Decommissioning and Disposal of Health Facilities and Health Technology
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Contents
- 1 OVERVIEW
- 2 POLICY AND SERVICE CONTEXT
- 3 PLANNING FOR DECOMMISSIONING AND RETROFITTING
- 3.1 Background
- 3.2 Contamination Control and Risk Planning
- 3.3 Minimisation of waste
- 4 SYSTEMS AND UNIT SPECIFIC DECOMMISIONING
- 4.1 Radiology facilities
- 4.2 Laboratory facilities
- 4.3 Intensive Care Units, Operating Rooms, Nursing department and Isolation Facilities
- 4.4 Filtration Media
- 4.5 Wet services
- 4.6 Information technology infrastructure
- 4.7 General building and administration facilities
- 4.8 Decommissioning and Disposal of Health Technology Equipment
- 5 EXAMPLE WORKSHEETS, CHECKLISTS AND PROTOCOLS
- 5.1 Checklist: Infrastructure Decommissioning and Disposal
- 5.1.1 Health Infrastructures need to take account of the following steps when considering the de-commissioning of any service and infrastructure.
- 5.1.2 Preparing a service for decommissioning
- 5.1.3 Engaging the stakeholders/market and understanding the response
- 5.1.4 Financial Impact
- 5.1.5 Other Factors: quality, performance, value for money, future demand
- 5.1.6 Laboratory equipment/Facilities Example checklists
- 5.1.7 Decommissioning Decision Record
- 5.2 References
- 5.1 Checklist: Infrastructure Decommissioning and Disposal
OVERVIEW
This article outlines the policy and service context and attempts to illustrate the desired planning principles and design considerations for Decommissioning and Disposal of Healthcare Infrastructure and Health Care Technology.
While this document outlines design requirements and acceptance criteria which have an impact on clinical services, these requirements are prescribed within the framework of the entire IUSS set of guidance documents and cannot be viewed in isolation. The following documents should be complied with, together with this document:
POLICY AND SERVICE CONTEXT
Introduction
Healthcare systems are dynamic and constantly changing. Amongst other changes, there are changes in healthcare infrastructure and healthcare technology to meet socio-economic needs and emerging medical requirements.
Healthcare infrastructure is constantly being adapted to meet a population’s healthcare needs. Such adaptation requires alteration of physical infrastructure and construction of new infrastructure. During the alteration or construction of new infrastructure part of or entire old infrastructure becomes redundant and need to be removed from service by decommissioning to be either re-used for other purposes or disposed of.
Health Technology is constantly changing and evolving. This change results in a short life-cycle compared to fixed healthcare infrastructure. Such changes result in old technology being removed from service and posing a health and occupational risk if not properly decommissioned. Health Technology which is out of service might even be re-commissioned for use at less demanding facilities, upgraded or disposed of.
This document provides guidance on procedures to be followed in decommissioning and disposal of healthcare infrastructure and health technology.
Healthcare facilities can generate two distinct waste streams. This document deals only with the waste generated in the decommissioning process and not with the waste generated from the operational waste stream. The terms waste, healthcare waste and healthcare risk waste in this document therefore only refers to forms of decommissioning waste.
Mothballing exists as an alternative to decommissioning. This document does not detail or discuss the requirements and protocols for mothballing.
Regulations, Guidelines, Standards and Definitions
Standards
- This document should be read in the context of the SANS 10248-1 Management of healthcare waste Part 1: Management of healthcare risk waste from a healthcare facility
- The ISO 14001 is the international standard for environmental management of activities
- SANS 10234: 2008 Globally Harmonized System of classification and labelling of chemicals (GHS)
Guidelines
- The Western Cape Guideline for Environmental Management Plans (EMPs) 2005 gives guidance on the development of an EMP for the decommissioning phase of the facility life cycle.
- World Bank’s (1999) EMP Guidelines
- The Department of Water Affairs and Forestry’s EMP Guidelines (CSIR, 2002)
- DEAT Framework for Health Care Waste Management (May 2000)
- Department of Water Affairs & Forestry, 2005. Waste Management Series. Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste.
Acts and Regulations
- Public Finance Management Act No.1 1999
- Hazardous Substances Act 15 of 1973 and its amendments
- National Environmental Waste Management: Waste Act 59 of 2008, and its amendments
- National Waste Classification and Management Regulations R634 of 2013
- National Waste Information Regulations R625 of 2012
- Regulation R1332 of 3 August 1973 Regulations Concerning the Control of Electronic Products
- Nuclear Energy Act, 1999 (Act 46 of 1999).
- Standard for Infrastructure Procurement and Delivery Management (2016)
Definitions
Healthcare infrastructure, healthcare infrastructure in this document refers to hospital facilities, buildings, wet services, cold and hot water systems, electrical reticulations, Air-conditioning system (HVAC and all its components, split-units and other ventilation systems), plant equipment, catering equipment, IT equipment and any other systems and equipment which form part of the hospital facilities.
Health technology, health technology in this document refers to medical equipment and/or devices, their accessories and any component(s) and or system which may provide a link between equipment and/or devices which is used in healthcare for the purpose of preventing, diagnosing, or treating diseases as well as for monitoring and rehabilitation.
PLANNING FOR DECOMMISSIONING AND RETROFITTING
Background
While engineering systems and components may have a functional life of less than 25 years, healthcare buildings could have a life approaching 50 years. It is therefore likely that equipment and services would need to be decommissioned, retrofitted, revitalised and replaced at least once during the life of a building and these interventions should be planned for.
Projects with a retrofitting element shall include for the formal decommissioning of equipment or services which become redundant or obsolete as a result of the retrofitting project or can be conveniently decommissioned within the project. Decommissioning of any assets shall be undertaken in accordance with the Public Finance Management Act, Generally Accepted Accounting Practice, Companies Act and Good Corporate Governance Practice.
When planning for retrofitting and decommissioning, consideration should be given to the following aspects:
- Establishment of a disposal management committee.
- Development of and compliance with an Environmental Management Plan (EMP).
- Development and implementation of a risk assessment and hazard control plan.
- Assignment of a clinician and IPC manager with authority to approve or halt construction activities only under defined conditions.
- Power requirements of future expansions and installations.
- Emerging healthcare technologies.
- Space for removal and refitting of equipment.
