This policy ensures all Laboratories and Research Support Spaces are properly cleaned and decontaminated prior to Decommissioning to mitigate the risk of exposure to Hazards and to maintain regulatory compliance during the Decommissioning process.

This policy applies to all University Departments where Research Laboratories, Research Support Spaces, workshops, teaching laboratories, or other similar spaces exist; to Laboratory Supervisors with responsibility for areas where Hazardous Materials are stored and/or used; and to the Department of Facilities Management (FM) when coordinating renovations in Laboratory, Research Support Spaces, workshops, teaching laboratories, or other similar spaces.

Decommissioning a Laboratory or Research Support Space is required when a Laboratory Supervisor leaves the University, will no longer use the laboratory at the University, or when a Laboratory is prepared for demolition or renovation. Prior to Decommissioning, the University must clear the Laboratory of all Hazardous Materials, and properly manage all Hazardous Materials and Decontamination of any potentially contaminated surfaces and equipment.  

Laboratory Supervisors must remove all Hazardous Material containers from the space in a safe and proper manner by:

• Shipping Hazardous Material to an off-site location;
• Returning gas cylinders to a manufacturer/distributor;
• Transferring containers an approved internal, on-site Brown Researcher with appropriate and current training and storage space; and/or
• Disposing the Hazardous Material in accordance with all biological, radiation, and Hazardous Waste procedures.

Regulations hold Brown University responsible for shipment of any Hazardous Materials even if the destination is paying the costs of moving. Under no conditions may anyone self-transport Hazardous Materials. Hazardous Materials are not permitted to leave the building unless the packaging and shipping is approved by the Office of Environmental Health & Safety (EHS).

The University must ensure surfaces are decontaminated before:

• Space is transferred to a new user;
• Either FM or an outside contractor remodels, renovates, or demolishes the space or any portion of it;
• Either FM or an outside contractor repair or perform maintenance on equipment;
• Equipment is disposed or relocated; and
• Equipment is returned to manufacturer for repair or replacement.

A University-approved vendor must be used for Decontamination of all Laboratory surfaces, where Hazardous Materials were used, including, but not limited to, benchtop surfaces, chemical fume hoods, Biological Safety Cabinets, and equipment. Decontamination methods will depend on the Hazardous Materials used.

The Laboratory will be cleared for renovation or new occupancy only after the University confirms that Hazardous Materials were properly removed, surface and equipment Decontamination is complete, regulated waste containers have been removed, hazard signs/labels are removed, and the Decontamination forms are posted. Additionally, if equipment is being transferred to a new owner or facility or is intended for disposal, the Disposition of Brown University Surplus Property Policy must also be followed.

For the purpose of this policy, the terms below have the following definitions:

Decommissioning: The process by which a room is safely transitioned from being occupied to being vacated, and its surfaces are decontaminated through cleaning and/or removing Hazardous Materials (including, but not limited to, chemical, biological, and radiological Hazards).

Decontamination/Decontaminate: The process of removing or destroying Hazardous Materials from an area or object.

Department: An administrative unit of faculty members joined by common intellectual field or academic discipline. Departments, which house both teaching and Research programs, have a governance structure and are the only academic units that may grant tenure.

Department Space: Space controlled by and, usually, housed within a specific Department.

Hazardous Materials or Hazards: Any material or substance (chemical, biological, radiological) that poses a physical or health risk capable of causing negative effects on the health and safety of humans, animals, or the environment. This includes but may not be limited to Hazardous Materials or substances regulated by the Department of Transportation (DOT), Occupational Safety and Health Administration (OSHA), and/or Environmental Protection Agency (EPA).

Hazardous Waste: A chemical substance or chemical product that is no longer intended or viable to use for work, Research, or academic purposes and meets specific criteria established by the Environmental Protection Agency or the RI Department of Environmental Management.

Laboratory: A facility where the use of Hazardous Materials occurs. It is a workplace where relatively small quantities of Hazardous Materials are used on a non-production basis.

Laboratory Supervisor: The University employee with responsibility for the conduct of Research and overall safety within the Laboratory. The Laboratory Supervisor may be the Principal Investigator or PI on the Research that involves the use of Hazardous Materials and is typically a faculty member.

