When a lab closes — because a principal investigator retires, relocates to another institution, a grant ends without renewal, or a department consolidates space — every piece of equipment in that room needs a documented destination. The options are narrower than they first appear: equipment can be declared surplus and redistributed inside the institution, transferred to another lab or institution, or disposed of through sale, donation, recycling, or waste channels. Which path is available, and who has to sign off on it, depends on who actually holds title to the item and how it was purchased.
This guide walks through equipment disposition specifically — instruments, benchtop devices, freezers, microscopes, and similar durable equipment. For the separate (and separately regulated) question of what to do with the chemicals themselves, see Chemical Waste Disposal Procedures for a Closing Laboratory.
Why equipment disposition isn’t just “throw it out or give it away”
Research equipment is rarely unencumbered property. It may have been purchased with unrestricted institutional funds, with federal grant funds (which come with disposition rules attached), or provided directly by a government sponsor as government-furnished property that the institution never owned in the first place. Some equipment may still be under warranty, on a lease, or tagged for chemical, biological, or radiological decontamination before it can safely be moved at all. Skipping the classification step is the single most common way institutions end up with a compliance problem, a lost asset on the books, or a piece of contaminated equipment leaving the building undocumented.
Step 1: Inventory and classify every asset
Before deciding what happens to anything, build a complete list of the equipment in the space and classify each item by:
- Funding source and title — institutional (unrestricted) funds, a specific federal or non-federal grant/contract, a state appropriation, or a gift/endowment with its own restrictions.
- Current condition and residual value — functional and in demand, functional but obsolete, or non-functional/scrap.
- Hazard status — has it held or generated hazardous chemicals, biological materials, or radioactive/radiation-generating components? (Autoclaves, fume hoods, freezers/refrigerators that stored chemicals or biologics, centrifuges used with hazardous materials, and any radioisotope-associated instrument all need a hazard review before disposition, not after.)
- Institutional asset tag / property record status — most institutions require anything above a set dollar threshold (commonly $5,000, though this varies by institution) to carry an asset tag and appear on the capital equipment inventory. Untagged equipment still needs a disposition decision, just not necessarily the same paperwork.
Most institutions route this through the sponsored programs or research administration office together with the campus property/surplus office, since the funding-source classification determines which set of rules applies next.
Step 2: Determine which disposition rules actually apply
The rules differ sharply depending on how the equipment was acquired. Three categories cover almost everything you’ll encounter in a lab closeout:
Institutionally purchased equipment (no federal strings)
Equipment bought with unrestricted institutional funds, indirect cost recovery, or most gift/endowment funds belongs to the institution outright. Disposition follows the institution’s own property/surplus policy — typically: offer internally to other labs/departments first, then route through the campus surplus property office for sale, auction, donation, or scrap, following whatever approval and documentation the institution’s policy requires. This is the most flexible category and usually the fastest to close out.
Equipment purchased with federal grant or contract funds
Equipment bought with federal award funds is governed by the equipment disposition rules at 2 CFR 200.313, part of the OMB Uniform Guidance that applies to non-federal entities receiving federal awards. The key thresholds, current as of the April 2024 Uniform Guidance revision (effective for awards issued on or after October 1, 2024):
- Equipment with a current per-unit fair market value of $10,000 or less may be retained, sold, or otherwise disposed of by the recipient institution with no further obligation to the federal government. If sold, the recipient may generally keep up to $1,000 of the proceeds to cover selling/handling costs, with any remainder allocated back to the federal government in proportion to its share of the original purchase.
- Equipment above that $10,000 fair-market-value threshold requires disposition instructions from the federal awarding agency (or the pass-through entity, for a subaward) before the institution can act. If the agency doesn’t provide instructions within 120 days of the disposition request, the recipient may sell or retain the equipment, but the federal government still retains a right to compensation based on its percentage share of the original acquisition cost.
Note that this $10,000 threshold replaced a previous $5,000 figure — equipment purchased under an award issued before October 1, 2024 may still be governed by the older threshold language in that award’s terms, so check the specific award document rather than assuming the current figure applies retroactively. For the full property-management picture — inventory records, physical-inventory cycles, and the required SF-428 reporting — see Property Management System Requirements for Federally-Funded Equipment (2 CFR 200.313).
If the lab closure coincides with the grant’s own closeout, disposition also has to fit inside the closeout timeline — generally 120 calendar days after the period of performance ends for the recipient institution (90 days for a subrecipient reporting to its pass-through entity). Equipment records specifically must then be retained for three years after final disposition, separate from the standard three-year financial-record retention clock.
Government-furnished property (GFP/GFE)
If the equipment was provided directly by a federal sponsor rather than purchased by the institution — common on defense-related and some agency contracts — the institution never held title to it. GFP has its own custodial, tracking, and return/disposition process set by the contract, and none of the 2 CFR 200.313 thresholds above apply to it. Treat GFP as a distinct inventory category from the start of the closeout, and coordinate its return or transfer directly with the sponsoring agency’s property administrator. See Government-Furnished Property in University Research Awards: Custodial Responsibilities and Tracking for the full custodial framework.
Step 3: Choose the disposition path
Once an item’s funding/title category is clear and it’s been cleared of hazards (Step 4), the realistic options are:
- Internal transfer/surplus — reassigned to another PI or lab within the institution. Usually the fastest option and the one campus surplus offices prefer to try first, since it avoids external disposition paperwork entirely.