- Potential and planning for recycling vs disposal of materials.
- Toxicity and environmental impact of gasses, paints and polymers.
- Specific healthcare services risks (IPC etc).
- Occupational Health and Safety Regulations and requirements.
Contamination Control and Risk Planning
A project risk assessment shall be conducted and consider the following aspects:
- Identification of occupancy groups which are susceptible to risks.
- Identification of building services, such as ventilation, in the proximity of the construction activity and the potential impact on function. Specific consideration should be given to specialist ventilation systems.
- Need for supplementary protection or support systems for building services.
- Impact on fire protection and response systems and action plans.
- Impact of noise and vibration on occupants and equipment
Opportunistic environmental or airborne microorganisms, allergens or hazardous materials which are liberated or distributed during retrofitting and decommissioning activities, can present a significant hazard to patients and employees unusually at risk.
Where the environmental and risk assessments identify the need for intervention or mitigating controls, the precautionary matrix described below shall be considered in determining risk levels. The principles of contamination control for high risk sites includes the following:
- Establishment of rigid non-permeable barriers, between patient or staff and construction activities, during construction with the inclusion of appropriate clean-down ante-rooms where traffic between occupied and construction areas is required.
- Increased outdoor air equivalent ventilation rates with high ventilation efficiency to areas at risk.
- Extraction and filtration systems serving the construction area. Where there is chance of re-entrainment of diluted exhausted air, a minimum of an EN779-F9 filter should be installed as the final filtration stage. Where air is actively recirculated it should be filtered with at least an EN1822-H13 final filter.
- Establishing a protective pressure cascade or airflow from clean to contaminated zones
With acknowledgement to Nicholas Thorne (Life Healthcare), the following construction risk matrixes provide guidance on undertaking construction, maintenance, retrofitting and decommissioning work, whilst maintaining functionality and safety in a working healthcare facility.
PROCEDURE:
- Locate risk profile by space-type using Table 1 below
- Identify intended activity classification using Table 2
- Determine class of precautionary measures using Table 3.
- Implement minimum routine precautionary measure guidelines, given in Table 4, before, during and after construction activities commence on-site.
- Complete “common sense” checks to ensure that adopted measures are sufficient and, where appropriate, provide either reduced or lesser measures.
- Document and keep a record of descisions and actions
LOW RISK | MODERATE RISK | HIGH RISK | HIGHEST RISK |
|
|
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TYPE | ACTIVITIES |
---|---|
TYPE A | Inspection and Non-Invasive Activities Includes, but is not limited to:
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TYPE B | Small scale, short-duration activities which create minimal dust Includes, but is not limited to:
|
TYPE C | Work that generates a moderate to high level of dust or requires demolition or removal of any fixed building components or assemblies
Includes, but is not limited to:
|
TYPE D | Major demolition and construction projects
Includes, but is not limited to:
|
TYPE | LOW RISK | MODERATE RISK | HIGH RISK | HIGHEST RISK |
---|---|---|---|---|
TYPE A
(Non-Invasive/Inspection) |
I | II | II | III/IV |
TYPE B
(Minimal Dust) |
I | II | III | IV |
TYPE C
(Moderate Dust) |
I | II | III/IV | IV |
TYPE D
(Major Demolition) |
II | III/IV | III/IV | IV |
Precautionary Measures Before and During Activity | Precautionary Measures Upon Completion of Activity | |
---|---|---|
Class I |
|
|
Class II |
|
|
Class III |
|
|
Class IV |
|
|
Identification and responsible disposal of hazardous and toxic materials
Identification of Hazardous Materials
Definition of Hazardous Waste
- According to the Hazardous Substances Act 15 of 1973 and National Environmental Management Waste Act 59 of 2008 and its amendments, hazardous waste is defined as:“any waste that contains organic or inorganic elements or compounds that may, owing to the inherent physical, chemical or toxicological characteristics of that waste, have a detrimental impact on health and the environment.”
- The Department of Water Affairs & Forestry, 2005. Waste Management Series. Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste gives the following rule of thumb for waste classification: “If a waste emanates from a certain industry, for example the medical, metal, agricultural or textile industry, it is probably hazardous”
- Hazardous waste (HW) can be generated during healthcare decommissioning where:
- Potentially hazardous materials are accidentally damaged, or spilled during decommissioning
- Residues accumulate from processes or pollution abatement activities such as, sludge, or filtration of contaminated dusts.
- Non-reusable or unserviceable parts contain hazardous materials such as in batteries or medical equipment, chemicals, etc.)
- Any materials, substances or products which have been banned by legislation or policy cannot be re-used.
- Any material is burned incinerated, accumulated, stored or treated, prior to disposal.
- Bio-hazardous materials are encountered in the decommissioning process.
Identification of Hazardous Decommissioning Waste
- The Hazardous Substances Act 15 of 1973, the National waste management regulation R634 of 2013, SANS 10234: 2008 Globally Harmonized System of classification and labelling of chemicals (GHS) and the National Waste Information Regulations R625 of 2012 describe the identification, labelling and division of substances or products into groups in relation to the degree of danger, the prohibition and control of the disposal of substances which may cause injury, ill-health or death by reason of their toxic, corrosive, irritant, strongly sensitising or flammable nature.
- Health facilities are required to establish complete descriptions of their generated hazardous waste, indicating quantities and composition. This information is to be included in the Hazardous Waste register.
- This identification and classification is to be carried out according to the National Hazardous Waste Classification System.
- Proper identification of hazardous waste is important for effective hazardous waste management. Health facilities planners should be aware that hazardous waste can be generated from different sources which can sometimes be overlooked or forgotten by the establishment. This may cause that part of the generated HW would not be registered.
- For further information on healthcare waste and its identification and handling, the reader is referred to the Waste Disposal guidance article.
Material Safety Data Sheets (MSDS’s)
- An MSDS must be available for all chemicals in the above categories in all areas where the substances are used, where the waste is generated and where it is segregated.
- The MSDS must, as a minimum, comply with the format as required by the Occupational Health and Safety Act 85 of 1993 and in an ISO 9000/14000 format.
- The MSDS must include a section on the classification of the waste according to the Minimum Requirements for the Classification, Handling and Disposal of Hazardous Waste.
