If improper management of hazardous materials at closeout requires removal services from the Department of Environmental Health and Safety Office (EHSO) or from an outside contractor, the responsible department will be charged for this service.

Any regulatory action or fines resulting from improper management or disposal of hazardous materials will accrue to the responsible department. DEHS will not be responsible for loss incurred by individuals or departments as a result of regulation-mandated removal of hazardous materials.

Closeout Procedures for Hazardous Materials in Laboratories

The following procedures should be completed when the responsible individual leaves the University or transfers to a different laboratory.

Chemicals

1. Assure that all containers of chemicals are labeled with the name of the chemical. All containers must be securely closed. Beakers, flasks, evaporating dishes, etc. should be emptied. Hazardous chemical wastes must not be sewered or trashed; they must be collected for disposal. Check refrigerators, freezers, fume hoods and bench tops as well as storage cabinets for chemical containers.
2. Determine which chemicals are usable and transfer responsibility for these materials to another party who is willing to take charge of them. If a new user cannot be found, the materials should be disposed.
3. All other chemicals should be prepared for disposal. Detailed instructions are available in the University's Hazardous Chemical Waste Management Guidebook. This process may take quite some time and should be started at least a month before departure from the laboratory. Chemical pickup must be completed before the laboratory is vacated. Waste collection will take at least a week after submitting forms to the UMD EHSO. Unlabled collection containers and chemical products will take longer.
4. Wash off fume hood surfaces and counter tops.
5. Notify Department Head when laboratory has been cleared.

Controlled Substances

1. All aspects of controlled substance use in research must comply with the U of M Policy 2.1.4 found at http://www.fpd.finop.umn.edu/groups/ppd/documents/policy/controlled
   _substance.cfm
2. Abandonment of a controlled substance is a violation of the DEA permit under which it was held.
3. To comply with Federal regulations, notify the DEA before transfer of controlled substances ownership and transfer or termination of DEA registration. Contact the Office of Regulatory Affairs (626-1462 or ORA@umn.edu) for help with this process.
4. Notify Unit Registrant of pending lab closeout and work within the Unit and Department to transfer and dispose of controlled substances. Transfer or terminate controlled substance registrations with Minnesota Board of Pharmacy and DEA. Contact the Office of Regulatory Affairs (626-1462 or ORA@umn.edu) for help with this process.
5. Controlled substances being held by a licensed individual should be disposed of per University procedures: http://www.d.umn.edu/ehso/controlled_substances
6. If controlled substances for which the licensee is unknown are found, initiate the documentation for transfer of controlled substances of unknown origin per University procedures, described at http://www.d.umn.edu/ehso/controlled_substances

Gas Cylinders

1. Remove gas connections, replace cylinder caps, and return cylinders to suppliers.
2. If cylinders are non-returnable, consult  Compressed Gas Containers/Aerosol Cans

Animal and Human Tissue

1. If tissue is held in a liquid preservative, tissue and liquid should be separated.
2. If human tissue is in a recognizable form, contact Mahjoub Labyad, EHSO 7273, for disposal in University crematorium. Other human tissue specimens should be placed in a red biohazard waste bag and stored in approved cold rooms. Call EHSO 7273 to arrange for disposal. For more information on infectious waste disposal consult The Infectious Waste Management Program .
3. Animal tissue can be disposed by rendering (large animal parts) or by placing in a biohazard waste bag for incineration.
4. Liquid preservative usually needs to be disposed as a hazardous waste. Contact Chemical Waste for assistance. Do not assume that the preservative can be sewered.
5. If appropriate disposal is uncertain, contact the EHSO (7273).
6. Defrost and clean refrigerators and freezers if they are empty.
7. If samples need to be saved, locate appropriate person to take responsibility for them and notify Department Head. For more information on infectious waste disposal consult The Infectious Waste Management Program

Microorganisms and Cultures

1. If an autoclave is available, decontaminate waste and dispose in regular trash.
2. If material cannot be decontaminated, place in biohazard bag for incineration.
3. Clean incubators, drying or curing ovens, refrigerators and freezers.
4. If samples need to be saved, locate appropriate person to take responsibility for them and notify Department Head. For more information on infectious waste disposal consult The Infectious Waste Management Program

Radioactive Materials

1. Prior to closeout of a radioactive materials use area and/or a radioactive materials use permit, it is the responsibility of the department and the authorized permit holder to assure that the following steps have been completed.
2. Package all radioactive materials (stock vials, sealed sources, lead containers/shields, and wastes) and label them in accordance with the Radiation Protection Division (RPD) procedures for pickup as radioactive waste, or for transfer to another permitted use area. Consult The UMD Radiation Protection Program for more information on Radioactive waste disposal.
3. Prior to the transfer of Rad Materials, notify the UMD EHSO (7273) to obtain authorization for the transfer and to assure that the new use area is properly posted and permitted by RPD.
4. Arrange for pickup of all radioactive wastes by EHSO. (fax waste pickup request form to 8127.)
5. Following removal of all radioactive wastes and stock materials, perform a contamination survey (and if appropriate a GM instrument survey) of all former storage and use areas within the laboratory or under the permit to be closed out. NOTE: Areas of potential residual contamination include refrigerators/ freezers, centrifuges, water baths, hoods, sinks, floor areas under waste containers, etc. Also, if there are contaminated areas or equipment in the laboratory, they must be decontaminated. A follow-up survey must be made of the decontaminated areas and the results included in the above survey.
6. Provide the Department Head and the UMD EHSO with a copy of the final contamination survey.
7. Schedule the Radiotion Safety closeout survey by EHSO (7273). Do not allow further use of room until the RPD closeout survey is complete and the radiation caution door posting is removed by EHSO.
8. If the permit holder fails to satisfactorily complete the above steps, he Department will be responsible for the completion of (or payment of costs to complete) the required closeout steps. The Department is responsible for immediate notification of the UMD EHSO if the above steps have not been completed.

Mixed Waste/Hazards

1. Occasionally it is necessary to dispose of materials that contain more than one of these hazards. Contact the the UMD EHSO (7273) for chemical, radioactive or biological agent assistance.

Equipment

1. If laboratory equipment is to be left for the next occupant, clean or decontaminate it before departing the laboratory. If exhaust or filtration equipment has been used with extremely hazardous substances or organisms, alert EHSO and Facilities Management.
2. If laboratory equipment is to be discarded, be aware that capacitors, circuit boards, transformers, mercury switches, mercury thermometers, radioactive sources and chemicals must be removed before disposal. Contact EHSO (7273) for assistance.
3. Equipment potentially contaminated with radioisotopes should be surveyed by Environmental Health and Safety.

Shared Storage Areas

1. One of the most problematic situations is the sharing of storage units such as refrigerators, freezers, cold rooms, stock rooms, waste collection areas, etc., particularly if no one has been assigned to manage the unit. Departing researchers must carefully survey any shared facility in order to locate and appropriately dispose of their hazardous materials.

Regulatory Impact

Mishandling of hazardous materials can result in citations, fines and/or loss of right to use hazardous materials. Adverse publicity is also a frequent result. Fines are paid by the department incurring them.

Hazardous Materials Closeout Procedures Check-List Form