indiana.eduLaboratory Close-Out Procedures and Transportation of Hazardous Materials
Introduction
Proper disposal of hazardous materials is required whenever a responsible individual leaves the University or transfers to a different laboratory. ("Responsible individual" can include, but is not limited to: faculty, staff, post-doctoral, and graduate students.) Plan the disposal of hazardous materials carefully. Hazardous materials such as chemicals, microorganisms, tissues, and radioactive materials can injure faculty, students, staff, contractors and visitors if handled inappropriately.
The primary responsibility for the proper disposal of all hazardous materials used in laboratories lies with the principal investigator or researcher. Ultimate responsibility for hazardous materials management lies with each department.
When the proper management of hazardous materials at close-out requires the services of the Office of Environmental, Health, and Safety Management (EH&S), or an outside contractor, the responsible department may be charged for these services.
Any regulatory action or fines resulting from improper management or disposal of hazardous materials will accrue to the responsible department.
Please consult the IU Bloomington Biosafety Program, Chemical Safety Program, and Radiation Safety Program for guidance on procedures regarding the transport and storage of potentially hazardous materials. Please read and adhere to the following procedures when a responsible individual leaves the University or moves to a different laboratory. You may use the following checklist to ensure that you have completed all the procedures:
- Laboratory Close-out Checklist [Adobe PDF]
Shared Storage Areas
- Shared facilities include storage units such as refrigerators, freezers, cold rooms, stock rooms, flammable liquids cabinets, waste collection areas, etc. They are of special concern, particularly if no one is assigned to manage the area.
- Departing researchers must carefully inspect any shared facility in order to locate and appropriately dispose of their hazardous materials.
Chemicals
- Determine which chemicals are usable. Transfer responsibility for these chemicals to a party willing to accept it. If a new user cannot be found, dispose of materials following the IU Bloomington Hazardous Waste Management Guide.
- Contact EH&S for waste collection. Do NOT evaporate chemicals, flush hazardous chemicals down drain, or discard them in the trash.
- Label all chemical containers with the proper chemical name. Abbreviations, chemical formulas or structures are not acceptable. Close all containers securely.
- Empty all beakers, flasks, evaporating dishes, etc. Remove all chemicals from refrigerators, freezers, fume hoods and bench tops as well as storage cabinets.
- Prepare unusable chemicals for disposal following IU Bloomington Hazardous Waste Management Guide. This process may take quite some time. Start at least one month before planned departure from the laboratory. Complete chemical waste removal before vacating the laboratory. Allow two weeks for waste collection to occur after notifying EH&S that the waste is properly prepared for pickup.
- Follow the transportation guidelines below for off site chemical transportation.
- EH&S can assist with laboratory and chemical moves between buildings (855-6311).
- For on-site chemical movement within buildings use the following "Guidance for Transportation of Chemicals Between Laboratories" [PDF].
- Wash off fume hood surfaces and counter tops.
- Notify Facilities Management (Building Administrator) when laboratory clean-up is complete. Facilities Management will contact EH&S to arrange a close-out inspection.
Controlled Substances
- The US Drug Enforcement Agency (DEA) issues controlled substance permits to individual researchers. There is no central record of permit holders at the University.
- Abandonment of a controlled substance is a violation of the DEA permit under which it was held.
- Permission to dispose or transfer ownership of a controlled substance to another individual must be received from DEA.
- Licensed individual may dispose of controlled substances through EH&S. Call 812-855-6311 for information.
- If controlled substances are found and the licensee is unknown, contact EH&S.
Gas Cylinders
- Remove gas connections, replace cylinder caps, and return cylinders to suppliers.
- If cylinders are non-returnable, please contact EH&S.
Animal and Human Tissues
- Animal specimens, organs, and tissues in preservative are disposed by EH&S. Contact EH&S for information.
- Frozen specimens should remain frozen and be picked up by Laboratory Animal Resources for disposal. Contact LAR at 812-855-2356.
- Human tissue should be placed in a biohazard waste bag and disposed of as potentially infectious waste. Contact the IU Bloomington Biosafety Officer for more information at 812-856-3638.
- If tissue was stored in a refrigerator or freezer - defrost, clean and disinfect the refrigerator and freezer when emptied.
- Locate an appropriate person to take responsibility for retained samples.
- If appropriate tissue disposal is uncertain, contact the IU Bloomington Biosafety Officer at 812-856-3638.
Microorganisms and Cultures
- If the material cannot be decontaminated, contact the IU Bloomington Biosafety Officer at 812-856-3638.
- Locate an appropriate person to take responsibility for retained samples.
Mixed Hazards
- Occasionally it is necessary to dispose of materials that may contain more than one hazard. Contact EH&S at 812-855-6311 for information on the disposal of any combination of biohazardous materials, and chemicals and/or radioactive materials.
Sharps
- Dispose of infectious waste sharps: Autoclave sharps container and discard in 55 gallon infectious waste drums. Infectious waste sharps include: all needles and syringes; broken or unbroken glass and plastic ware that has contacted infectious agents or was used in animal or human patient care or treatment, including plastic pipettes and other used plasticware that is recognizable after autoclaving or made of plastic that shatters on breakage or is considered breakable by the investigator.
- Chemically contaminated sharps: Segregate from other sharps into a puncture resistant container and label "Chemically Contaminated Sharps". Call EH&S for a waste pick-up.
- If uncertain, contact the EH&S at 812-855-6311.