- The MSDS must include a section on the expected environmental fate, if dispersed into the environment, and
- The preferred disposal options should also be given on the MSDS.
Hazardous Decommissioning Waste Segregation
- Hazardous waste must be separated at source from non-hazardous waste. Additionally, mixing of different types of hazardous waste must be avoided in order to prevent any undesired or unpredicted harmful reactions between them. The reader is referred to the following for guidance:
- Department of Water Affairs & Forestry, 2005. Waste Management Series. Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste[1].
- Proper identification of hazardous waste forms a basis for waste segregation. It is therefore essential that all personnel concerned are competent in relevant waste identification.
- The segregation process should start at the waste generation points. Effective segregation will facilitate downstream waste management activities and requirements.
- The reader is referred to the SANS 10248-1 Management of healthcare waste Part 1: Management of healthcare risk waste from a healthcare facility for normative guidance in the requirements for the collection, processing, storage and disposal of healthcare decommissioning waste.[2][3]
On-site Storage of Hazardous Decommissioning Waste
Storage areas
- Hazardous waste generated from different activities should be properly stored on site prior to treatment and/or disposal.
- Containers used for storage must be fit for safe storage of the waste considered.
- Measures must be taken to mitigate accidental spillage
- Steps should be taken to prevent the breeding of vectors and vermin
- Harm to the environment and health should be prevented
- National Environmental Waste Management: Waste Act 59 of 2008 requires that a waste management license be obtained where temporary onsite storage of hazardous waste exceeds 3 tonnes daily.
- The waste storage areas should be away from public places in order to prevent any harm to the public or those persons exposed to the waste, and should be of adequate size for the waste quantities to be stored.
- These areas should be clearly designated and equipped with the necessary safety and protection equipment such as fire extinguishers, protective clothing, absorbing materials and first aid equipment.
Disposal of Hazardous Waste
Health facilities carrying out on-site Hazardous Waste disposal should obtain a disposal license from the authorities including local municipalities in accordance with National Environmental Management Waste Act 59 of 2008.
Treatment and Disposal of Health Care Waste
After separating health care waste into its four different types, i.e. infectious waste, chemical including pharmaceutical waste, radioactive waste and general waste, different management procedures should be applied to the treatment and final disposal of each type. Treatment is in terms of IWM applied to unavoidable waste and that cannot be avoided, recycled or re-used. The objective of the treatment of waste is to eliminate or, at least, reduce the hazard to levels that minimise the risk to human health and the environment. Subsequent options for the treated waste still include the possibility of re-cycling and re-use, although, at this stage, any resulting residues are usually disposed to landfill. The options for treatment are extremely varied and include physical and chemical treatment, thermal treatment, biological treatment and stabilisation, cementation and microencapsulation.
Treatment of infectious waste
According to the Minimum Requirements for the Classification, Handling and Disposal of Hazardous Waste, sterilisation of infectious waste is a minimum requirement before disposal of any residue in a permitted landfill
- Incineration is an approved technology provided it meets the requirements,
- Alternative modern technologies, such as autoclaving, microwaving and chemical disinfection are subject to the approval of the Department of Water Affairs and Forestry and the Provincial Department of Environment. It is proposed that: “Any appropriate technology can be used, provided the operator/owner can demonstrate that it can meet all health, safety and environmental requirements including passing a full environmental impact assessment and public scoping study.”
- The areas where infectious waste is accepted, stored and treated must be maintained in an acceptable manner.
- The person responsible for the treatment facility must ensure that the approved method of treatment is used at all times.
- A team adequately trained in the handling of infectious wastes, as well as the effective use of the spill kits and clean-up procedures must man the treatment facility.
- All key staff members are given training in the handling and treatment of health care waste.
- Only waste accompanied by a waste manifest or consignment note may be accepted for treatment.
- All health care waste accepted at the facility must be measured for radioactivity and only wastes below the approved level may be treated.
- Records must be kept of:
- The amount of waste treated.
- The costs involved.
- Any incidents involving health care waste.
- Incidents must be reported to the appropriate authorities.
- Appropriate PPE should be worn at all times whilst loading, offloading and treating health care waste.
Disposal of infectious waste
- Wherever possible infectious wastes must be incinerated and the ash disposed of on a hazardous waste landfill.
- Where incineration is not possible, infectious wastes must be appropriately disinfected and disposed of on a hazardous waste landfill.
- Where no treatment is available, untreated infectious wastes must be disposed of on a hazardous waste landfill.
- Where there is incineration but no hazardous waste landfill, infectious wastes incinerator ash may be disposed of on a general waste landfill, depending on it’s hazard rating.
- Similarly, if there is no hazardous waste landfill, disinfected health care waste must be disposed of on a general waste landfill with proper procedures.
- Where there is no treatment and no hazardous waste landfill untreated infectious wastes may be disposed on a general waste landfill, with proper procedures.
- No infectious wastes waste may be disposed of on a general waste landfill without proper procedures.
Treatment and disposal of chemical waste
The objectives of treating chemical including pharmaceutical waste are:
- To minimise the volume of waste that must be disposed.
- To minimise or even eliminate the hazard characteristics, i.e. the flammability, corrosivity, reactivity and toxicity of the waste.
- Treatment technologies that are utilised include physical and chemical treatment, thermal treatment, biological treatment and stabilisation, cementation and microencapsulation.
- Mercury from broken thermometers, thermostats, specialised apparatus and laboratories and cadmium that can occur in batteries must be collected separately, and managed, treated and disposed as a chemical hazardous waste.
- Pressurised gases, flammable wastes with a flash point <61oC, acids with a pH<6 and alkalis with a pH>12 may not be disposed to landfill.
- All waste treatment and disposal facilities must be licensed in terms of the Department of Water Affairs and Forestry Minimum Requirements. They must conform to all requirements, including monitoring for gaseous emissions, monitoring of ground and surface water, etc. Treatment facilities for chemical hazardous wastes must conform to all relevant regulations concerning the management of hazardous materials, such as the Hazardous Installation Regulations
- The areas where chemical waste is accepted, stored and treated must be maintained in an acceptable manner .
- The person responsible for the treatment facility and/or disposal must ensure that only approved methods of treatment and/or disposal are used at all times.
