35.66 – Laboratory Decommissioning

A. Purpose. This policy provides requirements for the removal of hazardous materials and equipment from laboratory spaces when the Principal Investigator (PI) or laboratory supervisor is leaving the University of Idaho, moving to another campus building, relocating to another laboratory within the same building, or disposing of or transferring laboratory equipment that is no longer needed. This policy also applies to the removal of all hazardous materials and equipment from laboratory spaces prior to a renovation.

B. Scope. This policy applies to all laboratories and laboratory equipment that are part of the University of Idaho, including all teaching laboratories, research laboratories, and auxiliary spaces serving as laboratories. Management of laboratory hazardous waste and biohazards is within the scope of APM sections 35.01, 35.11, 35.40, and 45.20.

C. Policy

C-1. Disposition of materials and sharps. All chemicals, radioactive, and biological materials must be disposed of or their ownership transferred; hazardous wastes, sharps, and other wastes must be submitted to EHS for disposal in an appropriate manner before a laboratory is vacated.

C-2. Surfaces and storage locations. Laboratory work surfaces and storage locations for all hazardous materials must be thoroughly cleaned and decontaminated before a laboratory is vacated.

C-3. Laboratory equipment. All laboratory equipment must be thoroughly cleaned and decontaminated before removal from service, placing back into service, transporting to another location, storing in another location, or disposing of in a proper manner.

D. Procedure

D-1. Department chair. The department chair must notify Environmental Health and Safety when a PI plans to vacate a laboratory, ensure PIs are aware of and follow procedures defined in this policy, and pay for all costs associated with the proper disposal or decontamination of hazardous materials or equipment remaining in the laboratory after the PI leaves the university (hazardous waste, unknowns, expired chemicals, equipment, etc.).

D-2. Principal Investigator. The PI is responsible for the following:

a. Notify EHS of the plan to vacate the laboratory at least four weeks in advance and begin review of applicable items from the Laboratory Decommissioning Procedure and Checklist or the Laboratory Equipment Decontamination Form.

b. Arrange for the transfer or disposal of all chemicals, radioactive materials, and biological materials prior to leaving the University of Idaho.

c. Ensure all hazardous waste has been submitted for pickup and removed by EHS before leaving the University of Idaho.

d. Ensure all laboratory rooms, storage areas, equipment, and work surfaces are thoroughly cleaned and decontaminated before vacating the assigned lab space.

e. Ensure all laboratory equipment slated for removal has been decontaminated and has a completed and signed Laboratory Equipment Decontamination Form.

f. Correct any nonconformance after an EHS decommissioning inspection.

D-3. Environmental Health and Safety. EHS is responsible for the following:

a. Provide guidance to lab personnel on how to perform activities listed on the Laboratory Decommissioning Procedure and Checklist.

b. Provide guidance on proper methods or procedures for decontamination of lab equipment listed on the Laboratory Equipment Decontamination Form.

c. Collect all submitted hazardous chemical waste.

d. Perform a laboratory decommissioning inspection when applicable activities described in the Laboratory Decommissioning Procedure Checklist have been completed by the PI, notify the PI and department chair of any findings, and identify any potential nonstandard costs for review and determination by Vice President of Research, Vice President of Finance and Office of Research Assurances.

E. Nonstandard cost recovery

E-1. Department responsibility. The responsibilities and procedures mandated above should be managed within normal office operations and existing budgets because the PI is familiar with the area or materials and can thus partner with EHS for timely and cost-effective assistance. Current procedures on how to identify, manage and request disposal of hazardous wastes prior to decommissioning can be found at the Environmental Health and Safety website. Should decommissioning result in nonstandard costs, the department is solely responsible for the cost of remediation. Nonstandard costs are those that arise due to the specific nature of the waste or failure of the PI or laboratory supervisor to correctly and timely identify, manage, and request disposal of hazardous wastes prior to decommissioning. Whether an identified cost is nonstandard will be jointly determined by the Vice President of Research and Vice President of Finance in consultation with Environmental Health and Safety and the Office of Research Assurances.

E-2. Funding source identification. EHS will provide an estimate of nonstandard costs to the department. Within 10 business days, the department must identify to EHS a funding source. EHS will then engage the appropriate services.

E-3. Discretionary loan. The department’s parent college may petition the Vice President of Research to grant a loan from the Office of Research to the department for all or some of the costs. If granted, the Office of Research will withhold all F&A recovery from the college until the loan is repaid from withheld F&A recovery. Additional loan terms may be negotiated between the college and the VPR. These terms may include, but are not limited to, suspension of proposal submissions by the involved college, loan interest, etc.

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