Research: A systematic investigation, including development, testing, and evaluation designed to develop or contribute to generalizable knowledge.

Research Support Spaces: Any room that involves work for the purpose of Laboratory Research including stockrooms, tissue culture rooms, instrument rooms, autoclave rooms, cold rooms, storage and freezer spaces, and animal care facility spaces.

Researcher: Any University Member that conducts Research at Brown.

University Member: For purposes of this policy, University Members are Brown faculty, employees, staff, students (under certain conditions as described in this policy), volunteers, fellows and trainees, visiting faculty and Researchers, and those employees and visitors covered by sponsored Research agreements or other contractual arrangements.

All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure compliance with it.

Department of Laboratory Supervisor: The Department of the relevant Laboratory Supervisor is responsible for ensuring the Laboratory Supervisor follows this policy. If there is no responsible Laboratory Supervisor, the Department has sole responsibility for proper Laboratory closeout and assumes the duties of the Laboratory Supervisor provided in this policy. Department responsibilities also include:

• Notifying EHS in writing of the intention of the Laboratory Supervisor to vacate the Laboratory space or depart the University as soon as possible to allow for adequate time to plan and implement the process.
• Paying all costs incurred for Laboratory close out not covered by the Laboratory Supervisor’s new place of employment or a renovation project managed by FM.

• Ensuring that non-Laboratory individuals (e.g., Department Managers, Program Coordinators, Administrative Coordinators, etc.) within the Department designated to be responsible for the closeout do not take part in any physical clean-up activities in the Laboratory, and that they are only allowed to work with EHS to coordinate the cleanout.

Facilities Management (FM): FM is responsible for ensuring this policy is followed for renovations in a Laboratory or Research space, and will pay costs associated with decontamination and removal of equipment as part of the renovation project. Individuals within FM designated to be responsible for the closeout must not take part in any physical clean-up activities in the Laboratory; they are only allowed to work with EHS to coordinate the cleanout.

Environmental Health & Safety (EHS): EHS is responsible for providing guidance as needed related to Laboratory Safety, Biological Safety, Radiation Safety, and Hazardous Waste programs including:

• Assisting with the transfer of unwanted Hazardous Materials within the University;
• Supporting updates to the University’s chemical inventory in the Chemical Environmental Management System as needed;
• Ensuring individuals approved to adopt Hazardous Materials during the adoption process of Hazardous Materials are following appropriate training and storage requirements;
• Coordinating proper disposal of unwanted Hazardous Materials and/or Hazardous Wastes;
• Recommending approved contractors for Decontamination needs;
• Recommending approved Hazardous Material transportation or specialized moving contractors to facilitate the compliant transport of Hazardous Materials to another university, facility or outside company; and
• Ensuring the University has met safety and regulatory requirements prior to spaces being turned over for renovation or new occupancy.

Laboratory Supervisor: It is the Laboratory Supervisor’s responsibility to ensure the proper closeout of the Laboratory. Responsibilities include:   

• Notifying EHS of the intention to vacate the Laboratory space or depart the University as soon as possible to allow for adequate time to plan and implement the process.
• Ensuring the Laboratory Supervisor’s new employer, if applicable, pays costs incurred for Laboratory close out, such as shipment of hazardous materials and equipment to the new place of employment.
• Obtaining applicable quotes and scheduling required contractors for the close out process in coordination with EHS.
• Removing all Hazardous Materials in a safe manner according to University processes and procedures.
• Ensuring all equipment and Laboratory surfaces have been decontaminated and cleaned in accordance with this policy.
• Ensuring all unwanted Hazardous Materials, samples, vials, or other Research materials are properly labeled or otherwise identified.
• Ensuring all chemicals, biologicals, and radiological and temperature-controlled materials and equipment leaving campus are handled in compliance with all federal regulations (see Section 7.5).
• Following the Disposition of Brown University Surplus Property Policy.

Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures.

All Hazardous Materials, samples, vials, or other Research materials left behind after the Laboratory Supervisor has vacated the space are subject to disposal in accordance with all biological, radiation, and Hazardous Waste procedures at the discretion of the Department of the Laboratory Supervisor.

Brown University is a community in which employees are encouraged to share workplace concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).

The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.