- The treatment and/or disposal facility must be manned by a team adequately trained in the handling of chemical wastes, as well as the effective use of the spill kits and cleanup procedures.
- An adequate health and safety policy that conforms to the requirements of the Occupational Health and Safety Act must be in place and operational. Appropriate PPE must be worn at all times.
- Material Safety Data Sheets (MSDS’s) must be available for all chemicals being used for the treatment of chemical wastes.
- Only waste accompanied by a waste manifest or consignment note will be accepted for treatment and disposal.
Treatment and disposal of radioactive waste
Only a few health care facilities will require to treat and dispose of radioactive waste. However, the staff at those facilities that do utilise radioactive materials have an important responsibility to themselves and public. The following should be noted:
- The safe management and disposal of radioactive waste within health care facilities is a responsibility of the Directorate of Health Technology,
- If a sealed source is to be disposed of, written permission must be obtained from the Department and they are usually disposed of at the Atomic Energy Corporation's waste site at Pelindaba or as is the case with some imported sources, are re-exported to the country of origin.
- Sealed sources may not be treated at incinerators or disposed to landfill sites.
- Unsealed, low level waste can be discharged to sewer with permission or incinerated with infectious waste provided that the level of activity falls within the guidelines.
- Low-level radioactive waste may be disposed to an infectious waste incinerator, but the following must apply:
- An incinerator operator must have an authorisation to accept such waste and the Department undertakes regular monitoring of the radioactivity levels of incinerator ash.
- For radioactive waste under their control, the holder of an authority (the health care facility) must at all times ensure that:
- Disposal or radioactive waste to incinerators is restricted to suitable waste, which includes flammable solid waste (excluding sealed sources), animal carcasses, vials containing organic solvents and bulk solvents provided these are acceptable to the incinerator operator;
- Glass vials with closed metal caps must not be disposed to an incinerator because of the risk of an explosion and the possibility of radioactive glass residue in the slag; the contents of these should be transferred to plastic containers for incineration.
- The activity per waste package and the total activity disposed of per month must not exceed the specified limits;
- Short-lived materials not meeting the activity and/or surface dose-rate limits for packages are stored until they have decayed to below the specified limits;
- Accurate records must be kept of the nuclides and total activity disposed of per month to the incinerator;
- When disposing of radioactive waste at an incinerator, the holder of the authority or his agent shall liaise with incinerator operators to develop mutually convenient procedures for the receipt and disposal of the waste, which will minimise health hazards
- When a package is sent to an incinerator, it must carry the following markings:
- the warning sign for ionising radiation, information as to the sender,
- information regarding the mechanism of disposal (i.e. "for incineration"),
- information as to the radionuclide content and activity,
- a statement that the surface dose rate does not exceed 5 microsievert per hour (0.5 mR per hour),
- For discharge to sewer of the low-level radioactive waste under his control, the holder of an authority must at all times ensure that:
- Radioactive waste for disposal to the sewer is restricted to aqueous solutions of radioactive materials and macerated biological material where this is acceptable to the waste water authorities;
- At each release point there shall be a visible sign stating that radioactive waste may be released into the sewage system;
- Water to dilute the discharge is flushed before and for at least one minute after the discharge;
- Plumbing personnel are warned of the possible hazard prior to performing maintenance,
- Liquid scintillation counting vials containing chemically toxic organic compounds (e.g. toluene, xylene, etc.) must not be disposed of via the sewer.
Minimisation of waste
- While central and provincial government departments and agencies have the responsibility of setting policy and specific targets for waste reduction and recycling, municipalities are responsible for general waste management planning, and the development of by-laws which include economic incentives to support waste minimization and recycling in their areas.
- At the time of writing, no legislation exists making recycling a legal requirement. Recycling is at this stage entirely voluntary and not associated with any incentives or rewards from the Government.
- Healthcare facilities have a “duty of care” as described in Section 10 of the DWAF waste management series and are thereby bound to the minimisation, control and management of waste generated until it is responsibly and legally disposed of.
The 4 R’S:
The minimisation of waste can be achieved by considering the following alternatives to the disposal of waste.
- Reduce waste at source is the first principle after which the following principles are considered.
- Reuse materials and equipment which may still functional usefulness to another user or in another setting
- Recycle materials that can be rejuvenated by some industrial process
- Repair equipment or components which can be restored to either its original service or reused as described above
What to Recycle
Before deciding to recycle construction waste, identify who will accept what types of waste. This is important for defining levels of separation of recyclable waste and for making arrangements for drop-off or delivery of materials. Demolition materials that can be recycled or reused include:
- Appliances and fixtures
- Brush and Trees
- Cardboard and Paper
- Glass
- Timber and Plywood (in reusable form)
- Masonry (reusable structural forms or as fill)
- Metals
- Plastics – numbered containers, bags and sheeting
- Roofing (in reusable form)
- Windows and Doors (in reusable form)
Materials Separation
Containers for material recycling must be set up on site and clearly labelled. Decommissioning personnel must be trained in material sorting, and bins must be monitored periodically to prevent waste mixing as a result of crews or passers-by throwing trash into the bins.
Some materials will require bins or storage that protect from rain. Other bins may need to be locked to prevent tampering and vermin
SYSTEMS AND UNIT SPECIFIC DECOMMISIONING
Radiology facilities
Radiology facilities include, among others, facilities used for the purpose of diagnostic radiography (imaging X-rays) and radiation therapy (treatment X-ray). The objective for retrofitting and/or decommissioning of radiology facilities is to reduce the risk of harm caused by radiation to workers and the public to levels as low as reasonably acceptable (ALARA) in accordance with THE HAZARDOUS SUBSTANCES ACT 15 OF 1973, REGULATION R1332 of 3 August 1973 and other related regulations.
- Notify the Department of Health: Radiation Control Directorate, apply for permission and complete form RC002
- Appoint competent person(s) responsible for the decommissioning and retrofitting
- Initiate staff counselling and public information as necessary
- Determine as far as possible the historical context of the use of active radiation sources and inactive radiation sources. This includes the use of sealed iridium and cobalt radiation sources.
- Make available a register or an update of an existing register of sources including the characteristics of the sources
- Perform a thorough radiological survey of the facility buildings wherever it is suspected that spent sources may have been stored, used or leaked.
