Facility Closure Checklist - Medical Facility

What is a Facility Closure Checklist?

A facility closure checklist is a structured document that guides authorized personnel in properly shutting down a site or facility. It helps authorized personnel systematically complete closure activities while staying compliant with environmental, safety, and regulatory requirements.

What is Facility Closure?

Facility closure is the process of shutting down a site or facility following a set of tasks that include the proper disposal or, if appropriate, the containment of hazardous wastes and materials at the site to prevent the contamination of the immediate vicinity and the environment.

Importance

Federal law requires proper facility closure of sites that handle or treat hazardous materials and wastes. Facility closure is also important for healthcare providers not only because the closure involves the disposal of waste and other hazardous materials, but also because of the need to ensure the security and accessibility of patient information to authorized persons even when a healthcare facility is no longer in operation.

Which Sites Normally Shutdown a Facility?

Facility closure is most applicable to healthcare facilities and different types of Treatment, Storage and Disposal Facilities (TSDFs) or Hazardous Waste Management Units (HWMUs) which typically treat and temporarily or permanently store hazardous wastes.

Types of Facility Closure

The type of facility closure depends on how waste is disposed by a facility. Here are the two types according to the Environmental Protect Agency (EPA):

• Clean closure – This type of facility closure includes the complete removal of hazardous waste and, when applicable, decontamination or removal of contaminated soil and equipment at the site being closed.

• Closure with the waste in place – Sometimes called “closure as a landfill,” this mostly applies to facilities such as landfills and other TSDFs or HWMUs where removal of the waste is not possible and is instead sealed into the facility being closed following regulatory procedures.

The Facility Closure Process

Facility closure involves multiple professionals such as engineers and facility managers during the different stages of the life cycle of a facility. Below is an overview of the process involved during facility closure.

Before the operation of a facility

Even before TSDFs or HWMUs are allowed to operate, they are legally required to produce a written closure and contingency plan to be approved and will be part of the facility’s permit to operate.

During operation

Healthcare facilities should secure and update patients and other contact information so that, in case of a facility closure, the contact persons are sent the notification within the required timeline before closing the facility. Facility managers of sites that hold hazardous materials should ensure that incidents such as spills are mitigated and actions are taken to correct any issues are recorded.

After closure

Unlike clean closure, closure with waste in place needs post-closure care that could last for up to 30 years. Depending on the site, post-closure can involve risk management to determine how to properly close or seal the unit or site and maintenance inspections and testing to ensure that there is no leachate or contamination of the groundwater and the vicinity surrounding the facility. According to the EPA, post-closure care can be shortened or extended beyond the 30 years depending on how the hazardous materials are contained.

What to Include in a Facility Closure Checklist

The items included in a facility closure checklist differs depending on the site to be shutdown. For instance however, here are the key elements to include in a facility shutdown checklist for a medical facility:

• Facility name

• Date

• Prepared by

• Location

• Nofifications – notifying the following people 60 to 90 days before closing

  • Staff

  • Temporary staff hired and onboarded.

  • Patients

  • Public

  • Professional Associations

  • Drug Enforcement Agency (DEA)

  • Health Insurance Companies

  • Hospitals

• Tasks – performing these tasks 30 to 60 days before closing

  • Patient scheduling

  • Referral for accounts receivable

  • Referral for insurance policies

  • Referral for medical records

  • Clinic documents & equipment

  • Medications