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9/17/2007

EPA and DOT Requirements for Lab Packs [40 CFR 268.42(c) and 49 CFR 173.12(b) Lab Packs]


EPA requires waste generators to determine if their wastes meet the definition of hazardous waste at 40 CFR 261. If the wastes are hazardous wastes, they must be treated to meet the Land Disposal Restrictions at 40 CFR 268 prior to land disposal. This generally requires the creation of a “land ban form” that describes the waste codes, subcategories, and the treatability group of the hazardous waste.

If a hazardous waste generator packages several containers of hazardous waste into an overpack, referred to as a lab pack, the generator can take advantage of the alternate land disposal treatment standard for lab packs. If the alternate treatment standard is selected, at 40 CFR 268.42(c), the EPA requires that the lab pack:

  • Not contain the waste codes D009, F019, K003, K004, K005, K006, K062, K071, K100, K106, P010, P011, P012, P076, P078, U134, or U151
  • Be incinerated and the incinerator residues from lab packs containing D004, D005, D006, D007, D008, D010, and D011 treated in compliance with the applicable treatment standards for those waste codes
  • Meets the requirements of 40 CFR 265.316, which require:
    • Non-leaking inside containers that are compatible with the wastes
    • A steel or fiber outer package not exceeding 110 gallons
    • All wastes to be compatible with other wastes in lab pack
    • Any reactive waste (other than cyanide or sulfide wastes) to be rendered non-reactive before lab packing

The DOT allows some exclusions for lab packs at 49 CFR 173.12(b). The criteria are as follows:

      • Only class 3, 4.1, 4.2, 4.3, 5.1, 6.1, 8, and 9 are allowed
      • Specifically forbidden are poisonous by inhalation materials, 6.1 PG I, and 4.2 PG I materials, chloric acid, and oleum (fuming sulfuric acid)
      • The outer package must be either a 1A2 or 1B2 metal drums, or a 1G fiber drum, (DOT actually allows other types of packages, but EPA does not, so they are not mentioned here) and must be tested and marked for at least a PG III performance standard
      • The inner packages must not exceed 1 gallon or 5.3 gallons, for glass or metal/plastic, respectively
      • Only one hazard class per outer package is allowed
      • The outer package must contain enough compatible absorbent to absorb the total liquid contents
      • The gross weight of the complete package cannot exceed 452 pounds

To learn more about these and other hazardous waste management requirements, attend Environmental Resource Center’s Hazardous Waste Management: The Complete Course or our Advanced Hazardous Waste Management seminar. Or, to see how Texas and California’s hazardous waste programs address these issues, attend our Hazardous Waste Management in Texas or Hazardous Waste Management in California seminars.