Radioactive Materials
- Contact the Radiation Safety Office (812-855-3230) to relocate any radioactive materials to another laboratory, to remove these materials from the University or the radioactive material inventory, for decontamination of the work area, and to conduct a final survey of the vacated area.
Equipment
- Clean and disinfect equipment as is appropriate before departing. especially equipment in which biohazardous material was used or stored. Alert EH&S and Facilities Management of exhaust or filtration equipment used with extremely hazardous substances or organisms.
- If moving biological safety cabinets, decontaminate before moving and recertify before use in the new location.
- Deface or cover hazard labels on equipment to be moved or discarded.
- When discarding laboratory equipment: remove capacitors, transformers, mercury switches, mercury thermometers, radioactive sources, chemicals and biohazards before disposal.
Movement and Transportation of Hazardous Materials
Laboratory close-out and the subsequent movement of hazardous materials may require movement of materials within the University or to another university. Accidents during movement or transportation of any of these materials can result in serious harm to persons and property. For this reason, federal law and University policies require that persons who move or transport hazardous materials in the course of their employment or on behalf of the University are:
(i) Trained and authorized to handle and transport hazardous chemicals within University property; and
(ii) Licensed and/or certified to package and transport hazardous materials off University property.
The movement of hazardous chemicals can occur in three ways; 1) within the University buildings between rooms or laboratories; 2) within the University between buildings, departments, branch campuses, or into the field for research and 3) to other institutions or entities such as another university, a waste disposal facility, or a return to the manufacturer. Certain federal laws and public safety concerns require that there be some control over movement of these materials. It is important to the safety of all members of the University community on each campus that movement of hazardous materials be restricted to persons who have received training, can carry out the task safely, and adequately handle an emergency should an accident or chemical spill occur.
Ownership and liability for chemicals used in University research belongs to the University not the Principal Investigator. When Principal Investigators leave an institution, the research gets transferred to the new institution, which then becomes the owner. The original institution is legally responsible for the shipment to the new institution. The transfer of ownership of the chemicals needs to be documented in the transfer of ownership of the research and equipment.
- Hazardous Chemicals: Off site transportation of hazardous chemicals should only be done by DOT licensed hazardous material carriers to another location via a public thoroughfare. Toxic materials, carcinogens, highly reactive chemicals controlled substances, and other restricted chemicals should be moved by trained laboratory staff only. All chemicals should be properly labeled and packaged. Incompatible chemicals should not be placed together during storage or transport. Secondary containment should be utilized to control spilled material.
- Radioactive materials: Removal of radioactive materials from the University is prohibited without prior approval of the Radiation Safety Office. Contact the Radiation Safety Office (812-855-3230) to remove any of these materials from the University and make arrangements for shipment.
- Biological Materials: Off site transportation of biohazardous materials should only be done by DOT licensed hazardous materials carriers to another location via a public thoroughfare. Contact the IU Bloomington Biosafety Officer (812-856-3638) to make arrangement for shipment of biological materials.
Transportation of Hazardous Materials for Non-Commercial Purposes
A University employee handling and transporting hazardous materials in either a private or rented vehicle during the course of their work is performing non-commercial business. Transportation of hazardous materials for non-commercial business is not subject to Department of Transportations (DOT) Hazardous Material Regulations found in 49 CFR Parts 171-180.
The handling and movement of hazardous materials and waste within a building between rooms is governed by 29 CFR Part 1910.1200, Hazard Communication, 29 CFR Part 1910.1450, Occupational Exposure to Hazardous Materials in Laboratories, and 40 CFR Part 262, Standard Applicable to Generators of Hazardous Waste. These standards have specific training requirements that must be met to ensure that employees are thoroughly familiar with proper handling and emergency procedures. This training is provided by EH&S.
Similarly, the handling and movement of hazardous materials between buildings, between campuses, or into the field for research, in University vehicles by University personnel for non-commercial purposes are not subject to the DOT Hazardous Material Regulations. However, these personnel must 1) have a valid driver’s license, 2) be authorized to use a University vehicle, 3) use a University vehicle (private or rented) or an authorized service vehicle (DO NOT use personal vehicles), 4) use the proper containment and packaging materials en-route and 5) and have one or more of the following training programs. EH&S provides this training.
i) Hazard Communication, 29 CFR Part 1910.1200,
ii) Occupational Exposure to Hazardous Materials in Laboratories, 29 CFR Part 1910.1450,
iii) Standard Applicable to Generators of Hazardous Waste, 40 CFR Part 262 including emergency procedures to be used in the event of an accident.
Transportation of Hazardous Materials for Commercial Purposes
University stockroom employees that receive hazardous chemicals shipped by commercial carriers are subject to the training requirements found in the DOT Hazardous Material Regulations found in 49 CFR Parts 171-180. This training is provided by EH&S.
Chemicals being shipped to another institution or business that are offered to commercial carriers are subject to the DOT Hazardous Material Regulations found in 49 CFR Parts 171-180. Because the ownership of chemicals being moved to another institution changes the transportation becomes a commercial enterprise and these transportation requirements are also subject to the DOT Hazardous Material Regulations found in 49 CFR Parts 171-180. Therefore the commercial carrier must be licensed to transport hazardous materials in accordance with federal law.
In the case of transportation of complete chemical collections to another university, the commercial carrier must package their own containers using properly trained, licensed and/or certified individuals to ensure that the materials are properly segregated for shipping, packaged in DOT approved containers, labeled, and shipped with the proper manifest or shipping documents in accordance with the DOT regulations.