Lab Relocation Regulation Quicknotes

Lab Relocation Regulation Quick Notes

Spark a compliant lab move with these quick-flip notes on the most

important regulations to your move.

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Introduction

EPA

DOT & IATA

The Process

Local & Facility

Conclusion

Introduction

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Lab Relocation Regulation Quicknotes

Introduction

Lab relocations are hard enough without remembering all the regulations. Throw requirements by law into the mix and you have more than enough to think about. Unlike most other projects, a lab relocation requires you to consider the regulations that govern your current facility, the facility you’re moving to and regulatory bodies that govern the transportation you’re using to get your stuff from one facility to the next.

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Introduction

A&er your headache subsides from trying to do it on your own, flip through our quick )ps and summaries of the rules and regula)ons you need to know for your lab reloca)on to run smoothly. We’ve compiled it all in one place just for you. Let’s start with how to handle all these regulatory requirements.

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Introduction

EPA

DOT & IATA

The Process

Local & Facility

Conclusion

The Process

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The Process

Before you can idenGfy what regulaGons may be applicable, you must clearly understand your opera)ons. Generally, any type of work with hazardous materials will be regulated from local ciGes all of the way up to federal agencies. The amount and type of regulaGon is dependent on the type and volume of hazmat. Some material types that will have regulaGons associated with them include: chemicals, biological materials, select agents, radia)on, or DEA regulated materials.

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The Process

When wading through this ocean of regulaGons, always begin by making sure you’re compliant with your most local requirements and regulaGons and work your way out to state and federal. Some towns and ciGes have specific requirements regarding facility use, hazmat regulaGons, and other ordinances that impact your business. From there, each state may regulate specific acGviGes differently. With this strategy in mind, we’ll first be addressing facility and local regula)ons.

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Introduction

EPA

DOT & IATA

The Process

Local & Facility

Conclusion

Local & Facility

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Local & Facility

Every facility will have different regulaGons, permits, and licenses to operate their site. RegulaGons are generally dictated by two variables: 1) the loca)on of your facility and 2) the types of ac)vi)es occurring at your facility.

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If you’re unsure about your faciliGes regulaGons and requirements, reach out to the property manager for the proper documentaGon. Likewise, local requirements can usually be found on the city’s website. If you can’t locate them on the site, contact the city and schedule a mee)ng to discuss requirements and necessary permits. Keep in mind that you have to do this for the locaGon you’re moving into as well as the locaGon you’re moving out of.

Local & Facility

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A&er determining citywide requirements, go through the same process for your state. Your state’s EPA branch or DOT branch might have addi)onal rules and regula)ons on top of the federal ones. Keep in mind, state rules are always more stringent than federal ones.

Local & Facility

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A&er determining all local and facility requirements, you should check to make sure you’re not overlooking anything on the federal level. There are several regulatory bodies you should check with and plan accordingly for before beginning your move. Here they are.

Local & Facility

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Introduction

EPA

DOT & IATA

The Process

Local & Facility

Conclusion

EPA

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EPA

The EPA gets involved when you start disposing of hazardous waste as part of your lab relocaGon. Hazardous waste is regulated as part of the EPA’s Resource ConservaGon Recovery Act (RCRA). Find below some of the most important regulaGons to keep in mind.

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EPA

Regulations Disposal of hazardous waste is regulated in RCRA 40 CFR Parts 239 – 282. These regulaGons are important to know. The same regulaGons for waste disposal apply throughout your lab move, conGngent upon the type and amount of waste you’re disposing of.

Iden)fica)on Make sure you’re following the proper procedures for idenGfying waste as hazardous, solid, or exempted waste.

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EPA

Responsibili)es Know that if you’re a generator of waste you must obtain an idenGficaGon number, prepare a manifest, ensure proper packaging and labeling and more. Before disposing of any waste you must understand all your responsibiliGes.

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EPA

Storage (Tanks and Containers) All waste must be tested to determine concentraGon before stored and saGsfy tank and emission standards. .

This is a general overview of EPA standards in terms of hazardous waste removal. For more informaGon on hazardous waste RCRA regulaGons, visit their website here. All chemicals not being disposed of are probably being transported to your new facility. For these, you need to be mindful of DOT and IATA standards. Here they are.