- Transfer with a departing PI — when a PI moves to another institution and wants to bring equipment along, this needs an equipment transfer agreement (or, for federally funded equipment above the disposition threshold, agency approval) documenting the change of custody and, where applicable, title. This is a separate process from transferring the grant itself, though the two often happen together.
- Sale — through the institution’s surplus property office, a public auction, or (for higher-value federally titled property in some circumstances) a federal disposal channel. Proceeds handling depends on the funding category above.
- Donation — to another nonprofit, school, or research institution, subject to institutional policy and, for federally funded equipment, the same disposition-instruction requirements as a sale.
- Recycling or waste disposal — for equipment with no realistic resale or transfer value, routed through the institution’s e-waste/electronics recycling program. Equipment containing refrigerants, mercury (some older thermometers, manometers, and switches), or lead-acid/lithium batteries needs to go through the appropriate regulated waste stream, not general e-waste, so check with EHS before disposal.
Step 4: Decontaminate and clear hazards before anything moves
No disposition path — including an internal transfer down the hall — should proceed until equipment that contacted chemicals, biological material, or radioactive material has been decontaminated and cleared by the institution’s environmental health and safety (EHS) office. This typically means:
- A visible decontamination/clearance tag or certificate attached to the equipment before it leaves the lab, especially for anything going to surplus, sale, or another institution.
- Radiation survey and clearance from the radiation safety office for any equipment used in radioisotope work, even if the equipment itself (e.g., a centrifuge or freezer) isn’t inherently radioactive.
- Biosafety cabinets, autoclaves, and other biological-containment equipment certified and documented per the institution’s biosafety program before transfer or sale — a receiving lab or buyer has no way to independently verify prior use.
- Chemical residue removal from glassware-adjacent equipment (ovens, hoods, refrigerators/freezers used for chemical storage) coordinated with the chemical waste disposal process described in Chemical Waste Disposal Procedures for a Closing Laboratory.
This step exists independently of who holds title to the equipment — hazard clearance is a safety requirement, not a property-rights question, and it applies the same way whether the item is headed to another PI on campus or to an external buyer.
Step 5: Document the disposition
Whatever path an item takes, the closeout record should show: the asset ID/property tag (if any), funding source and any award number it was charged to, condition at disposition, decontamination clearance (if applicable), the disposition method chosen, the date, and who approved it. For federally funded equipment, this documentation supports the institution’s own capital-equipment inventory and, where a physical inventory or disposition report is required, feeds into the reporting the sponsoring agency expects — see the SF-428 discussion in Property Management System Requirements for Federally-Funded Equipment for how that reporting mechanic works. Keep these disposition records for at least three years after the disposition date, consistent with the federal equipment-records retention period, even for equipment that turns out not to have been federally funded — it’s simpler to apply one retention standard across a closeout than to sort records by funding source after the fact.
Common mistakes in lab equipment disposition
- Treating all equipment as institutionally owned. Skipping the funding-source classification step is how federally funded equipment ends up sold or scrapped without the required agency disposition instructions.
- Moving equipment before decontamination clearance. A biosafety cabinet or chemical-exposed refrigerator that changes hands without documented clearance creates liability for both the sending and receiving party.
- Confusing government-furnished property with federally funded (purchased) equipment. They look identical sitting on a bench but follow entirely different disposition tracks — GFP was never the institution’s to dispose of in the first place.
- Losing the paper trail on informal PI-to-PI transfers. An instrument that quietly moves to a colleague’s lab without an update to the property record becomes very hard to account for at the next physical inventory or audit.
- Missing the closeout clock. If the lab closure lines up with a grant’s own closeout, equipment disposition decisions need to happen inside that same 120-day (or 90-day, for subrecipients) reporting window, not months afterward.
Frequently asked questions
Who decides where lab equipment goes when a lab closes?
Typically a combination of the departing/retiring PI, the department or center, the institution’s sponsored programs or research administration office (for anything tied to a federal award), and the campus property/surplus office. For government-furnished property, the sponsoring agency’s property administrator is also involved. No single office usually has unilateral authority over every item — the funding source determines who has to sign off.
Can a PI take equipment with them to a new institution?
Sometimes, but it requires a documented equipment transfer — an institutional transfer agreement for institutionally owned equipment, or agency approval/disposition instructions for federally funded equipment above the disposition threshold. It is not simply a matter of physically moving the item; the property record has to follow it.
Does old lab equipment need to be decontaminated before it’s sold or donated?
If it contacted hazardous chemicals, biological material, or radioactive material, yes — decontamination and a documented clearance from EHS (and radiation safety, where applicable) should happen before any transfer, sale, or donation, regardless of who ends up with the item.
What’s the dollar threshold for federal equipment disposition rules to apply?
Under 2 CFR 200.313, equipment with a current fair market value of $10,000 or less can generally be disposed of by the institution without further federal approval; above that, the institution needs disposition instructions from the federal awarding agency. That $10,000 figure applies to awards issued on or after October 1, 2024 — earlier awards may carry a lower ($5,000) threshold in their terms.
How is equipment disposition different from chemical waste disposal in a lab closeout?
Equipment disposition is about the physical instruments and durable equipment — where they go and who has to approve it. Chemical waste disposal is about the chemical inventory itself — what gets neutralized, what gets picked up by a licensed hazardous-waste hauler, and how that’s documented. They run in parallel during a closeout, and equipment often can’t be released for disposition until it’s been cleared of chemical residue, but they’re governed by different rules and usually different offices.
