Moving? Know Your Environmental Decommissioning Lease Requirements
July 7, 2021
Is your life science research and development or manufacturing business preparing to move into a new facility? Your lease probably requires environmental decommissioning services such as decontamination, permit closure, clearance sampling, and an environmental assessment report, such as a Phase I Environmental Site Assessment, ANSI Z9.11 Laboratory Decommissioning Survey, Exit Assessment or Exit Survey. Environmental Decommissioning involves numerous steps to prepare your site for surrender.
- Risk Assessment
To ensure your site is ready for surrender to the property owner, a new tenant, or safe for demolition, an environmental risk assessment should be performed to evaluate potential hazards onsite. A third-party environmental professional should evaluate your company’s operations, chemical and biological inventories, and onsite processes to identify potential environmental risks. Several standards are used to conduct an environmental risk assessment, including: the Phase I Environmental Site Assessment per ASTM E-1527-13 standard, the ANSI/ASSP Z9.11-2016 Laboratory Decommissioning Standard, a Surrender Plan or Exit Survey based off your lease requirements.
- Decommissioning Hazardous Materials Closure Plan
Once a risk assessment is conducted, a decommissioning or hazardous materials closure plan will be formulated and implemented. The plan should include: a blueprint for the removal of hazardous materials and waste, decontamination of equipment and hazard areas, permit closure, and preparation of final status report that documents the decommissioning site.
- Removal of Hazardous Materials and Biohazardous Materials
About three months before your move, have your hazardous materials transporter conduct an evaluation of the chemicals and waste that need to be moved or disposed of for the site relocation or closure. Waste profiles and scheduling may take time, so it is important for the waste transporter to identify exactly what is onsite. Once the hazardous and biological materials and waste are removed from the site, the site will be decontaminated.
- Decontamination of Hazard Areas
Decontamination typically occurs in two steps: 1) decontamination of all equipment that needs to be transferred and used at the new facility or is being sold, and 2) decontamination of fixed laboratory equipment and hazard areas that are within the leased space. Decontamination methods used vary based on the biological or chemical hazard(s) present at your site. Biological decontamination should be conducted in tissue or cell culture suites, vivariums, biological safety cabinets, environmental chambers, cold rooms, biohazardous waste storage areas, and other potentially biohazardous storage or use areas or equipment. Chemical decontamination should be conducted in chemical storage rooms, hazardous materials storage buildings, hazardous waste accumulation areas, fume hoods, chemical storage cabinets, filtered balance stations, and other chemical hazard areas. In some cases, your site may require or request environmental clearance sampling post decontamination to provide data that no elevated levels of contaminants remain onsite. For integrity, a third-party environmental professional should conduct both the decontamination and clearance sampling.
- Permit Cancellation
All environmental permits and registrations with local Certified Unified Program Agency, Department of Environment, Environmental Protection Agency, Air Pollution Control District, Air Quality Management District, Fire Department, Wastewater Authority, etc. should be inactivated or transferred prior to surrender. Some permit inactivation requires advanced notice to the regulator and an onsite closeout inspection. Radioactive Materials Licenses and Drug Enforce Agency registrations are the most time sensitive and termination or transfer must be planned for six to nine months before anticipated site closure.
- Final Status Report
The final step of the decommissioning process is to have your third party environmental professional document all the steps implemented for the hazardous materials site closure and provide all documentation in a final status report. This report will not only provide the property owner or future tenant of the space with evidence that the site was properly decommissioned and fulfill your lease requirements, but will also provide business liability risk coverage for your company.
If your business needs assistance with any of these services in the San Diego, California, San Francisco, California or Austin, Texas areas please contact:
Alexis Rodriguez, MCP, QISP, ASP
Manager of Environmental Projects
Occupational Services, Inc.
Cell: 619-920-0691
Email: alexis@occserv.com
www.occserv.com
An ISO-17025 Accredited Company