Using Lab Packs for Chemical Shipments
Laboratories, universities, medical facilities, and warehouses use and generate many different chemical substances. Sometimes these chemicals go unused—they may be out of date, off-specification, or simply no longer needed. To protect employees from potential hazards or to simply reduce the inventory of unwanted materials, facilities remove these unused chemicals from inventory.
Unused chemicals accumulate for a number of reasons. A corporate purchaser may buy chemicals in bulk, not knowing that much of the bulk purchase will go to waste due to process or time constraints. Research and development professionals may use part of many different hazardous chemicals and generate various by-products. In addition, a lab closeout may reveal forgotten stockpiles and left-over reactions. These unused substances often include acids, bases, reagents, aerosols, cleaning agents, inks, dyes, paints, solvents, and unidentified chemicals.
In these situations, and many more, the facility is left with many small amounts of unused chemical substances that will be discarded. Packaging and shipping each of these small amounts separately for disposal can be a time-consuming and even cost-prohibitive task. This is one reason for why the US DOT allows shippers to use an alternative packaging method for these shipments.
Shipping Chemicals in a Lab Pack
An easy, cost-effective way to ship collections of different hazardous chemicals off site is to use “lab packs.” A lab pack consists of a DOT-authorized outer packaging containing two or more smaller containers of hazardous wastes.
The US DOT regulations at 49 CFR 173.12(b), (d), and (f) include special requirements for transporting lab pack shipments. 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. In addition, the materials shipped in the lab pack must be of the same DOT hazard and compatible.
There are other requirements specified in 49 CFR 173.12, so the process of preparing a lab pack must be performed by individuals with an appropriate level of knowledge in chemistry and the necessary function-specific training.
Lab Pack Treatment Standards
Each container of discarded chemical in a lab pack is generally subject to its own land disposal restriction (LDR) treatment standards at 40 CFR 268. Requiring the TSDF to treat for each of the treatment standards can add complexity, and likely cost, to the disposal process. Therefore, the EPA has included an alternative treatment standard to the LDR requirements at 40 CFR 268.42(c).
The alternative treatment standard allows for the incineration of the entire lab pack. In order to utilize this treatment standard, the generator must identify each waste code that applies to the wastes in the lab pack and certify, in writing, that the lab pack does not include any of the prohibited wastes codes specified in Appendix IV in 40 CFR 268.7(a)(9). Appendix IV includes the following waste codes: D009, F019, K003-K006, K062, K017, K071, K100, K106, P010-P012, P076, P078, U134, and U151. Lab packs that contain toxic heavy metals or other highly dangerous chemicals (cyanide, arsenic, etc.) 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.
Unused chemicals that are discarded may be hazardous waste and must be managed correctly. By using the standards for lab packs, facilities ensure the materials are properly transported and that proper treatment and disposal of the different hazardous chemicals is accomplished—protecting the public and the environment and minimizing the potential for fines.
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