Guide
What is a lab pack?
Last reviewed 29 October 2026
A lab pack is an outer container, usually a drum, holding many small containers of hazardous waste, with absorbent packed around them. It's how laboratories, schools, hospitals and plants send away leftover and outdated chemicals in their original bottles, without opening each one.
Lab packs are put together on site, most often by crews from environmental services companies. They inventory every container, classify each chemical, keep incompatible ones apart and pack the rest by hazard, then prepare the paperwork that goes with the drums. A single job can involve hundreds of different chemicals.
How RCRA says a lab pack is packed
The RCRA rules for lab packs, at 40 CFR 264.316 and 265.316, set out how the containers go into the drum:
- Each inside container must be tightly sealed, must not leak, and must not react with, be broken down by or be ignited by what it holds.
- The inside containers go into an open-head, DOT-specification metal drum of no more than 416 liters (110 gallons), which must be full once packed.
- They're surrounded by enough sorbent to soak up all of the liquid, and the sorbent must not react dangerously with what's in them.
- Incompatible wastes may not share an outer container.
- Reactive wastes are treated or made non-reactive before packing, except for cyanide- and sulfide-bearing reactive wastes.
How lab packs meet the land disposal restrictions
Most hazardous wastes must meet a treatment standard before they can be land disposed. Lab packs have an alternative, at 40 CFR 268.42(c): instead of treating each waste to its own standard, the lab pack may be incinerated in a unit that meets the RCRA incinerator rules, if:
- it's packed to 40 CFR 264.316 or 265.316;
- it holds none of the wastes listed in Appendix IV to part 268; and
- incinerator residues from lab packs holding D004, D005, D006, D007, D008, D010 or D011 wastes are treated to those wastes' own standards.
A generator using this standard sends a notice and certification with the first shipment. Our guide to LDR notices covers it.
How DOT lets a lab pack travel
49 CFR 173.12(b) lets waste chemicals in small containers ship together in one outer packaging, under a generic description, when the package meets its terms:
- Inner packagings of glass hold no more than 4 liters (1 gallon); metal or plastic, no more than 20 liters (5.3 gallons).
- Liquids are surrounded by enough compatible absorbent to take up all of the liquid.
- Each outer packaging holds only one hazard class of waste, and its materials must be compatible.
- The outer packaging is one of the drums, boxes or bulk containers the rule names, tested to the level it sets, and the completed package weighs no more than 205 kg (452 lb).
- Some materials can't travel this way at all: materials poisonous by inhalation, Division 6.1 Packing Group I materials, chloric acid, oleum, and temperature-controlled materials unless they meet 173.21(f)(1).
What travels with a lab pack
- The hazardous waste manifest, which follows the shipment to the receiving facility.
- The land disposal restriction notice, with the first shipment of each waste to each facility.
- An inventory of what's in each drum, which receiving facilities ask for.
Where Pack-Star comes in
Every one of these rules has to hold for every container on every job. Pack-Star checks each placement against DOT, RCRA and facility rules as you pack, and writes the paperwork from the job itself.
A note on this guide
This guide summarizes federal rules as they stood when it was last reviewed. States can add requirements of their own, and the regulations themselves are the authority. It's general information, not legal or regulatory advice: see our disclaimers.