Lab Pack Management: Removal of Lab Waste in Schools and Laboratories
January 8, 2024

A lab pack, also known as an ‘over-pack’ is the gathering of small amounts of listed hazardous chemicals which have been re-packaged safely into an approved lab pack disposal container. The container is normally a fiber or steel fifty-five-gallon drum.

The lab pack’s purpose is to facilitate disposing of the chemicals properly under federal regulations. The amounts of the chemicals are generally less than ten gallons each, and while very small in amounts when compared to other hazardous wastes generated, they are no less dangerous.

What Does the Disposal Process Involve?

The disposal of the lab pack involves identifying, categorizing, and separating each of the acids, solvents, base, and chemicals, repackaging each of them, and then depositing the packages into a drum that is no larger than a one-hundred and ten gallons. Once the drum is full, or all chemicals generated have been placed into the drum, an absorbent substance like vermiculite is added to the top of the container.

If the container or drum should leak or become damaged, it has to be ‘over-packed’ into a larger drum. Once the container is full of the lab wastes generated, it is ready to be correctly labeled, marked, and then readied for proper transport by a professional hazardous waste disposal service.

What is the Purpose of a Lab Pack?

Companies and organizations such as manufacturing facilities, hospitals, automotive industry, dry cleaners, schools, and laboratories need lab decommissioning, and this is even more vital in the educational sector.

  • Lab Decommissioning– this is the process of performing a formal deactivation of a laboratory. It ensures the safety of the space for further occupancy, renovation, and cleaning. The method of decommissioning would involve an inspection if radioactive materials were used by the RSS (EHS Radiation Safety Service).

Community colleges, universities, and high school chemistry labs contain a lot of toxic, flammable, reactive, poisonous, and corrosive chemicals which are used for demonstrations during an academic term. These chemicals have to be disposed of at the end of each term or school year. Lab packing is not only fully compliant with the required disposal requirements, but it is also the safest method to use when removing hundreds of different lab chemicals at one time.

Local, State, and Federal Concerns Over Lab Pack Disposal

The EPA (Environmental Protection Agency) through the  RCRA (Resource Recovery and Conservation Act, along with the LDR (Land Disposal Restrictions) program have very strict guidelines that must be followed on lab pack chemicals. The state and local environmental agencies also have regulations and guidelines that must be adhered to as well when disposing of lab waste.

It violates the law to pour hazardous chemicals down a drain or throw them out with the regular garbage generated. The government has very strict laws in place which forbid lab pack chemicals being combined without having a licensed chemist at hand to oversee the process. Without proper monitoring, a volatile eruption could occur, which would lead to a more expensive disposal fee. There are even some states that require schools to report the lab pack chemicals they have destined for disposal.

State organizations along with the EPA have strict rules on lab decommissioning as well as the DOT (Department of Transportation), and OSHA (Occupational Safety and Health Administration) have their set of requirements regarding the safe handling, treatment, and transportation of lab waste.

Besides the legal requirements of adequately disposing of lab waste, there are also real-life anxieties connected to storing out-of-date, partially-used, contaminated, chemicals for too long of a time. Explosions are a real possibility for some of the acidic chemicals when they age or react.

End of the Year Lab Pack Disposal 

At the end of an academic school year, you will need to look for means on how to dispose of lab waste, and it is vital all proper and safe practices are in place.

How to Properly Dispose of School and Laboratory Lab Waste

It would be wise and beneficial to your institution if you consulted a federally-licensed treatment, storage, and disposal facility regarding the stringent regulation that must be followed regarding small-volume lab waste. You can also consult with an approved hazardous waste disposal service that is able to handle your lab waste according to all laws.

Why the Need to Dispose of Lab Waste at Year-End

School laboratories looking to dispose of lab waste at the end of the school year will want to use the safest and best methods. Improper storage and handling methods of lab waste, or the non-disposal of such chemicals, can create serious health hazards, legal action, and large fines.

Usually an academic campus is not thought of in terms of hazardous waste generators; however, research and teaching labs while only creating a small percentage of dangerous waste, you are not exempt from being classified by the EPA (Environmental Protection Agency).

