Most people dislike dealing with hazardous materials. Fortunately, the trend is to purchase, use and store fewer toxic materials in the workspace. Unfortunately, there is the legacy of hazardous materials left behind from a less enlightened time as well as hazardous materials used in R&D and manufacturing operations. Since environmental management is an important responsibility of every facility manager, you need to make sure that they are stored, used and disposed of safely. When it comes time to shutting down an operation and moving out of a facility, we have a responsibility to current and future stakeholders, including future occupants of the facility to ensure that the premises are safe without risk of exposure to hazardous materials that could cause illness or even death. Since we must deal with the hazardous waste properly, I will share my experience, how I was able to mitigate risks, minimize costs and expedite the work while making the process more pleasant.
Recently, I was asked to take over the building closure and hazardous materials removal from a company that went out of business before completing the work. The building was leased and the tenant had failed to complete the hazardous materials closure, so the fell to the building owner. Since 80% of the work had been completed by the former tenant and the landlord didn’t have extra bandwidth to complete the job quickly, they asked our company to complete the closure as quickly and inexpensively as possible. Most importantly, the building closure needed to get completed properly to ensure that all hazardous materials risks are eliminated for future tenants.
The process starts with a closure plan and ends with getting final approval from the hazmat inspector, but having closed technology buildings with hazardous materials from Silicon Valley to Japan, I know there is much more to it than that. Let’s dive a little deeper.
1. Know what you have and keep it current
Start with the latest Hazardous Materials Business Plan (HMBP) for your site as the basis for your hazmat closure. An HMBP is a document containing detailed information on the storage and use of hazardous materials at a facility. The purpose of an HMBP is to provide information to emergency responders, but it’s also a great tool for the basis of your hazmat closure plan.
The HMBT is your roadmap for removal of hazardous materials and building closure; use it to determine your plan of action. Therefore, obtain a copy of the latest report and compare it to your site survey and responses from the latest building operators to determine what you are up against before taking the next step.
2. Hire the Right Consultants
Finding the right consultants for your closure project is especially critical if your operation used hazardous materials during for R&D and manufacturing processes. Epicus Group has extensive experience with all types of work environments and hazardous materials. If you hire consultants with little or no experience with heavy metals, for example, and they were used in your facility, then your closure process will likely take longer, cost more and make your bosses unhappy.
In addition, work with consultants that have a good relationship with your inspector. I had an inspector once who was concerned that hazardous materials may have gotten into the office area carpet and suggested that we test multiple areas or clean the entire carpet (which the prior tenant had not done) then treat the carpet cleaning waste as hazardous waste. But he wasn’t sure and during our last walk-thru, I could see that he had a lot of respect for my industrial hygienist because he kept asking for his opinion and ideas. Ultimately, my industrial hygienist suggested that since the carpet was not likely contaminated, if we just sampled a spot on the tile floor adjacent to the carpeted area that would likely suffice. And he was right – it turned up with negligible traces, saving us a lot of time and work.
3. Partner with your hazmat inspector
Look at your hazmat inspector as a team member and not as an adversary. Listen to his or her concerns and work with them to develop solutions. Oftentimes, they look to you and your team to make the suggestions; be prepared to discuss alternatives and why you recommend one tactic over the others. The key to remember is to include your inspector in your proposed action before you act. And of course, communicate your progress and setbacks with your inspector. With reductions in city budgets, your inspector may be stretched and stressed, so make his or her job easier by being prepared during your inspections and listen to their concerns. Remember, he or she wants to get the project completed too.
4. Develop a plan and execute
Like other projects, you will need to establish a budget and schedule that you should review with decision makers prior to executing. Add contingency to both as you should expect the unexpected to happen, like when a mysterious powder showed up during an inspection with the city (oops!). He asked us to test it even through everyone thought it was harmless. Guess what? It wasn’t! But since we had built a trusting relationship with our inspector, we were able to empathize with him and ask ourselves, “What would John want?” When we called our inspector with our recommended plan (along with an option that we rejected) he quickly agreed with our recommendation, saving us time and money.
5. Realize that something will go wrong
No matter how much you plan (and you need to have a detailed plan from the start), surprises will happen. When the unexpected happens, you will need to develop options, make recommendations, justify your recommendations and explain the cost and schedule impact of each. Once your scope change has been approved, you will be expected to execute quickly and flawlessly.
For example, during one project my team all agreed on a course of action to clean a concrete slab of heavy metals. However, after the cleaning the test results showed that the area was still contaminated. We came up with several options and a recommendation to remove the contaminated part of the floor. When I asked one of my contractors to provide a quote, he surprised me by telling me about an alternate cleaning method because he had encountered this same problem before. I presented this option to my team, the inspector and the client, obtained approvals then successfully completed the task faster and cheaper than our initial recommendation.
6. Communicate, Communicate, Communicate
Finally, I can’t overemphasize how important it is to communicate successfully before and during your building hazmat closure project. These projects usually have high visibility and you need to keep your team focused and involved. Your boss and building owner will need to know how the work is progressing. I once sublet a building that contained numerous hazardous materials. The subtenant was very anxious to move in so there was a lot of pressure to close the hazmat plan so they could occupy the space. Even if the space is empty, the building owner will be anxious for completion because they can’t even make improvements or lease it again until the hazardous materials plan and permit have been finalized.
Hopefully my six key points will be helpful in making your next (or first) hazmat building closure project a success and have it go as smoothly as possible. Good Luck!