistance on packing and moving radiation sources
that might require shielding for safe transport.
- If you are moving to another Vanderbilt laboratory contact
the VEHS Lab Close Out Coordinator
to determine if any special permits are needed and for information
regarding revised approvals for the use of biological and radioactive
materials and hazardous chemicals.
- Schedule your lab for a radiation close out survey by contacting
the VEHS Lab Close Out Coordinator.
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Thirty Days Before You Move
- Review your lab(s) again to be sure all unknown materials have
been identified and no new ones have been created while preparing
to vacate the lab(s). It is productive to repeat this step of
the close out process, because identifying and disposing of "unknowns"
is a major cost item in laboratory close outs.
- Seek assistance from the VEHS Lab Close
Out Coordinator in planning the safe transfer to your new
lab and removal of any high hazard materials (violently reactive
chemicals, toxic gases, etc. as identified during the chemical
disposal process).
- Follow-up on the status of time critical close out plan steps
such as: radioactive and chemical waste collection, special equipment
moving arrangements, posting of your new laboratory for biological
or radioactive materials, etc.
- Visit your new lab space to ensure that previous occupants
(if any) have not abandoned any equipment or materials.
- Verify that all modifications in your new space will be completed
before your move.
- No equipment used for radioactive material should be moved
with external removable contamination present. You and your radiation
workers can perform wipe and meter surveys to assure this for
smaller items. The Radiation Safety
Section of VEHS will provide this service for major pieces
of equipment including freezers and refrigerators. Contact the
VEHS Lab Close Out Coordinator to
arrange this service.
- Verify the hood(s) in your new lab are operating properly -
sash is functional, flow rate is adequate, drains are open, etc.
Contact the VEHS Lab Close Out Coordinator
for assistance with checking and verifying the flow rate in the
hood(s).
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At Moving Time
- Package and move lab items only during normal business hours
(8:00 am - 4:30 PM) so staff will be available to help if there
is a spill or accident.
- Provide secondary containment for biohazardous materials, chemicals
and radioactive materials during transport (even when just moving
a few doors down the hall).
- Never transport hazardous materials alone.
- Never transport hazardous materials on public roads.
- Wear appropriate personal protective equipment for the materials
being handled (safety glasses or goggles, lab coat, gloves, closed-toe
shoes, etc.).
- Have boxes, plastic bags and containers for broken glass, etc.,
ready and available before you begin.
- Post any required warning signs (radioactive materials, biohazard,
etc.) in your new lab location.
- Review the location of safety showers, eyewashes, fire extinguishers,
and all available means of exit from laboratories and the building.
- Revisit your old lab space. Have any materials been left? Are
any hazardous materials left in your old lab?
- Notify the VEHS Lab Close Out Coordinator
that the lab(s) are ready for Close Out Survey(s) using the
Laboratory Close Out Certification attached.
- Lock your lab, when you are through moving out and return your
key to your department administrator.
- Move compressed gas cylinders properly secured on a cylinder
cart or other conveyance device designed for this purpose.
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Lab Close Out Coordinator
If
you are unsure about anything, please ask questions! Your department
administrator may be able to help you smooth out logistics problems
at any point in the process. If you have any health and safety related
concerns pertaining to vacating your old lab or occupying a new
one, contact the Lab Close Out Coordinator:
Kevin Warren
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