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Lab Packs

This guidance will help you to report the generation, management, or shipment of lab packs on the GM form; and/or the receipt of lab packs on the WR form.

What is a Lab Pack?

Lab packs are small containers of state and/or federal dangerous waste in over packed drums. If you are not reporting a lab packed waste you do not need this guidance.

It is easy to confuse some federal reporting codes with previous Washington State only designation waste code for PCBs.

•  Ecology changed the W001 waste code for PCBs to WPCB to avoid confusion with the new EPA Form codes for annual reporting in 2005.
• The form codes W001, W002, and W004 are reported in Section A-8 on the GM Form and Section A.7 on the WR Form.
  • The Form codeW001 refers to lab packs without acute hazardous waste.
  • The Form code W004 refers to lab packs containing acute hazardous waste.
  • The Form code W002 is not a lab pack code. It refers to contaminated debris: paper, clothing, rags, wood, empty fiber or plastic containers, glass, piping, or other solids.

Acute hazardous wastes are likely to be packed in lab packs. Acute Hazardous Wastes are chemicals on the "P" list of discarded chemical products. An example is P065 which means mercury fulminate. The only acute hazardous wastes are the "P" chemical wastes, any containers and/or inner liners which held "P" chemical wastes, or any spill clean-up residues or contaminated soil or water from "P" chemical wastes.

How to Report a Lab Pack on the GM Form

•  A-2. Waste description: Enter description of wastes.
• A-3. EPA waste codes: Leave blank or fill out as appropriate.
• A-4. Washington state-only waste codes: Leave blank or fill out as appropriate.
• A-5. Designation: Complete as appropriate: if you entered WT01, WP01, or WP03 in question A-4, select EHW; if you don't have any of those enter DW.*
• A-7. Source code: Enter an appropriate code.
• A-8. Form code: Enter W001 for lab packs without acute hazardous waste, or enter W004 for lab packs containing acute hazardous waste.
• A-9. Origin code: Fill out as appropriate.
• B-1. Quantity managed in the reporting year: If you are able to, estimate the quantity of the waste contents of the lab pack(s), excluding the containers. Otherwise, enter the overall quantity.
• Complete the rest of the form as appropriate.

Note: Lab packs do not qualify for recycling credits.

How to Report a Lab Pack on the WR Form

• A.2. Waste description: Enter description of wastes.
• A.3. EPA waste codes: Leave blank or fill out as appropriate.
• A.4. Washington state-only waste codes: Leave blank or fill out as appropriate.
• A.5. Designation: If you answered WT01, WP01, or WP03 in question 4, select EHW; if you answered none of the above enter DW.*
• A7. Form code: Form code: Enter W001 for lab packs without acute hazardous waste, or enter W004 for lab packs containing acute hazardous waste.
• B.8. Quantity received in the reporting year: Estimate the quantity of the contents of the lab packs).
• Complete the rest of the form as appropriate.

* Remember that a single waste stream should have only one DW or EHW designation. Do not combine EHW and DW lab pack waste on a single annual report form. If' you have a lab pack that is EHW and one that is DW, you should have two separate GM or WR forms. If EHW and DW waste is mixed in one lab pack, then report the waste stream as EHW waste.