How to Ship Lab Packs

A lab pack is a container, often a pail or a drum, that is filled with smaller containers of expired, off-spec, or unwanted chemicals for the purpose of transportation to a disposal or recovery site. Lab packs are a useful way for chemical research labs, universities, medical facilities, warehouses, and others to ship a variety of waste chemicals at once, in a single package.

What Chemicals Can Be Lab Packed?

Lab packs can be used to ship many hazardous wastes covered by RCRA, as well as non-RCRA wastes regulated as "hazardous materials" in transportation. 

Wastes shipped in lab packs must: 

• Be destined for disposal or recovery, 
• Meet the definition of a Class 3, 4, 5, 8, 9, or Division 6.1 (PG II or III) hazmat, and
• Be transported by highway, rail, or cargo vessel. 

The chemicals in a lab pack must all be compatible and of the same hazard class—e.g., flammable (Class 3), corrosive (Class 8), etc.  

What Chemicals Can Not Be Lab Packed?

The following types of wastes may not be shipped in a lab pack: 

• Poisonous-by-inhalation materials. 
• Most temperature-controlled materials. 
• Chloric acid. 
• Oleum (fuming sulfuric acid). 
• RCRA code D009.
• RCRA code F019.
• RCRA codes K003—K006, K062, K071, K100, or K106.
• RCRA codes P010–P012, P076, or P078. 
• RCRA codes U134 or U151. 

Packaging and Lab Pack Capacity Limits

Lab packed materials must be transported in a combination packaging. A combination packaging consists of one or more inner packagings secured in a non-bulk outer packaging [49 CFR 171.8]. 

Inner Packagings

Inner Packagings for lab packs may be glass, metal, or plastic. 

Maximum rated capacity limits for lab pack inner packagings are as follows: 

• Glass: 4 L (1 gal) 
• Metal: 20 L (5.3 gal)
• Plastic: 20 L (5.3 gal)

Inner packagings containing liquids must be: 

• Tightly and securely sealed, 
• Non-leaking, and 
• Surrounded by enough compatible absorbent material to recover all the liquid contents. 

To ship a lab pack, all inner packagings must be placed in an outer packaging that fits specific criteria for type, material, and UN performance rating.  

Outer Packagings 

The outer packaging for a lab pack must be a UN rated packaging. Outer packagings may contain only ONE hazard class of compatible waste materials, and each outer packaging must be “full”—packed with inner packagings and absorbent—before it is closed. 

The gross weight limit for each completed package is 205 kg or 452 lbs. The “gross weight” of a package includes the weight of the cargo and the weight of the packaging. 

With rare exceptions,* authorized outer packagings for lab packs include: 

• Metal, plywood, fiber, or plastic drums performance-rated to at least the PG III level.  
• A specific type and strength of double-walled fibreboard box lined with polyethylene, and 
• Certain types of fibreboard or composite IBCs lined with polyethylene. 

UN performance rating criteria and other requirements for drums, boxes, and IBCs used as lab pack outer packagings are in 49 CFR 173.12(b)(2)(ii). 

* The rare exceptions: 1) Division 4.2, PG I materials must be shipped in a UN steel or plastic drum that meets PG I performance standards. 2) A fibreboard box may not be used to ship bromine pentafluoride or bromine trifluoride.  

Lab Pack Exceptions for Shipping and Disposal

Lab packs are excepted from some of the transportation and disposal requirements that normally apply to hazardous materials and wastes. US DOT's Hazardous Materials Regulations (HMR) and US EPA's RCRA hazardous waste regulations each contain exceptions for lab packs.  

• Lab pack exceptions for transportation: 49 CFR 173.12(b), (d), and (f). 
• Lab pack disposal reliefs: 40 CFR 268.42(c), 

Exceptions for lab packs include broader and less costly packaging options, fewer marking and labeling requirements, relief from some hazardous waste disposal standards, and more.  

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Tags: chemicals, hazmat shipping, lab pack