School laboratories are still capable of generating thousands of different types of hazardous chemicals and are still considered hazardous waste, even if they are chemicals that are going to be unused. Disposing and storing these materials properly and according to regulations is not only a safety issue but also the law.

EPA Regulatory Acts Applies to School Lab Waste

School lab chemicals and their generators fall under the regulations of two EPA regulatory acts:

  • CERCLA also called the ‘Superfund’ Act, was put into place in 1980 and is a regulation widely known to require generators of chemical waste to clean up any waste dumps. This act applies to any sector regardless of their propriety or their practice during the generation of said hazardous waste.
  • RCRA (Resource Conservation and Recovery Act) mandates that generators, including those in the educational sectors, dispose of their chemical waste promptly.

Lab packing is the only safe and compliant manner in which the EPA allows academic labs to remove their lab waste. OSHA (Occupation Health and Safety Administration) along with the DOT (Department of Transportation) have their own set of requirements which govern the educational or any sector handling and shipping of hazardous lab waste.

Inspection of How Lab Waste is Handled Can Happen Anytime

Legislation isn’t just put into place and forgotten with the hopes all sectors will abide by the rules. Surprise inspections by both state and federal agencies are conducted to ensure all rules are being followed. In one case at the Massachusetts Institute of Technology during a surprise inspection, it was discovered there were 56 of their 114 labs that were in violation of lab waste disposal, storage, or labeling of their lab waste materials.

Other universities have been found in violation of preventable laboratory chemical wastes as well for not storing lab waste properly, mislabeling their waste, not providing essential training or chemical waste management, having open containers of lab waste, or dumping mercury improperly.

Learning From Other’s Mistakes about Lab Packing

You can learn from the mistakes other educational institutions have made in regards to lab packing. Training is an essential part of dealing with hazardous materials and will go a long way to ensure your campus complies with the law.

Improperly disposing of toxic chemicals such as mercury, or keeping out-of-date materials is easily remedied by an experienced and reliable lab packing company. Having trained chemists working with an experienced cleanup crew during the lab packing process will ensure your chemicals are treated to meet EPA’s regulations. It also ensures there are no potentially dangerous chemical reactions occurring in the process.

Educational Institutes Regulation Rule

The EPA (Environmental Protection Agency) created and finalized an Academic Laboratories Rule in 2008. This rule added Subpart K to the Resource Conservation and Recovery Act to specifically apply to educational labs and their improper disposal of lab packs.

Subpart K states schools and university labs must remove unused or unneeded chemicals at regular intervals, or within six months of the chemical’s accumulation start date. Generation of hazardous lab waste is a liability for your university or school.

It is common sense to follow the line of all state and federal rules regarding the disposal, storing, handling, and labeling of your lab waste. There are a number of regulatory and compliance concerns in place for your school’s or university’s safety and health welfare which relate to the toxic nature of lab waste.

How to Choose the Right Hazardous Waste Disposal Service for Lab Waste

When looking for the right hazardous waste disposal service, it must be EPA-compliant, have the correct certification, and be up-to-date with all regulatory requirements. You will want to ask the service if they have all staff up-to-date with the required training, experience, skilled chemists, detailed cleanup crews, and have their paperwork required to perform a lab decommissioning.

You may also want to check if the service offers a ‘paper pack’ service, which means they have a knowledgeable off-site chemist that is capable of performing the legwork of chemical inventory before disposal. This service may not be available, but you can inquire as to if it is offered, as it will significantly cut down on labor costs associated with the lab packing procedures.

Choosing the right company to meet your institution’s needs can be an intimidating process, but when you know the criteria, the service should offer, it will help you narrow the search. The factors of the right lab pack disposal service for you depends on:

  • The amount and the nature of chemicals you have in your labs
  • How fast you need the disposal to occur
  • Where your school or educational institute is located

You will also need the waste disposal service to:

  • Be able to handle the lab waste you will have
  • Follow all EPA, DOT, and OSHA regulations
  • Be within your service location
  • Follow all rules and regulations regarding the retraining of trained chemists
  • Be able to file and provide all necessary paperwork
  • Follow all the correct procedures
  • Be cost-efficient

Use these few factors, and others to help you choose the right hazardous waste disposal service to meet your educational institute’s needs.

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