Empty Container Preparation
Proper Container Emptying
- Proper Emptying
- Empty Definition
- Empty Drum Certification
- Shipment Preparation
Proper emptying of every container is the most important aspect of in-plant Responsible Container
Management. It affects cost, regulatory compliance, and legal liability.
Cost - The residue of costly material left in containers can represent enormous lost profits to companies.
This is virgin product that has been paid for, but is discarded, unused, if left in a container. Emptiers
should remove as much product as possible every time.
Regulatory Compliance - For most products only containers meeting the EPA "empty" definition (40 CFR
261.7) escape classification as hazardous wastes. Used containers which are hazardous waste face
staggering costs of legal disposal - far more than through disposition when empty to container
reconditioners and dealers.
Legal Liability - Persons arranging for disposition of non-empty containers 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), or "Superfund" and both activities
establish strict, retroactive, joint-and-several liability for any subsequent contamination and environmental
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 nonflowable products, RIPA prefers the term "drip-dry," indicating that all materials that can be
removed (using normal methods - like pouring) have been removed.
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The definition of "empty" can be found in 40 CFR 261.7 and requires:
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- All wastes have been removed that can be removed using the practices commonly
employed to remove materials from that type of container, e.g., pouring, pumping, and
- No more than 2.5 centimeters (1 inch) of residue remain on the bottom of the
container or inner liner, or
- No more than 3 percent by weight of the total capacity of the container remains in
the container or inner liner if the container is less than or equal to 110 gallons in size.
- No more than 0.3 percent by weight of the total capacity of the container remains in
the container or inner liner if the container is greater than 110 gallons in size.
Empty Drum Certification
Empty Container Certification is a written document, executed by the container emptier
and the container reconditioner or dealer. It confirms that the containers being
transferred are actually empty, in accordance with the EPA definition of empty
containers, and that they have been properly prepared for transportation. Some
companies execute the certification on a contractual basis, but most reconditioners print
the certification on their receiving tickets so that one is signed every time containers are
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Retaining labels - especially the precautionary information - is required by regulation for
any container 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 emptiers plant. All openings including removable heads,
filling and vent holes must be tightly closed prior to shipment. Closed head drums must
have all plugs reinserted and tightened, and open head drums must have the covers and
locking rings refastened.
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