Chemical Waste — Lab Packing

Lab packing is a chemical collection and transport method that utilizes smaller inner containers inside a larger outer container for packing and shipping. This process enables cost and space efficiency in transport when shipping "like" materials while ensuring that no incompatible chemicals are mixed together. If you have small containers intact and contained within their own primary container, then these items could be placed into a drum that is equal or lesser than 55 gallons and “lab packed” together with inert packing material (typically packed in vermiculite or another compatible absorbent). It should be noted however that there are specific requirements for the amount of packing material required in each specific size drum per D.O.T regulations, and combining bottles of chemicals in the same outer container can be dangerous if not done correctly.

The US DOT regulations at 49 CFR 173.12(b), (d), and (f) include special requirements for transporting lab packs. Firstly, the materials shipped in the lab packs must be of the same DOT hazard and must be compatible. Outer packaging must be UN-performance packaging, typically open-head drums of steel, plastic, other metal, or fiberboard. Each inner container cannot exceed 20 liters capacity, and the total weight of the lab pack cannot exceed 205 kilograms.

Lab packs that contain highly dangerous chemicals such as cyanide or arsenic and/or container toxic heavy metals are subject to special treatment requirements. Generators are not required to determine underlying hazardous constituents (UHCs) when using the alternative treatment standard for lab packs.

Chemistry laboratories in educational institutions (including but not limited to community colleges, high schools and universities) store many toxic, corrosive, flammable, reactive, and poisonous chemicals that are used in class demonstrations and training. With a clear shelf life, these chemicals must be disposed of at the end of each semester or school year. Lab packing is both the safest and most compliant means of packaging and transporting hundreds of different lab chemicals at once.

Chemicals should be designated for Lab Pack disposal if they meet the following criteria:

Within six months of expiration (this should be captured on the label of the chemical container). Best practice irrespective of expiration date is to not keep hazardous chemicals for longer than five years.
When the condition of the chemical’s storage has been compromised, for example if the chemical was stored in an unsuitable temperature or without being properly sealed.
If you do not need or use the chemical regularly or it poses an unsuitable hazard risk.

It is the responsibility of the "Lab Packer" to identify and properly segregate each substance based on the US Department of Transportation’s regulations. Many flammable substances cannot be packaged with other chemicals because they are in different hazard classes, for example, picric acid is one chemical that becomes explosive with age and must be handled with extreme caution and expertise. It is therefore imperative, whether for a Chemist or a Hazardous Waste partner, that the person responsible for lab packing has knowledge of the substances they are working with.

Only transportation companies permitted under the U.S. DOT hazardous materials regulations and the U.S. EPA's hazardous waste regulations can transport hazardous waste. It is the responsibility of the waste generator to confirm that their nominated transporter is fully permitted, being aware that some service providers outsource transportation to a third party. Using a third party can add an additional layer of risk when considering lab pack disposal.

Lab packing is the process in which chemicals are placed into a DOT approved container and transported to a permitted waste disposal facility. Because many of these substances are hazardous and even more dangerous when accumulated with other chemicals, it is important that only an individual who has expertise in lab packing operations performs them. A trained lab packing technician will have knowledge of how to handle and segregate chemical substances in a way that is safe and regulation compliant.

Lab packs are typically used by universities, laboratories , dry cleaners or other industries that produce chemical waste. When disposing of multiple chemicals with different hazardous properties, lab packs are a convenient and cost-effective option for shipping hazardous chemicals off-site. The large lab pack container gets filled with various smaller-quantity containers of materials or chemicals that are similar to each other, such as acids, flammables and oxidizers. The container is then marked with its assigned shipping name for easy sorting.

Common materials that would be transported in a lab pack include toxic, flammable, corrosive, pyrophoric or explosive materials, acids, aerosols and compressed gas, solvents, oxidizers, chemical reagents, cleaning and disinfecting agents, radioactive materials, organic peroxides, paints, paint thinners, varnish strippers and reactive materials from metals.

To load the lab pack (drum), small vials and containers (anywhere from one-quarter ounce to gallon jugs) are packed together into the larger container which must be packed according to waste type, so the waste segregation process is vital. For example, flammable items should be packed with other flammable items. Corrosive waste should be packed with similar corrosive waste. You should never mix flammable, corrosive, or reactive materials within one large container.

Before packing any chemical containers into the lab pack, a qualified individual must create an inventory of every expired, damaged, or out-of-date chemical to be disposed of. This inventory should accurately detail everything that’s going into the pack in order to properly – and safely – dispose of chemicals that are no longer needed.

A turnkey lab pack service (which is what MCF offers) typically involves the following:

• Identification of all materials within the lab.
• Inventory creation of those materials.
• All DOT-certified containers.
• Necessary paperwork (profiles, shipping manifest, labels, placards, and so on).
• All labor associated with the pack.
• All travel expenses associated with transport.