Chemical Packing

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Subpart P is a new group of healthcare specific regulations covering hazardous waste pharmaceuticals generated at healthcare facilities. The EPA now recognizes that healthcare is fundamentally different from other industries that generate hazardous waste. Their regulations have been updated to reflect that change.

Who does this new rule affect?

These new regulations apply, but are not limited to

• hospitals
• pharmacies
• clinics
• veterinary hospitals or clinics
• wholesale distributors or retailers
• Pyrophoric, gases, aerosol, unknown, reactive, explosive and shock-sensitive materials 
• Ethers, THF, dioxane and sodium azide

What does the EPA consider ‘pharmaceutical’?

• prescription medication
• OTC (over the counter) drugs
• dietary supplements
• compounded drugs
• investigational drugs
• personal protective equipment (PPE) contaminated with pharmaceutical waste
• clean-up material from pharmaceutical spills
• any item for which the FDA requires a “drug Fact” sheet

When do these rules become effective?

For the moment, current Resource Conservation and Recovery Act (RCRA) rules are enforced. Although Subpart P Rule is final, it will not become effective until six months after publication in the Federal Register. Individual States are required to adopt the rule, but they will have the ability to make changes. Actual rules and effective dates will differ by state.

Clean Harbors will continue to closely monitor these regulatory changes. For more information and updates, consult our Subpart P FAQs as well as this link.

Clean Harbors proprietary CleanPack Laboratory Chemical Packing services provide proper recognition, handling, packaging, transportation and disposal of laboratory chemicals. We also perform laboratory relocations, closures and cleanouts.

Clean Harbors can manage virtually any chemical found in a laboratory environment including:

• RCRA and non-RCRA chemicals
• TSCA, DEA, radioactive, mixed waste and universal waste 
• Biological and etiological chemicals
• Compressed gas and cylinders 
• Toxic, flammable, oxidizer, organic peroxide and corrosive materials 
• Pyrophoric, gases, aerosol, unknown, reactive, explosive and shock-sensitive materials 
• Ethers, THF, dioxane and sodium azide

Compliance

Throughout the chemical packing and disposal process, our skilled chemists help ensure your compliance with the latest EPA, DOT, TDG and Environment Canada regulations and record-keeping. 

Download Fact Sheet (CleanPack® Lab Chemical Packing​)

Clean Harbors provides a wide array of Reactive Material Services to ensure secure chemical management and safe disposal of unstable and explosive materials.

Clean Harbors has extensive experience working with unstable and shock-sensitive materials, as well as managing disposal of explosives and materials restricted from transportation. With a vast transportation fleet and permitted transfer storage and disposal facilities throughout the United States, Canada and Puerto Rico, we provide turnkey reactive material services. 

Reactive Material Services require specialized expertise and diverse techniques to ensure safety and compliance. Clean Harbors deploys multiple approaches to fulfill these goals.

Download Fact Sheet (Reactive Material Services​)

Container Evaluation 

Clean Harbors has standard operating procedures for the proper identification and evaluation of shock-sensitive, peroxidizable and unknown reactive materials. We follow strict evaluation criteria including age, storage conditions, exposure, contamination and stability.

Chemical Stabilization 

Clean Harbors understands the disadvantages of controlled detonation and has developed sound chemical stabilization techniques that enable us to manage the following types of potentially unstable materials (along with others on a case-by-case basis):

• Peroxide-forming compounds 
• Temperature-sensitive compounds 
• Organic peroxides 
• Shock-sensitive compounds 
• Multi-nitrated compounds 
• Azides

Remote Container Opening Procedures 

Our Reactive Material specialists take every precaution and limit the handling of hazardous and potentially unstable materials. We use specially designed equipment for all reactive remediation and stabilization projects, including pneumatically driven machinery that can remotely open a container.

Engineering Controls and Personal Protective Equipment 

Our state-of-the-art engineering controls include devices such as:

• Trailer-mounted blast deflection units
• Portable remote openers with bomb blanket and safety circle
• Custom-designed remote drum openers
• ATF Type III Blasters day boxes

Our personal protective equipment protects our employees from high heat, flames and explosions and includes:

• Fire proximity suits
• Explosive Ordinance Disposal (EOD) protective search suits
• Riot helmet, Kevlar® vest, and Nomex® coveralls (standard issue)

Unknown Compound Fingerprint Analysis

Our CleanPack® chemists provide fingerprint analysis for unknown compounds within lab pack-sized containers provided that the materials pass our safety evaluation. If these materials fail the evaluation and are suspected to be shock-sensitive, unstable or reactive, they must be remotely opened and tested before packaging.

Clean Harbors provides safe, cost-effective Cylinder and Compressed Gas Management and disposal. 

Clean Harbors highly trained specialists―who meet rigid personnel qualifications―handle all types of cylinder projects from the removal of a single lecture bottle to large-scale, multi-phase cylinder remediation efforts. We manage a wide range of liquefied, non-liquefied and dissolved gases, including hydrogen cyanide, anhydrous hydrogen cyanide (HCN), tetrafluorohydrazine (TFH), pentaborane and incompatible mixtures. And we have the unique ability to design and manufacture custom compressed gas cylinder equipment to meet your needs.

