The following article was written by Frank Jankoski, an EES associate and guest author. Mr. Jankoski is the founder and President of Corporate Environmental Services Inc. (CES), a company that specializes in providing personal attention and high-quality consulting and engineering services to private sector clients. CES has completed a wide range of environmental, health and safety projects for companies and organizations in the Mid-Atlantic region.
Numerous small to medium sized biotech and chemical facilities are closed each year for a variety of reasons. These facilities usually contain an office area and one or more laboratories, which may handle infectious materials and/or toxic chemicals. Site closure entails closure of both documentation and the physical facility. This month we’ll discuss the physical facility and next month we’ll review documentation.
While certain closure requirements may be prescribed by state regulations, there are a number of actions that should be taken to ensure that the facility is safe for future tenants.
- Hire an Environmental Health and Safety consultant to oversee the entire closure and provide a final report. During a closure, especially with company dissolutions, scarce remaining staff may not have the time, skills or motivation to carefully monitor equipment removal, cleaning and decontamination.
- If biological safety cabinets and fume hoods are present, have the company that normally services them sterilize, decontaminate, remove filters, and clean interiors. This requires special equipment and extensive personal protective equipment (PPE).
- Hire state-licensed contractor(s) to properly package, remove and dispose of chemicals and biologicals.
- Before lab equipment and instruments are moved, make sure they have been decontaminated; an alcohol-water wipe usually works well.
- Hire a cleaning company that is experienced in laboratory cleaning/decontamination. An ordinary janitorial service may not have the skills and equipment. Ask for appropriate references. Provide a written cleaning protocol, including use of PPE, and make sure the cleaning staff follows it.
- Ensure that every lab surface is cleaned. This includes ceilings, walls, floors, windows, benchtops, cabinet interiors and exteriors. Use cleaning solutions appropriate for the surface being cleaned.
- Keep records of every phase of the cleaning, including decontamination of biosafety cabinets and fume hoods, equipment and instruments, and all lab surfaces. Check, re-check, and re-re-check! It’s all too easy to miss something.
- When cleaning is complete, there are at least two surveys that should be conducted:
- Mercury Survey: Using a portable mercury analyzer, survey sink drains and floors – the most likely places for mercury from a broken thermometer.
- Perform a volatile organics survey using a portable PID analyzer. Check all drains and floors and any other areas suspected to be contaminated with solvents or volatile organic chemicals.
- If radiological materials have been used, a radiological survey will be required. This is a specialized task and probably needs to be contracted out unless a Radiological Safety Officer is available among remaining staff.
CES can provide site closure oversight and direction, ensuring that the closure is complete and effective. Call us for details, or with any other compliance questions at 609-730-0040.