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http://www.epa.gov/epawaste/inforesources/online/index.htm

Introduction

EPA

DOT & IATA

The Process

Local & Facility

Conclusion

DOT & IATA

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DOT & IATA

DOT The transport of hazardous materials via road and air are heavily regulated. If you intend on moving any hazardous materials in this way, you must comply with DOT and/or IATA transport regulaGons. These regulaGons are significant in scope and regulate both the shipper and the transporter. We’ll focus on DOT first. Here are some responsibiliGes you have for remaining DOT compliant. •  Shippers are responsible for preparing and

packaging hazmat shipments; there are also training and record keeping requirements.

•  All people involved with the transportaGon of hazardous materials must be DOT hazmat trained.

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DOT & IATA

DOT RegulaGons: The PHMSA branch of the DOT is exclusively dedicated to the safe transportaGon of hazardous material. For moving your laboratory Title 49 Part 172 should be your point of focus. In the link above, you can find the main points of this regulaGon synthesized. For the complete text of the regulaGon, look here.

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http://www.law.cornell.edu/cfr/text/49/part-172

http://phmsa.dot.gov/portal/site/PHMSA/menuitem.146906cb99fdf34f8113ae92e90d8789/?vgnextoid=56acd3c1af814110VgnVCM1000009ed07898RCRD&vgnextchannel=56acd3c1af814110VgnVCM1000009ed07898RCRD&vgnextfmt=reg172&baseReg=172

DOT & IATA

DOT RegulaGons •  Shipping Papers: All shipping papers should

include a descripGon of the hazardous materials. There can’t be any abbreviaGons unless otherwise specified. The person wriGng the shipping papers must retain a copy. The label must include an emergency phone number.

•  Marking: The offerer and carrier must mark each piece of hazardous material for shipment. The type of marking is dependent on the subcategory in which it falls. This includes bulk, non bulk, poisonous, etc.

•  Labeling: All hazmat offered for shipment must be labeled properly.

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http://www.law.cornell.edu/cfr/text/49/part-172/subpart-C

http://www.law.cornell.edu/cfr/text/49/part-172/subpart-D

http://www.law.cornell.edu/cfr/text/49/part-172/subpart-E

DOT & IATA

DOT RegulaGons •  Placarding: All hazmat must be placarded

properly. Here are the types of placards that can be chosen from.

•  Emergency Response Info: Emergency response informaGon must be readily available on all containers being offered for shipment unless otherwise noted.

•  Training: All DOT personnel must be DOT hazmat trained if they are involved in any part of the DOT shipment process.

•  Safety and Security Plans: This plan should address all security risks in relaGon to the transportaGon of your hazmat. Anyone offering hazmat for shipment must develop and adhere to a security plan.

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http://www.phmsa.dot.gov/pv_obj_cache/pv_obj_id_058C261A5CEE28873576D096AB614E27E8DE1A00/filename/Placarding_Requirements(04-07).pdf

http://www.law.cornell.edu/cfr/text/49/part-172/subpart-G

http://www.law.cornell.edu/cfr/text/49/part-172/subpart-H

http://www.law.cornell.edu/cfr/text/49/part-172/subpart-I

DOT & IATA

IATA The InternaGonal Air Transport AssociaGon regulates air transportaGon across conGnents. These regulaGons are only applicable if you’re transporGng your lab via air. If these regulaGons apply to you, look here.

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http://www.iata.org/whatwedo/cargo/dgr/Pages/index.aspx

Introduction

EPA

DOT & IATA

The Process

Local & Facility

Conclusion

Conclusion

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Conclusion

Non-‐compliance with any of these regulaGons can result in unsafe procedures and hundreds of thousands of dollars in fines. Some violaGons could even result in the shut down of your enGre operaGon. With the help of this guide, you can keep the compliance of your project operaGons in check. If you have any addiGonal quesGons about the compliance of your lab move, feel free to contact one of our experts.

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http://www.triumvirate.com/contact-our-sales-and-service-team/

Complete Lab Relocation Services

Our lab relocation services are the only in the industry that will cover all EH&S related aspects of your move. Here is an overview of what we’ll do for you. •  Risk assessment and mitigation •  Environmental reporting •  Lab move planning and logistics •  Lab packing/unpacking •  Lab decontamination Want more information on our lab relocation process? Check out a video walk through of our comprehensive process or a case study example.

Video Walk-‐Through

Case Study

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https://triumvirate.wistia.com/medias/mio55q5x8a

http://info.triumvirate.com/lab-relocation