Lab Pack Guide: What Your Business Needs to Know About LabPacking Hazardous Waste for Shipment and Disposal

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Lab Pack Guide: What Your Business Needs to Know About LabPacking Hazardous Waste for Shipment and Disposal

Guide to Managing Wastes for Laboratories

This guide was originally prepared by the U.S. EPA to provide information about small chemical laboratory environmental issues. EHSO has updated and revised it to make it more useful. Click here for the printable pdf version of the SMALL LABORATORY GUIDE (814K) Be sure to ALSO see this page on OSHA lab standards and requirements !!!

Note, labs at schools, colleges, achademic institutions and certain research facilities have a separate option, Subpart K to Part 262. Click here to see that option.

The Guide for Laboratories offers the following:

• Small Lab Characterization and Applicable Regulations: A summary of lab activities and the federal regulations that typically affect these activities. Key topics include lab waste management, lab air quality management, and lab wastewater management.
• Self Assessment Tool: A set of questionnaires that labs or others can use to assess relative environmental status in the key areas mentioned above. With an emphasis on pollution prevention, these tools should be useful to labs of all types and sizes.
• Directory of Applicable Resources: Although there is a lot of information available on labs, much is not relevant to the environmental issues associated with small chemical labs. This directory contains a listing of books, newsletters, meetings, and Internet sites that should be useful for anyone interested in the subject. Each source has been screened for relevancy.

What is a "laboratory?"

The word "laboratory" (or "lab") is generally used to describe a facility that conducts experimental or routine testing. Most people associate labs with activities involving chemicals.

Although there are some large lab organizations, such as research and development functions in corporations and government, most labs are small businesses or small entities within larger organizations. These labs may be in hospitals, warehouses, business, colleges or a stand-alone business or operation.

For example, many communities have at least one independent testing lab with 10 or fewer employees. These local labs may test a wide range of environmental, physical material, medical, biological, or food samples. A review of your local telephone directory often reveals a surprising number and variety of labs. At most small labs, environmental management is a "shared" responsibility as opposed to that of a single individual.

Common lab types include:

• Clinical labs associated with medical or dental practices.
• Forensic testing labs.
• Environmental testing labs.
• QA labs for chemical or other manufacturing plants.
• Teaching and academic research labs (grade school, high school, and college).

In each of these cases, it is useful to think of the lab as a small business that either operates on its own or is "captive" to a larger organization. The environmental aspects of "captive" labs should be evaluated independently because lab staff and activities are often very different from the rest of the organization or business they are associated with.

To help protect workers from the diversity of chemical hazards in labs, The Occupational Safety and Health Administration (OSHA) established the " Lab Standard " in 1990. OSHA estimated there are about 35,.000 labs in the U. S.. Given this number, it is probably safe to assume that most states have hundreds of labs.

What is a "small lab" - Is it different from a "large" lab?

For the purpose of this guide, a "small lab" is one that has no full-time position in environmental management. In small labs, environmental management is most likely a shared responsibility or administered by part�time staff or through collateral duty. Given this definition, most labs probably fall into this "small lab" category and will benefit from this document . Of course, many large labs should benefit from the information contained in this document as well. However, large labs are likely to have additional environmental management responsibility that is not fully addressed here. Air emissions management is one example where large labs, especially those involved in research and development may have additional responsibility because large lab air emissions may be greater.

Small labs are diverse in their settings and operations. Some small labs are affiliated with a larger organization, while others are independent operations. Given widespread use of the word "lab" many types of small labs exist; a few are listed below.

All of these small lab types should benefit from the information in this Guide. The remainder of this document is organized into four additional sections.

• Section 2.0 Environmental Management in Small Laboratories - Presents information on the overall environmental management system at a small lab including the implementation of pollution prevention and environmental training programs.

• Section 3.0 Key Environmental Management Issues - Provides descriptions of 15 key regulatory programs and media-based environmental management areas that impact the effective operation of small labs. These range from air pollution control to sustainable practices such as energy and water conservation.

• Section 4.0 Reliable Resources - Lists additional information sources on small lab environmental, health, and safety management.
• Section 5.0 Little Known but Allowable Ways to Manage Hazardous Waste - Provides a description of five ways EPA allows for the on-site treatment of hazardous wastes. Many labs should find these methods useful, but it is important to check state, local and tribal regulatory programs first.

What environmental issues occur in labs?

Unlike other small businesses such as printers, auto shops, and dry cleaners, which tend to generate large quantities of a few pollutants, labs typically generate small quantities of a wide variety of pollutants. This characteristic requires careful attention in dealing with labs on compliance and on pollution prevention issues. In fact, because of this characteristic, the term "lab pack" was coined years ago by hazardous waste firms to describe a typical method of waste handling. In a "lab pack" a number of small containers (i.e. jugs and bottles) of hazardous waste, are individually packaged in a traditional 55 gallon drum. Although "lab packs" appear inefficient compared to combining all materials, they make sense because it is unwise, for safety and legal reasons, to encourage mixing different lab wastes in a single container.

Like many other small businesses, labs have environmental challenges and opportunities. associated with air quality management, wastewater management and hazardous waste management. Some examples follow:

• States and local municipalities often regulate wastewater discharges and may also regulate lab fume hood exhausts through a permitting system. The uneven natural patchwork of regulations requires each lab situation to be carefully evaluated.
• Many labs perform "sink disposal" of waste materials. Though legal in many cases, this practice is still not necessarily the best environmental management choice.
• Labs may resist using recycled materials, especially solvents, in analyses due to concerns about compromising test result quality. Because the results of testing are used to make decisions that often have severe financial or legal consequences for their customers, labs are typically focused exclusively on quality and may be resistant to material or process changes.
• Labs often must follow standard test methods and therefore cannot easily deviate in procedures or materials.
• Labs often stockpile samples (which may be hazardous) and aged chemicals, until there is no longer sufficient storage space. When this happens, labs may have a "Spring Cleaning" which could temporarily catapult them into a higher RCRA generator class and cause unnecessary disposal costs and paperwork.
• Some states, like California and Washington, have special lab-based regulations or assistance programs that may also occur elsewhere. These programs are not well publicized.

In general, labs present a unique environmental compliance and pollution prevention situation that is very different from arty other small businesses needing assistance.

More special issues about labs

There are a number of additional concerns about labs that readers should be aware of. Among the most important are:

• Unique health and safety concerns associated with site visits. Visitors should be especially cautious during a lab site visit because special training is often needed to work within a lab. Consider, for example, that lab workers have the second highest rate of HIV/AIDS infection from occupational exposure among all professions (after nurses).
• Lab workers tend to be highly educated compared to many other small business types. Thus it would not be unusual to provide assistance to workers with advanced college degrees, some of whom may have uniquely advanced knowledge of chemicals and reactions.
• Academic or teaching labs provide a special opportunity to provide training. In these labs, students are learning, for the first time, how to deal with chemicals. It is important that they also learn, at the same time, how to handle these materials in a way that does not Cause pollution. Environmentally responsible work habits learned in an academic lab will hopefully be taken elsewhere in the job market.

Finally, because there is no single association representing all labs, it is difficult to reach them effectively. Conversely, it is difficult for the labs to learn about the resources EPA and states can offer.

What EPA resources are available?

EPA recognizes the unique environmental challenges associated with small lab operations and has developed a document titled, "Environmental Management Guide for Small Laboratories" (Guide).