A lab pack is a combination packaging that lets small containers of waste chemicals ship together in one outer drum or box. Under 49 CFR 173.12(b) the inner packagings are limited to 4 litres for glass and 20 litres for metal or plastic, liquids must be surrounded by enough compatible absorbent to soak up the entire contents, and the completed package may not exceed 205 kilograms gross.

Can different hazard classes go in the same lab pack drum?

No. 49 CFR 173.12(b)(2)(ii) states that each outer packaging may contain only one class of waste material. Separately, 40 CFR 264.316(d) prohibits incompatible wastes from sharing an outside container, so materials in the same hazard class can still need separate drums.

Which materials cannot be lab packed at all?

49 CFR 173.12(b)(3) prohibits materials poisonous by inhalation, temperature controlled materials unless they comply with 173.21(f)(1), Division 6.1 Packing Group I materials, chloric acid, and oleum. Only Classes 3, 4.1, 4.2, 4.3, 5.1, 5.2, 6.1, 8 and 9 are eligible in the first place.

Can waste cyanides ship with waste acids?

Only under the specific limits in 49 CFR 173.12(e)(2). The cyanide may not exceed 2 kilograms net per inner packaging and 10 kilograms per outer packaging, or 2 litres and 10 litres for solutions, and the acids must be in lab packs or in single packagings authorized in Column 8B not exceeding 208 litres.

Which waste codes are excluded from the lab pack land disposal standard?

Appendix IV to 40 CFR part 268 excludes D009, F019, K003, K004, K005, K006, K062, K071, K100, K106, P010, P011, P012, P076, P078, U134 and U151 from the alternative lab pack treatment standard in 40 CFR 268.42(c).

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Lab Pack Segregation Tool

Look up any UN number or shipping name to see whether it can be lab packed at all, which pack family it belongs in, what it must be kept away from, and the container limits that apply. Built entirely from federal regulation: 49 CFR 173.12, 40 CFR 264.316 and 265.316, and 40 CFR 268.42(c).

Look Up a Material

Try acetone, UN1830, sodium hydroxide, hydrogen cyanide, or picric acid.

Lab Pack Rules Reference

Which classes may be lab packed

Waste materials in Class 3 and Divisions 4.1, 4.2, 4.3, 5.1, 5.2, 6.1, 8 and 9 are excepted from the specification packaging requirements for combination packagings when packed as a lab pack and moved for disposal or recovery by highway, rail or cargo vessel.

Explosives, gases and radioactive material are not on that list, so Class 1, Class 2 and Class 7 cannot be lab packed.

When two or more chemically compatible wastes in the same hazard class share an outer packaging, a generic description from the 172.101 table may be used instead of specific chemical names.

49 CFR 173.12(b)(1)

Materials that may never be lab packed

A material poisonous by inhalation
A temperature controlled material, unless it complies with 49 CFR 173.21(f)(1)
A Division 6.1, Packing Group I material
Chloric acid
Oleum, that is fuming sulfuric acid

49 CFR 173.12(b)(3)

Container limits

Inner packagings. Glass may not exceed 4 litres (1 gallon) rated capacity. Metal or plastic may not exceed 20 litres (5.3 gallons). Inner packagings containing liquid must be surrounded by chemically compatible absorbent in a quantity sufficient to absorb the entire liquid contents.

Outer packaging. Each outer packaging may contain only one class of waste material. Authorized outers are a UN 1A2, 1B2 or 1N2 metal drum, a UN 1D plywood drum, a UN 1G fiber drum or a UN 1H2 plastic drum at Packing Group III performance or better; a double walled UN 4G fiberboard box with a 3 mil polyethylene liner at Packing Group II performance; or a UN 11G or 11HH2 IBC with a 6 mil liner at Packing Group II performance.

Division 4.2 Packing Group I must use UN steel or plastic drums at the Packing Group I performance level. Bromine pentafluoride and bromine trifluoride may not go in 4G fiberboard boxes.

Gross weight of the completed package may not exceed 205 kilograms (452 pounds).

49 CFR 173.12(b)(2)

EPA container and compatibility requirements

Inner containers must be non-leaking, tightly sealed, and made of a material that will not react dangerously with, be decomposed by, or be ignited by the waste.

The outer container is an open head DOT specification metal container of no more than 416 litres (110 gallons), packed full, with enough nonbiodegradable sorbent to completely sorb all liquid contents. Lab packs destined for incineration under 40 CFR 268.42(c)(1) may use fiber drums instead of metal.

Incompatible wastes must not be placed in the same outside container. Reactive wastes other than cyanide or sulfide bearing waste must be treated or rendered non-reactive before packaging; cyanide and sulfide bearing reactive waste may be packed without prior treatment.

40 CFR 264.316 and 40 CFR 265.316

Land disposal restrictions on lab packs

Lab packs may use an alternative to the otherwise applicable subpart D treatment standards, provided they meet 40 CFR 264.316 or 265.316, contain none of the codes below, and are incinerated under part 264 or 265 subpart O.

Codes excluded from the alternative standard: D009, F019, K003, K004, K005, K006, K062, K071, K100, K106, P010, P011, P012, P076, P078, U134, U151.

Incinerator residues from lab packs containing D004, D005, D006, D007, D008, D010 and D011 must then meet the subpart D treatment standards for those codes.

40 CFR 268.42(c) and Appendix IV to 40 CFR part 268

Loading lab packs with incompatible materials

Lab packs are excepted from the segregation tables in 49 CFR 174.81(d), 176.83(b) and 177.848(d) when blocked and braced so they are separated from incompatible materials by at least 1.2 metres (4 feet) horizontally and loaded at least 100 millimetres (4 inches) off the floor.

The vehicle may not contain any Class 1 explosives, Class 7 radioactive material, or uncontainerized hazardous materials.

Waste cyanides with waste acids. Cyanide or cyanide mixture may not exceed 2 kilograms net per inner packaging or 10 kilograms per outer. Cyanide solutions may not exceed 2 litres per inner or 10 litres per outer. Acids must be in lab packs or in single packagings authorized in Column 8B, not exceeding 208 litres.

Waste Division 4.2 with waste Class 8 liquids. The 4.2 material may not exceed 2 kilograms per inner or 10 kilograms per outer.

Waste Division 6.1 PG I Zone A with Class 8 liquids or Divisions 4.2, 4.3, 5.1 and 5.2. Division 5.1 is limited to 2 kilograms per inner and 10 kilograms per outer, with 100 kilograms aggregate per vehicle. Division 5.2 is limited to 1 kilogram per inner and 5 kilograms per outer, or 0.5 and 2.5 kilograms for Organic Peroxide Type B, with 50 kilograms aggregate per vehicle.

49 CFR 173.12(e)

Potentially incompatible waste groups

This tool reports what federal regulation says. It is not a waste determination. The generator retains responsibility for characterizing its waste under 40 CFR 262.11 and for the accuracy of the shipping description. Pack family suggestions here are based on hazard class and the incompatibility groups in Appendix V to 40 CFR part 265; your receiving facility may impose stricter profile, concentration or code restrictions than the regulation does. State requirements can be more stringent than federal. Always confirm against the current 49 CFR 172.101 table entry for the material you are shipping.