- Establish a disposal or storage route for disused sources
- Remove all sources to interim storage or off-site
- Initiate and complete decontamination and dismantling activities
- Conduct a final radiological survey
- Update records and register of sources to the current status
Decommissioning of Radiology equipment
- The following are requirements for decommissioning or disposal of radiology equipment:
- Conduct a screening survey to identify possible contamination.
- Clean up contamination.
- Call DoH if you need assistance with decontamination,
- Arrange for a decommissioning survey. A representative from DoH or certified officer will perform a survey of the facilities involved and will advise you of any contamination identified.
- Notify Department of Health Radiation Control Directorate prior to relocating, discarding x-ray units, liquid scintillation counters (LSC), or gamma counters. Liquid scintillation counters and gamma counters may contain a radioactive sealed source (Cs-137, Ba-133, or Ra-226) which must be removed by the manufacturer or prior to disposal.
- Only officials authorized by the department of health should dispose of radioactive waste. Adhere to established protocols for the segregation, storage, and identification of radioactive wastes. All radioactive waste must be disposed in approved waste containers.
- Radionuclide users are strongly encouraged NOT to generate mixed waste (radioactive & chemical combinations). Segregate radioactive wastes from hazardous chemicals whenever possible; DO NOT combine chemicals with radioactive wastes, in the same container, unless the combination is an inherent, validated element of your protocols. Isolate chemical and mixed wastes from all forms of radioactive wastes. Reduce the volumes of unavoidable mixed waste at all times.
- Contact DoH prior to servicing equipment that had been used for radioactive material work. The equipment must be surveyed and decontaminated, if applicable.
- Report all radioactive material spills and other incidents or accidents involving radioactive material or radiation-producing devices to Radiation Safety Service as soon as possible after occurrence.
- After removal of radioactive materials and equipment, remove all labels, postings and markings that identify the presence of radioactive material; e.g. tape and labels bearing the word "Radioactive", door postings, refrigerator postings, etc.
- Conduct a screening survey to identify possible contamination.
- Auxiliary Equipment
- Users often need to relocate, service or dispose of equipment that was used with radioactive materials and that may be contaminated. Users must arrange to have DoH to conduct a contamination survey prior to release or relocation of equipment users intend to relocate or release for:
- unrestricted use,
- in-house or return service by the manufacturer,
- in-house service by DoH personnel, or
- for sale through property disposal
- Users must complete and attach a copy of the equipment decommissioning form certifying that the equipment is free of contaminants.
- Users often need to relocate, service or dispose of equipment that was used with radioactive materials and that may be contaminated. Users must arrange to have DoH to conduct a contamination survey prior to release or relocation of equipment users intend to relocate or release for:
- Sealed Sources
- Some common devices and instruments contain radioactive sealed sources installed by the manufacturer. These sources are not intended to be opened but are used when using the device as part of its operation or to test the response of the instrument. Some common examples include gas chromatographs with Ni-63 electron capture detectors, liquid scintillation counters, gamma counters, static discharge devices and air ionization devices, certain self-luminous "EXIT" signs, and smoke detectors. There is a common misconception that such devices or items are exempt from all regulations. All such radioactive sources are subject to regulation. The facility is responsible for ensuring that such devices are used as intended by the manufacturer, are not lost, tampered with or stolen, and are properly disposed. Contact DoH before acquiring or disposing of such devices.
- Radiation-generating Machines
- Machines that generate ionizing radiation (e.g x-ray machines) must be registered with DoH prior to use. The DoH maintains a registry that identifies each machine including the exact location of the machine. DoH regulations require that facilities notify them of changes to registration information including when the machines are to be relocated, sold or disposed. You must notify DoH whenever you intend to relocate, sell, trade-in or dispose of such machines.
Laboratory facilities
- Laboratory facilities include, among others, facilities used for diagnostics, research, teaching and training of pathological sciences. The purpose of this decommissioning and retrofitting protocol is to provide steps to be taken when safely vacating, upgrading and disposing of laboratory facilities in accordance with The National Health Act 61 of 2003[4] and regulation R178 of 2 March 2012[5] and other related regulations.
- Notify the Department of Health of the intention to vacate, upgrade or dispose of the laboratory facilities.
- Appoint a competent person responsible for the decommissioning and retrofit
- Initiate staff counselling and public information as necessary
- Determine as far as possible the historical context of the use of human pathogens in accordance with the relative risk(s) that a particular human pathogen can cause, this should include reagents, catalyst and any other regulated substance(s).
- Make available a register or an update of an existing register of biological material, chemicals, controlled substances, gas cylinders, radioactive materials, and equipment and storage areas.
- Perform a through survey of the laboratory facility wherever it suspected that biological tissue, pathogens and microorganisms may have been stored, used or leaked.
- Establish a disposal and storage procedure:
- Biological material, all biological material and potentially infectious material must be rendered safe and disposed of in accordance with The National Environmental management Waste Act 59 of 2008 and its regulations. Human and animal tissues should be incinerated and microorganism should be decontaminated.
- Chemicals, unwanted chemicals should be labelled and return to authorized distributor(s) for redistribution to other laboratories, expired and unusable chemical should be disposed in accordance with The National Environmental management Waste Act 59 of 2008 and its regulations. Any chemical residues, drips and spills should be decontaminated.
- Controlled substances, are to be transferred to another laboratory or disposed of in accordance with the Medicines and Related Substances Control Act 101 of 1965[6] and its amendments as well as regulations.
- Safely disconnect all gas cylinders and return the cylinder to the original manufactures for proper disposal of unwanted gasses or redistribution on usable gasses. Keep record of returned gasses and the cylinders as well as the licenses, certificates and permits of the gas management company.
- Radioactive material, if there was use of radioactive materials then perform a through radiological survey of the laboratory wherever it suspected that radiation material may have been stored, used or leaked. Radiation material should be managed and disposed in accordance with The hazardous substances Act 15 of 1973[7] and its regulations
- Remove all items to temporary storage or dispose of all materials which will not be used again.
- Initiate and complete decontamination and dismantling activities
- Update records and register of the laboratory facility status.
