Introduction

Disposition of used steel drums was once a simple matter: usually one phone call, and the drums were gone – with no problems. Today, however, strict new standards of environmental responsibility and transportation safety make empty drum management a more precise activity. Those responsible for used container disposition now have several responsibilities – none very difficult, but all very important.

Proper Emptying

Proper emptying of every drum is the most important aspect of in-plant responsible container management. It affects costs, regulatory compliance, and legal liability. Costs – The avoidable residues of costly materials left in drums can represent enormous lost profits. This is virgin product that has been paid for, but discarded unused. Regulatory Compliance – For most products, only drums meeting the EPA “empty” definition (40 CFR 261.7) escape classification as hazardous wastes. Used drums which are hazardous wastes face staggering costs of legal disposal – far more than through proper management when “empty” by drum reconditioners and dealers. Legal Liability – Persons arranging for disposition of non-empty drums may be considered to have “arranged for disposal or treatment… of hazardous substances,” or to have engaged in the “abandonment or discard” of unclean containers. Both of these terms are from the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42 USC 9601), “Superfund”, and both activities establish strict, retroactive, joint-and-several liability for any subsequent contamination and environmental response costs. Emptying personnel should know the details of the EPA definition of an empty container. Especially important is understanding the nickname “one-inch rule” applies only in the very limited number of cases involving non-flowable products. Since most drums contain flowable products, ACR prefers the term “drip-dry,” indicating that all materials that can be removed (using normal methods – such as pouring) have been removed.

Label Maintenance

Retaining labels – especially the precautionary information – is required by regulation for any drum formerly containing hazardous materials (49 CFR 173.29). These labels are needed to communicate to all custodians of empty containers important safety information until the containers are cleaned by reconditioning or processing for scrap recycling. Labels should never be removed or painted over unless the drums have been cleaned and purged at the emptier’s plant.

Control Procedures

Empty drums should not be fully or partially refilled with products different from the original lading. When emptied, such drums then contain a residue that is no longer accurately described by the label. Shipment of such a drum – even to a drum reconditioner – may violate DOT regulations and exposes plant workers to unforeseen hazards. All drums should be accounted for; empty drums should be kept in a secure area. All drums should be sent to a qualified reconditioner or dealer; the liability exposure of giving drums away to the community or employees exceeds the goodwill benefit. See 40 CFR 261.7 Residues of Hazardous Waste Preparation for Shipment Plugs must be reinserted and tightened in closed head drums. Covers and locking rings must be refastened to open head drums.

Selection of a Qualified Reconditioner

The drum reconditioning industry has the equipment and technical competence to complete the cycle of Responsible Container Management: Reconditioning of drums for reuse or processing for steel scrap recycling. Like all providers of industrial services, however, drum reconditioners and dealers should be evaluated by drum emptiers as carefully as any major supplier of a key raw material. A plant visit is recommended. To assist drum emptiers in such inspections, see the ACR Responsible Container Management pamphlet: Environmental Compliance – Suggested Plant Review Guide for Drum Emptiers.

Summary

Drum emptiers have a variety of tasks to ensure the proper disposition of used, empty containers. All of these responsibilities, however, are just “good operating practice” in this day of heightened environmental standards. When they are put into place, drum emptiers can continue to enjoy the benefits of the low cost, safe, versatile steel drum while fully confident of total environmental compliance.