Download Cylinder and Compressed Gas Management Services Brochure 

Specialized Equipment and Expertise 

Using state-of-the-art personal protective, project and safety equipment, our experts evaluate your situation and safely package and remove cylinders from your site. When materials are potentially unsafe to ship, Clean Harbors will mobilize a team of cylinder specialists to your location where they can:

• Contain leaking or damaged cylinders
• Test and identify unknown materials 
• Manage both portable and fixed tanks
• Handle inherently unstable and high-hazard cylinders

Safety Training 

All of our specialists undergo Compressed Gas Emergency Response Training (CGERT) certification, a rigorous technical course that provides advanced training on industrial and specialty gas emergency response. 

Clean Harbors CustomPack Self-Pack Program offers a cost-saving, do-it-yourself alternative to customers who want to pack their own waste chemicals. 

With Clean Harbors CustomPack Self-Pack Program, you can package facility waste material yourself using either a standard set of guidelines or custom guidelines tailored to the waste streams you normally generate.

CustomPack Program Support 

Even though you’re packing the chemical waste yourself, you’re not alone in the process. Every CustomPack user has a dedicated program manager to provide technical support. You also receive all necessary materials and paperwork to ensure safe, compliant chemical packing and transportation. 

Online Services 

CustomPack users can also take advantage of Clean Harbors complimentary Online Services—web-based tools that help our customers manage their Environmental Health and Safety (EH&S) programs more efficiently. With our Online Services, you can:

• Create, view, edit or print waste profiles
• Track manifests
• Generate reports
• View invoices
• Track waste inventory
• Schedule a drum pickup 

Download Fact Sheet (CustomPack Program)

Clean Harbors experienced teams make your lab move easy, safe, efficient and compliant with all relevant regulations. 

Moving your laboratory is a challenging, high-risk endeavor that requires precision, experience and utmost care. Clean Harbors highly trained staff takes care of all your chemical packing and moving needs with our: 

• Wide range of chemical packaging expertise 
• Flexible volume capabilities from small vials to 55-gallon drums or bulk storage tanks 
• Ability to handle one lab or an entire research building
• Use of our own fleet to transport your lab chemicals 
• Identification and removal of potential decontamination areas

Turnkey Packing, Transportation and Delivery

Clean Harbors provides all chemical packaging materials and supplies needed for the lab move, such as drums, coolers, absorbents, dry ice, etc. Chemicals are packaged in DOT- or TDG-approved containers and maintained at appropriate temperatures. We also manage the disposal of unwanted chemicals such as peroxidized ethers, or previously used chemical packaging like corroded cylinders—items that are no longer needed or are not suitable for shipment. We will identify and provide the most sound, cost-efficient disposal option for your laboratory waste.

Download Fact Sheet (Laboratory Move Services)

Clean Harbors provides secure transportation and destruction of all types of DEA controlled substances including off-spec, out-of-date and returned products.

Transporting DEA controlled substances with Clean Harbors could not be simpler. Our personnel complete the required transfer paperwork, and our Company-owned trucks deliver the substances to our facilities for disposal. Afterward, we provide a Certificate of Destruction certifying the proper disposal of each controlled substance shipment. We also provide the following security provisions:

• Shipment tracking
• On-site vaulting at our Aragonite, Utah, facility
• Witness destruction

DEA-Approved Reverse Distributor

Clean Harbors is the only RCRA Incinerator in North America that is also approved as a DEA Reverse Distributor. As such, Clean Harbors assumes full chain-of-custody ownership of Schedule I-V controlled substances from the pickup at the customer’s site to transportation and complete destruction. Our experts ensure:

• Product security
• Documentation and reporting to required federal agencies
• Accurate segregation of hazardous and non-hazardous drugs 
• Material ownership continuity 

Clean Harbors DEA Registration Number:  RC0331049

Clean Harbors is uniquely positioned to offer safe disposal of Naturally Occurring Radioactive Material (NORM) and Technologically Enhanced Naturally Occurring Radioactive Material (TENORM), in addition to other commonly occurring radioactive materials. Our extensive rail-car and truck networks provide unmatched disposal options. 

Radioactive Material Handling Capabilities 

Clean Harbors Radioactive and Disposal services utilize a network of approved, certified radioactive waste disposal outlets to ensure that our customers are in full compliance with DOT regulations as well as state, local and NRC regulations. 

We adhere to strict safety protocols and customer liability reduction while managing the following radioactive materials:

• • Uranium and thorium compounds (acetate, nitrate)
  • Smoke detectors
  • Biological specimens
  • Exit signs
  • Radioactive sources
  • Scintillation fluid
  • Electronic equipment containing radioactive sources
  • Mixed waste
  • Radioactive standards and solutions
  • Radioactive scintillation vials
  • NORM  
  • TENORM

NORM and TENORM Disposal

Clean Harbors also provides disposal for Naturally Occurring Radioactive Material (NORM) and Technologically Enhanced Naturally Occurring Radioactive Material (TENORM) waste and containing radionuclides (in the decay series of U-238, U-235 and Th-232) up to 2000 pCi/gram.

Download Fact Sheet (NORM and TENORM Waste Disposal Services)