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8.8 LAB PACKING and SEGREGATION Drums will be typically lab packed according to the following procedures: • Only compatible wastes will be labpacked in the same drum. • Only DOT-approved drums marked with DOT-approved labels are used to store and transport HHW. • HHWs are lab packed in their existing containers unless damaged. If repacking is necessary, the container will be placed in a bag made of compatible material, such as high-density polyethylene, or in a glass or plastic container, then placed in a drum. • Absorbent material compatible with the waste is used for packing containers in the drums. The drums are prepared by placing a layer of vermiculite poured in the bottom (2-3 inches). The items are carefully placed in the drum. A layer of absorbent is then poured covering the top of the containers (2-3 inches) and then more items are placed in the drum. This procedure is repeated until the drum is full. Once the drum is full, the lid is secured to the drum which is then taken to the compatible storage bay. • Drums will remain closed except when wastes are added or removed. Drums must be labeled with the EPA ID Number, generator information, DOT Description, Hazard Class, and Accumulation Start Date. It must also have Hazard Class Labels. • Drums with liquid waste must have up arrows (TT). • Supplies (such as PPE) contaminated with HHW will be decontaminated or disposed of as hazardous waste. SEGREGATION • All chemicals will be reviewed and assessed for packaging. Each will be assigned the proper DOT Hazard Class. Further segregation may be required for materials based on subsidiary DOT Hazard Classes, EPA treatment standards, and destination disposal permits/restrictions. When segregating materials, the following hierarchy should be used to determine the hazards associated with each material and thus segregate the materials into compatible lab packs: • Segregate the materials by initial hazard class than further by secondary hazard class. Chemicals with different secondary hazards may be packed together, provided they are compatible (secondary acids should not be packed with secondary bases). • If an item has a tertiary hazard class, this will most likely be packaged separately. • All items in one lab pack must be compatible. • Items that are lab packed must be authorized under 49 CFR 173.12(b); otherwise, the material must be packaged in accordance with the single packaging rules found in sections 49 CFR 173.201 - .229 for non-bulk packages. • The following hierarchy will apply when assigning descriptions: a. Liquid over Solid b. Organic over Inorganic Page 20 of 41