A question from the regulated community (01.26.17): Hello, Do the new labeling requirements impact lab packs? Are they considered ‘non-bulk’ and thus must conform to the new UN size? Thanks, My reply, buying time: That’s a good question! Let me…
Q&A: Lab Packs and Satellite Accumulation Areas for Hazardous Waste
(12.12.16) From a customer who had just completed one of my RCRA Training Webinars: Hi Daniel, Thanks for the training today. I am working on completing the evaluation and will get that to you soon. I have a couple of…
Exception to the Segregation Restrictions of 49 CFR 177.848 for Lab Packs of Hazardous Waste
49 CFR 173.12 contains many exceptions to full regulation for shipments of hazardous waste in a lab pack. In an earlier blog post I discussed the exception in 173.12(d)that removes the need to include the technical name of a hazardous…
The Exception From use of the Technical Name for Lab Pack Shipments of Hazardous Waste
Sometimes when shipping hazardous materials the proper shipping name does not adequately describe the contents of the shipment. An example of this, found in the Hazardous Materials Table (HMT) at 49 CFR 172.101 is the proper shipping name of: Flammable Liquids, n.o.s. This…