need a special license. In many cases, vehicles must be placarded. Generators depend on waste dispsosal firms and transportation services for compliance with these rules. Many transportation firms also provide waste characterization and preparation, disposal site selection, and disposal approval services. Transport services can be contracted directly by a generator or through a broker.

Waste disposal firms also include companies that operate permitted treatment facilities, disposal sites, and recycling/reclamation facilities. The appropriate TSDF should be selected by the generator, although often this decision is heavily influenced by the waste disposal firm, which usually has ties to selected TSDFs or will make recommendations. The generator should always be involved in this decision, because it can affect long-term liability as well as short-term cost.

8.B.7.1 Preparation for Off-Site Treatment or Disposal of Waste

Transportation and packaging requirements dictate how waste is prepared for shipment to a transfer, treatment, or disposal facility. Laboratory waste is often placed into DOT-compliant 1- to 55-gal overpacks. Reactives, gases, and highly incompatible and some highly toxic chemicals must be packaged separately.

Using labpacks is quite simple. As described above, small containers of compatible waste materials are placed in a larger container, usually a 30- to 55-gal drum, along with appropriate packing materials, as they are collected. When a drum is filled and ready for shipping, an inventory list of the contents of the labpack is prepared.

For certain similar and compatible liquid wastes, however, collecting containers of waste in a labpack is usually much more expensive than commingling (i.e., mixing) the wastes, partly because a 55-gal lab-pack only holds about 16 gal of waste in its individual containers. Most often, nonhalogenated solvents are ideally suited for commingling in bulk, because the best disposal strategies for flammable liquids are fuel blending or recycling. Commingling requires opening of containers and transferring their contents from the smaller laboratory containers to a larger drum. Furthermore, the containers should be rinsed before they are considered nonhazardous, and the rinsate must be treated as a hazardous waste.

Safety precautions and facility requirements for commingling are described above. See section 8.B.3.4, above, for information on rinsing and disposal of empty containers. Drums of commingled waste usually require an analysis or listing of their contents.

Commingling does not make sense if safe facilities are not available, or when insufficient amounts of compatible waste are generated within storage time limits.

8.B.7.2 Choice of Transporter and Disposal Facility

Because the long-term liability for the waste remains with the generator, it is imperative that the generator be thoroughly familiar with the experience and record of the transporter and TSDF. Economic factors alone should not govern choices, because the long-term consequences can be significant. The generator must obtain assurance, in terms of documentation, permits, records, insurance and liability coverage, and regulatory compliance history, that the chosen service provider is reliable.

There is often an advantage, particularly for smaller facilities, to contracting for all of the hazardous waste disposal operations. These include the packing and appropriate labeling of waste for off-site transportation and disposal, preparation of the shipping manifest, and arranging for the transporter and disposal facility. Again, the liability remains with the generator, and so the choice of such a waste disposal firm is critical.

In some states, Minnesota and Montana, for example, arrangements have been developed with local regulators to allow a large laboratory waste generator to handle the waste from very small laboratories such as those at small colleges and public schools. This plan results in informed assistance and cost savings for the smaller units. In Wisconsin, a statewide commercial contract that can be accessed by all state educational systems has been arranged. There is usually significant advantage to working with local and state agencies to develop acceptable plans for disposal methods that are environmentally and economically favorable for both large and small generators.

8.B.8 Liability Concerns

Generators are liable for proper disposal regardless of who is involved once waste leaves the facility. Long-term liability usually refers to Superfund liability. Superfund, the federal environmental policy initiative officially known as the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), provides EPA with broad authority to initiate the cleanup of hazardous waste sites. Originally funded primarily by taxes on chemicals and petroleum, the trust fund was fully depleted in 2003. All cleanups are now paid for by organizations found by EPA to have contributed to the contamination. Referred to as PRPs (potentially responsible parties), these organizations include four classes of parties:

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