The recent completion of the new Cheng Yu Tung Building (CYTB) is the latest on the list of establishments that equip HKUST to embrace the challenge ahead. Although commissioning of the building has yet to be completed, users are fully aware of the need to start working in the CYTB soon. While users may be preoccupied with the logistic and schedule for taking over the new laboratory assigned in the new building, it is equally important that occupants should take time to think about the laboratory they will leave behind for the next occupant. Vacating of a laboratory space may present more safety concerns than we can imagine.
Decommissioning is the term used by the American National Standard Institute (ANSI) to describe a process that ensures a facility and its associated infrastructure meet environmental health and safety requirements for its next use. For research laboratories, a systematic approach for decommissioning is recommended as research activities may involve the use of or generate hazardous materials that require special handling and treatment before proper disposal. More important, some of these materials are regulated by regulatory agencies that require due reporting of relocation and disposal.
Major components of the laboratory decommissioning process include analysis of the needs and scope of the decommissioning; risk assessment and characterization of the laboratory; remediation and mitigation to ensure the laboratory is fit for next use; and finally, verification of the decommissioning process with proper documentation.
The decommissioning process begins with the analysis of the needs and scope. The task focuses on the determination of the extent of the decommissioning that will be needed, stakeholders' responsibilities, acceptance criteria for release and strategy. Occupants are requested to provide information on the usage, typical procedures performed in the laboratory and use of any hazardous chemicals. The purpose of risk assessment and characterization is to evaluate the potential risk of hazardous materials contamination and relocation of equipment which may contain potentially highly hazardous materials.
Remediation and mitigation are required if the vacated space is contaminated with hazardous substances. The process may include actual decontamination of the vacated space to ensure its suitability for next use. Verification of the general conditions of vacated space will take place after the overall cleanup. Verification consists of visual inspection, document review, confirmatory testing and identification of deviation from relevant standards. The vacated space will only be considered as safe for next use after completion of the verification process.
To address the needs of better managing laboratory decommissioning, HSEO has established a policy to provide occupants with guidance on the processes. The policy starts with an aim to follow the approach established in the ANSI Standard for Laboratory Decommissioning. The scope of decommissioning and the roles and responsibilities of departments, PIs, administrative units under HKUST's environment are clearly defined in the policy.
The policy provides a detailed list of hazardous materials and equipment which requires proper decommissioning before removal can be taken place. Some of the typical examples are laboratories that handle regulated chemicals covered under various regulations and radioactive isotopes or irradiating apparatus such as X-ray machine. Proper documentation of these decommissioning processes is important as disposal and relocation of any regulated items require due reporting to the relevant regulatory agency. Failing to report disposal or relocation of the regulated items in a timely manner is, in many cases, a legal offence. On top of the needs to report removal of such items, contamination survey such as surface swipe is needed to ensure the vacated space is free of contamination of the hazardous materials before next use. Furthermore, equipment which has been used for handling and processing highly hazardous materials may present potential safety concerns to the workers transporting the equipment. Biological Safety Cabinet and Chemical Vapour Deposition are typical examples of equipment which require thorough decontamination before transferring or disposal.
At the end of the decommissioning process, occupants are required to contact representative from HSEO to verify thorough decommissioning of laboratory equipment and decontamination of laboratory before handing over the vacated space to the next occupant. Only with the thoroughly implemented procedures, will the new occupants be ensured to have a safe laboratory space to begin their new endeavor.