Intensive Care Units, Operating Rooms, Nursing department and Isolation Facilities
Room Decommissioning
- It is the responsibility of individual unit/department to ensure that room(s) are rendered to a reasonably safe condition prior to decommissioning a room, turning it over for a major renovation or a change of use. The following information is intended to assist responsible officials to render rooms reasonably safe for workers and new occupants. In some cases the definition of a room may be stretched to include areas such as chemical storage rooms or shared use spaces where hazardous materials are used or stored.
- Only teams with proven competence should be assigned to complete the following:
- General Information
- All hazardous materials (Chemical, Biological and Radiological) must be relocated or disposed.
- All equipment and supplies must be relocated or disposed.
- Decontaminate for Chemical, Biological or radiological contamination as appropriate.
- Chemicals
- All chemicals and chemical waste must be safely relocated or disposed.
- All compressed gas cylinders must be relocated and secured, returned to the vendor or disposed.
- Biological Materials
- All biological waste must be decontaminated (autoclaved, chemically sterilized) as appropriate and disposed.
- Ensure all other containers to be moved/stored are intact, labelled and have secure lids. Transport in secondary containment. Disinfect surfaces of transport containers before removing from the room.
- Remove biological materials from all incubators, fridges, freezers and cold rooms
- Lab Furnishings, Cupboards, Shelving, Benches
- All contents including hazardous materials (Chemical, Biological and Radiological) must be relocated or disposed.
- Decontaminate for Chemical, Biological or Radiological contamination as appropriate. Consult Material Safety Data Sheets (MSDS) for additional information. The minimum requirement is to wipe down with soap and water any surfaces that workers may contact.
- Sharps
- Place all needles, razor and scalpel blades in puncture-resistant containers with a secure lid and labelled with the appropriate hazard.
- Decontaminate and dispose of all biologically contaminated sharps.
- Search drawers, counters, crevasses for stray scalpel blades, needles, razor blades.
- Any broken glass or glass for disposal should be packaged in a plastic-bag lined card board box and labelled as ‘Broken Glass’ or a commercial ‘Broken Glass’ box and placed for the custodians to remove.
- Radioactive Materials, Equipment and Areas
- For items or areas where radioactive chemicals have been used or stored, that are marked with the radiation warning symbol, wipe tests must be done and documented according to Radiation requirements Safety Manual Only persons listed as Designated Workers on a current Radioisotope Permit should be handling (cleaning or performing wipe tests) potentially radioactive items or areas.
- Any equipmnt containing radioactive sources must be removed or relocated.
- All radiation warning labels must be removed.
- Door signs and Radioisotope Permits may only be removed by Radiation Safety staff.
- Fume Hoods
- All hazardous materials (Chemical, Biological and Radiological) must be relocated or disposed.
- Notify responsible authorities if the fume hood was used for perchloric acid digestions or any other activities that involved heating perchloric acid. No work is to proceed in the fume hood until a further assessment of the hood is performed jointly with responsible authority.
- Decontaminate for Chemical, Biological or radiological contamination as appropriate. Consult MSDS
- Remove all signs/labels or signage except fume hood stickers.
- Sinks and Associated Appliances
- All hazardous materials (Chemical, Biological and Radiological) must be relocated or disposed including anything in the cabinet below the sink.
- Decontaminate for Chemical, Biological or radiological contamination as appropriate. Consult MSDS
- Equipment
- Any equipment must be removed or relocated.
- General Information
Filtration Media
General ventilation filters
General course, medium and fine particle air filters can be disposed of as general waste through the waste management service provider. Where these filters are installed in an exhaust air stream in conjunction with HEPA or ULPA filtration they should be decontaminated and bagged by a certified biosafety technician.
HEPA and ULPA Filters
Where these filters are installed in an exhaust air stream in conjunction with HEPA or ULPA filtration they should be decontaminated and bagged by a certified biosafety technician.
Vacuum system filters
Vacuum system filters and traps should be treated as potentially bio-hazardous and should only be handled by staff suitably trained in biosafety. These components should be decontaminated before disposal or incineration.
Wet services
Wet services in hospitals can provide ample opportunities for the breading of and inoculation with harmful water-borne pathogens. The following processes is prescribed for the decommissioning management of wet services.
- Form a team, appoint a leader and establish procedures.
- In a hospital, the team should be headed by the facilities director and include members from infection control, risk management, administration and the medical staff.
- The team should meet periodically to ensure that the wet services decommissioning plan is being implemented, to review its effectiveness, and to consider revisions.
- Identify high-risk building areas based on water exposure and occupant susceptibility.
- Establish decommissioning staff vigilance for symptoms of legionellosis. Provide access to diagnostic tests and encourage clinician suspicion for it.
- Conduct an environmental risk assessment. Have the cooling towers, domestic water system, manufacturing equipment and other aerosolizing devices evaluated with respect to preventive measures.
Information technology infrastructure
- Information technology infrastructure for this purpose will be defined as the physical hardware used to interconnect computers, computer operated systems and equipment. Infrastructure includes the transmission media, transmission of x-ray images via PACS systems, including telephone lines, cable television lines, and satellites and antennas, and also the routers (Network and hardware infrastructure). IT infrastructure are decommissioned when they reach their end of life and become redundant (disposal) or upgraded to meet new system requirements (upgrade, this may include moving from wired to wireless systems).
- Proper planning when decommissioning IT infrastructure is of paramount importance to prevent information security threats and interference between IT systems and medical equipment.
General building and administration facilities
Initial Site Inspection:
- The key to this process is careful planning and matching the decommissioning expectation and the requirements of regulations, different regulations will apply depending upon the final disposal – sale /change of use, mothball, or demolition. Structural engineers and real estate consultations may be necessary to determine structural integrity and marketability of the building and property.
- The person(s) responsible for the Initial Site Inspection team should include: Technical facilities manager, Assets manager, Health and safety manager, Medical personnel, Plumber, Electrician and Waste manager, Clinical technician.
- The initial site inspection should be conducted to establish the history and records of the following: Building floor plans, underground mechanical and electrical drawings, Soil boring logs, historical environmental reports, asbestos survey reports, Solid waste, Potential polychlorinated biphenyls areas (PCB), Ventilation machinery and duct work, , Chlorofluorocarbons (CFC) containing equipment, Types of paint, location and dimension of any sumps, types of equipment present and any waste holding capacity, underground and above ground storage tanks, types and location of lightning, types and location of transformers and capacitors, Process sewers and lines, Cooling towers, air-conditioning or refrigeration equipment, Medical waste, Mercury switches and previous locations of mercury-containing devices, radioactive material, Water processing systems, Wells, Recycling operations, Previously filled in pits and sumps, Logistical concerns, including equipment size(s) and weight, location and use of any confined spaces.
