Life-sciences labs: empty IBC totes

Records are the asset

A regulated laboratory knows what it put in a tote, in what batch and when. That record turns a used tote into a graded one. A tote that held a reagent and has a clean record can sometimes be reconditioned for the same reagent. One with an unknown history is recycled, however clean it looks.

Maryland Commerce reports MilliporeSigma investing $286 million and moving into a new 250,000 square foot space at the Traville Gateway campus in Rockville. A move of that size brings construction empties and, later, process empties.

Gaithersburg, Rockville, Germantown

The cities on the corridor have their own pages: Rockville for biotech manufacturing and biosafety testing, Gaithersburg for the biggest employers, and Germantown for reagents and diagnostics.

What to send

1. The SDS for the last product.
2. The tote size and count.
3. The heel from the Empty Check.
4. A note on whether the product is classed as acute.

A laboratory in Maryland also has to read its generator category from MDE, because the state does not use the federal very-small-quantity category.

Not every lab tote is a candidate

A tote that held an acute hazardous waste needs a triple rinse, and a rinsed tote is not food or pharma grade unless its history is documented. Lab totes that fail either test go to a licensed hauler or to recycling.

Buffers, media and cleaning solutions

A biologics plant makes products in solutions that must be exact. Buffers hold the pH. Media feed the cells. Cleaning solutions sanitize the equipment. All are bought in volume, and the larger volumes come in totes.

The classes are patterns, not rulings. The SDS for the actual product decides.

Batch records help

A plant that operates under a quality system already keeps batch records. A tote that is traceable to a batch is traceable to a product, and a traceable product is a graded tote. That is one reason lab empties can reach the higher grades more often than ordinary industrial ones.

Chemical or biological waste

Totes that touched biological material have an extra consideration: the facility’s own biosafety rules. We take no totes that are not empty and we do not decide what a lab’s biological waste is. The facility’s EHS office does.