What are Lab Packs and How Could Your Facility Use Them?
I've never been a fan of "spring" cleaning, but it's a necessary part of good housekeeping around the home or at your facility.
About the Author: iSi’s Casey Moore has more than 25 years of experience in the hazardous waste industry including working for hazardous waste carriers and operating hazardous waste facilities in California and Arizona.
I’ve never been a fan of “spring” cleaning, but it’s a necessary part of good housekeeping around the home or at your facility. When was the last time your facility did a “spring cleaning” walkthrough to see if there are any materials around your workplace that are expired, or you don’t need?
⚡ TL;DR — Lab packs consolidate expired chemicals, solvents, and paints from small containers into properly classified, DOT-compliant hazardous waste shipments. One cleanup trip instead of individual disposal headaches.
Flammable cabinets, chemical storage, research/QC labs and maintenance shops are likely places these items accumulate.
⚠️ The Problem — Expired materials sitting around create inventory liability and environmental risk. Improper segregation during cleanup can mix incompatible chemicals. Facilities that don’t consolidate correctly face DOT non-compliance and RCRA generator status penalties.
What is a Lab Pack?
Since most of the items in these locations are likely to be in smaller containers, they aren’t treated like regular waste streams. Lab packs are a practical solution. Lab packs are consolidation packaging of “like” materials from the smaller containers into larger containers to satisfy proper DOT shipping and EPA RCRA hazardous waste management.
The lab pack was designed for managing expired materials in labs, however, it’s something that can be used for any facility that needs to do a cleanout of smaller containers usually less than 10 gallons each.
What Items Are Candidates for a Lab Pack?
Look for jars, jugs, vials and cans of hazardous materials, including chemicals, solvents, paints, thinners, acids, cleaners, strippers, inks and more. These are typically out of date, off-specification, partially used, and no longer needed.
Who Does Lab Packing?
There are strict regulations about who is qualified to do lab packing. These persons need to determine which containers can be put together and which ones may cause harmful reactions when mixed. Typically, hazardous waste carriers provide this service.
How is Lab Packing Accomplished?
First, items are segregated, that is, sorted, for combining into one larger container. Items are segregated by:
Hazard class — most common are flammables, corrosives, and toxics Type of material — liquids, solids, etc. Compatibility
“Paper pack” is the term used to show the segregation by container. An initial inventory list is converted into lab pack inventory sheets (what goes into each container). This is what waste companies use to create approval numbers for compliance under RCRA. It is also how they establish price. Pricing is based on disposal, transportation and labor associated with packaging.
Packaging is accomplished by:
Putting the segregated materials into their respective larger containers; Filling with a packing material (vermiculite is most common) to create stability and containment while shipping; Vermiculite will be in the base and surrounding each of the internal containers; and, The smaller containers are placed into the larger container vertically, so the label with the double arrows pointing up is on the outer packaging.
RCRA Regulation Implications
A lab pack counts towards your waste generation status if you’re a Very Small Quantity Generator (VSQG) or a Small Quantity Generator (SQG), so be mindful of the amount of hazardous waste generated in the process. For states that have already adopted the Generator Improvements Rule, this is a good use of the episodic event and would not count against your generator status.
Most facilities misjudge how many materials trigger RCRA generator status. A facility cleanup can push you from non-generator into SQG territory, which changes your compliance requirements overnight. Knowing your state’s rules—and whether an episodic exception applies—saves thousands in compliance costs and avoids misclassification penalties.
If you have any questions regarding lab packs or hazardous waste regulations, reach out to our team.
💰 Typical cost: $1,500–$3,500 per lab pack shipment depending on volume and material variety. Mishandling hazardous waste cleanup can trigger RCRA generator status penalties starting at $5,000.
Frequently Asked Questions
Q: What are lab packs and when should a facility use them?
Lab packs are consolidated packaging of smaller containers (typically less than 10 gallons each) of hazardous materials into larger containers for proper DOT shipping and EPA RCRA compliance. Facilities use lab packs to consolidate expired materials, off-specification chemicals, solvents, paints, and small containers of hazardous waste from labs, QC areas, maintenance shops, and storage locations.
Q: How are lab packs categorized and segregated?
Lab packs are segregated by hazard class (flammables, corrosives, toxics), material type (liquids or solids), and chemical compatibility. A “paper pack” inventory is created showing which small containers combine into each larger container. This segregation ensures incompatible materials aren’t mixed, preventing dangerous reactions during transport and disposal.
Q: What qualifications do lab packers need to have?
Lab packers must be qualified hazardous waste professionals who understand chemical compatibility, hazard classification, and RCRA regulations. Typically, hazardous waste carriers provide lab packing services because they understand how to combine materials safely and maintain compliance with EPA and DOT requirements.
Q: How does lab packing affect a facility’s hazardous waste generator status?
Lab packs count toward your waste generation status for VSQG (Very Small Quantity Generator) or SQG (Small Quantity Generator) classification under RCRA. However, in states that adopted EPA’s Generator Improvements Rule, lab packing qualifies as an episodic event and may not count against your generator status. iSi Environmental helps facilities understand implications for their specific state.
Need help planning your facility cleanup? Contact iSi Environmental for a same-day quote, or explore our EPA services to see how we can help your facility.
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