- Determination of Assessment Criteria, involves sampling plan for the potential areas of concern. This should include the following:
- Sampling methodology, location and safety factors
- Site specific health and safety plan, personnel protective equipment to be used and potential hazard report should be part of the sampling plan.
- Compare the known to the unknown data and SANS regulation standards,
- Determination of changes from documented building plans and the built reality: That which may seem to be a minor change may be significant for the decommissioning process.
- The sampling plan will assist in knowing if the building still meet regulatory standards and as such can recommend reuse or disposed.
- Development of List of Areas to be decommissioned based on the initial report and sampling report list of the areas to be decommissioned can be created; this can be the entire building or part of the building. Development of list of areas to be decommissioned will include decommission strategy, whether the building will be reused for other purposes with few alteration, building will be disposed/demolished or major upgrade to fit purpose of use.
- Development of a decommissioning technical specification, this will define the scope of work, technical procedures and standards to be followed when doing the actual physical work. This will include:
- Demolishing procedures
- Material to be re used
- Materials to be recycled.
- Materials to be disposed and procedures of disposal
- Safety standards
- Site management
- Waste management
- Actual decommissioning project
- Decommissioning implementation and final report, actual performance of the decommissioning work, active oversight is essential in this stage and technical specification should interpreted consistently in this stage. Documentation of the work in progress is as important as the decommissioning work, all activities should be documented with its related item such as location, personnel assigned, equipment used, PPE used waste generated, problems encountered and photographs portraying the work before, during and after.
- The final report of the entire decommissioning should provide records of all activities, final disposals of waste and recycled products. The document should be treated as legal document and made available to regulator or technical person, the content of the report should include among others:
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Decommissioning and Disposal of Health Technology Equipment
- Decommissioning of Health technology in this document refers to decommissioning for the purpose of upgrade and removal from service (disposal/resell/donation) of medical equipment and/or devices, their accessories and any component(s) and or system which may provide link between equipment and/or devices which is used in healthcare for the purpose of preventing, diagnosing, or treating diseases as well as for monitoring and rehabilitation
- Identify the need and responsibility this phase of decommissioning should include the clinical specialist and clinical engineering specialist. The following should form part of this phase
- Assessment of the change in clinical need/demand, change in technology and aging in technology (this should include the cost of maintaining the old equipment and the procedure/purpose turnaround time versus the cost of new technology and its turnaround time)
- Identify the needs and responsibility, technical and clinical specification for the need to either upgrade or completely replace the equipment. Clinical engineering should be responsible for the technical specification and equipment lifecycle management as well as decommissioning of part or the entire equipment which is removed from services. Clinical department should be responsible for the clinical specification and compliance requirement as per the clinical procedure to be carried-out with the newly acquired technology.
- Replacement decommissioning, the decommissioning committee must include the institution manager, clinical engineering manager, health and safety officer, nursing manager and clinical manager. When removing equipment from service the following should be conducted: Final test and calibration (certificate should be issued for filing), equipment service records and acceptance certificates, removal (migration) and erasing of patient information, equipment decontamination, equipment has to be marked as being out of service and removed from asset registered as being sold/donated/trade-in or scraped with its current value.
- Identify the need and responsibility this phase of decommissioning should include the clinical specialist and clinical engineering specialist. The following should form part of this phase
EXAMPLE WORKSHEETS, CHECKLISTS AND PROTOCOLS
Checklist: Infrastructure Decommissioning and Disposal
Health Infrastructures need to take account of the following steps when considering the de-commissioning of any service and infrastructure.
- Preparing a service for decommissioning
- Informing the stakeholders/market and understanding the response
- Financial impact
- Other Factors: quality, performance, value for money, future demand
Preparing a service for decommissioning
The de-commissioning activity should be in line with the broader commissioning context so that plans do not come as a surprise to the various stakeholders. It is important that appropriate project support and risk management plans are in place to support the management of decommissioning activity – link to programme office and risk management
Engaging the stakeholders/market and understanding the response
The decommissioning team needs to establish an understanding of how the stakeholders/market will respond to the decommissioning plan. These stakeholders include both the healthcare service users and providers. This understanding should be gained prior to putting plans into action since this will affect how the project could proceed. The very process of engagement can smooth or even aid the way for decommissioning implementation.
The following stakeholder engagements checklist is provided as an example:
No | Question | Commentary/Why is this important |
---|---|---|
1 | Have you notified affected providers and offered to meet to explain the rationale and process? | Engaging with affected providers throughout the process is not only good practice may mitigate a legal challenge to the process and decisions at a later stage. |
2 | Have you analysed the outcome of any such meetings? | Following your meeting (or other form of communication) with the provider you should be able to answer and document the following
what is their response? do they want to keep strictly to the terms of the contract? is there any indication of their willingness to agree to a variation in the contractual terms? |
3 | Have the providers in question attended any workshops that you have run on outcomes bases service/ infrastructure? | If not then they may not be able to understand the change in policy, direction and the context for service delivery. Analyse this and if necessary provide and communicate relevant information. |
4 | Having gone through these stages, what is your assessment of the provider’s attitude and the chances of reaching a negotiated solution? | It will be important to take stock at regular intervals through the process and to analyse and adjust plans according to the responses and attitudes of provider(s). The objective should always be to reach a negotiated position. |
5 | Is the provider inflexible? | If no negotiated solution can be found and the provider intends to stick strictly to the terms of the contract, and the contract does not provide any of the flexibility required to achieve services of the required nature, then a risk assessment and impact analysis should be undertaken. |
6 | Do you need to undertake a risk assessment and impact analysis? | This should include:
a cost/benefit analysis Impact of decommissioning the service - effect on service users, provider organisation and on your ability to deliver services. |
7 | What is the advice of your legal department? | The facility owner's legal department should be involved in the process. |
Financial Impact
There are likely to be costs associated with decommissioning and these need to be calculated.
No | Question | Commentary/Why is this important? |
---|---|---|
1 | What will be the cost of decommissioning a service/ infrastructure? | This needs to be considered in terms of the potential cost (e.g. breaching or buying out a contract) if the consequences of continuing with the existing contract is limiting or risky in terms of performance or service quality. |
2 | What will the cost be of not decommissioning the service? | Against this needs to be set the adverse effect on performance judgement if the facility is not making progress with policy initiatives, or is not taking incisive action over services that can be considered of an adequate quality but may be of a poor or outdated service model. |
3. | If a provider is completely inflexible have you considered working and discussing this with other facilities that do business with them? | This may help a provider to reconsider their stance and enter into discussion and negotiation to find common ground and agreed solutions. |
Other Factors: quality, performance, value for money, future demand
No | Question | Commentary/Why is this important? |
---|---|---|
1 | What is the quality of the service/ infrastructure? | Is service quality good or acceptable? Is there a risk that if the contract is changed then it might deteriorate? It is important to pay particular attention to process quality (i.e. the service user experience of receiving the service) |
2 | How effective is the service/ infrastructure, particularly in terms of outcomes? Or has the service/ infrastructure service got the potential and adaptability to be effective in terms of outcomes? | Although the service may not at this point be delivering the outcomes required you need to apply your analytical skills to evaluate whether the service, if changed, has the potential to be effective. |
3 | Is performance, against agreed measurables, meeting the requirements of, and standards set out in, the service specification? | If this is the case it will bode well for future delivery and effectiveness of services, taken together with other factors that will be looked at as part of any decommissioning / re-commissioning / re-tendering process. |
4 | Is the demand for the service/ infrastructure commensurate with the service/ infrastructure that the facility is committed to paying for (particularly if this is locked into a block contract)? | If there is no longer the demand for the service, or if the block purchasing of services need to be reduced within the contract period due to the development and implementation of the personalisation agenda, then consider whether there is scope for negotiating with the provider on this point. |
5 | Do you need to terminate a current contract?
Have you sought advice from legal and contract service/ infrastructure? |
Has the provider unilaterally changed any elements of the service, withdrawn service or failed to provide services that it is contractually bound to do to any significant or substantial degree?
If any of these apply then they can be used as leverage to either ensure compliance or to get the provider to become more flexible and responsive to change contractual requirements. |
6 | Where you terminate a contract:
Are you able to develop decommissioning / transfer / transition plans in conjunction with the provider? |
This is vital to effect a smooth transfer and to minimise the impact on service users and staff. |
7 | Have you got a communication plan? | It is important to communicate well in advance with service users and the press / media, as well as other stakeholders. |
8 | Have you briefed elected members and other key stakeholders?
Who else should you inform or consult with? - Link to stakeholder engagement section |
It is important to brief anybody within the governance structure, other stakeholders who might be affected, or where there might be an impact on other services |
9 | Have you developed a decommissioning / transition / transfer plan? | This should be managed by a programme/project management approach:-Link to decommissioning / transition / transfer plan |
10 | Have you considered future contracts to ensure that they do not constrain you unduly? | Your contracts may need to be revised to be more flexible and include scope for periodically revising the service specification. Legal advice should be sought and examples sought from other facility. |
Laboratory equipment/Facilities Example checklists
Serial Number: - |
Model: - |
Manufacturer: - |
---|---|---|
Description: - |
Installation Date: - |
Decommissioning date: - |
Acceptance Check |
Comment | Pass (yes/no) |
Is equipment documentation available (acceptance certificate, calibration certificates, service records and final tests) | ||
Hazardous material exposure possible? (Biological, chemical, radioactive and others) | ||
Decontamination procedure | ||
Does the equipment planned maintenance schedule exist | ||
Has the equipment been tested for electrical safety | ||
Does the equipment pass all of the above conditions | ||
Will the equipment be disposed or re-used for other/laboratory purposes | ||
Make sure that all hazards material are disposed as per the disposal procedure for all equipment due
for disposal and all equipment to be reused should comply with regulations and license requirements. |
Building Number |
Room Number
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License Number | |||||||
Acceptance Check | Comment | Pass (yes/no) | |||||
Inform the department of health of the intended decommissioning of the LAB | |||||||
Decontaminate the room(s) and all exposed facilities of all the hazards? | |||||||
Will the room(s) be disposed or re-used for other purposes? | |||||||
Make sure that all hazards material are disposed as per the disposal procedure and all rooms to be reused should comply with regulations and license requirements. |
Decommissioning Decision Record
Serial Number: | Model: | ||
Manufactures | Description | ||
Installation Date | Decommissioning date | ||
Acceptance Check | Comment | Pass (yes/no) | |
Is equipment documentation presented? (acceptance certificate, service record, final test ) | |||
Has this item been identified for decommissioning by a clinical technician? |
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Reason for decommissioning: | |||
Is the equipment functional: | |||
Is the equipment CE market | |||
Is the equipment class and type indicated | |||
Does equipment have the instruction manual | |||
Does the equipment planned maintenance schedule exist | |||
Has the equipment been tested for electrical safety | |||
Does the equipment contain any hazards substance such a radiation isotopes,
mercury and/or other harmful materials |
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Does the equipment pass all of the above conditions? | |||
Will the equipment be disposed or re-used for medical purposes | |||
Make sure that all hazards material are disposed of as per the disposal procedure for all equipment
due for disposal and all equipment to be reused should comply with regulations and licence requirements. |
References
- ↑ http://sawic.environment.gov.za/documents/265.pdf
- ↑ SABS, 2008, https://store.sabs.co.za/pdfpreview.php?hash=75951170a020c6a3aba42e6a518d8f79f0ac7a84&preview=yes
- ↑ SAIOH, 2020, https://cdn.ymaws.com/www.saioh.co.za/resource/resmgr/docs/2020_docs/sans_-_management_of_healthc.pdf
- ↑ https://www.gov.za/documents/national-health-act#:~:text=The%20National%20Health%20Act%2061,regard%20to%20health%20services%3B%20and
- ↑ https://www.gov.za/sites/default/files/gcis_document/201409/35099rg9699gon178.pdf
- ↑ https://www.gov.za/documents/drugs-control-act-7-jul-1965-0000
- ↑ https://www.gov.za/documents/hazardous-substances-act-16-apr-2015-1120