Drum Disposal and Transportation Requirements for Hazardous Waste Removal

The 55-gallon drums endemic to hazardous waste disposal must meet strict government standards for eco-friendliness. This includes their end-of-life disposal or recycling; and mistakes concerning these types of drums are one of the most common reasons for EPA citations and fines.

Expert advice is recommended. But if you’re in the mood for adventure, then you’ll want to check out Handling Drums and Other Containers, a 37-page tour-de-force on the subject that the EPA confuses with “guidance.”

Transporting drums for disposing of hazardous waste: lighter is cheaper

Drums for hazmat or chemical disposal might be made of steel or polyethylene. (Sometimes fiberboard, but that’s way rare.)

• Steel drums are best where durability and strength are paramount. They can handle more weight than poly drums, and better withstand any blunt force (e.g. collisions), and are inherently fireproof. This durability decreases risk so that your insurance bill for drum transportation can be less ugly—although no beauty queen. Steel drums are easier to reuse than poly, making them a better long-term value. But they have a weight problem, and excess avoirdupois renders them expensive to ship.

• Polyethylene drums or, to a layman, plastic drums can cost half as much as steel ones. Being about half the weight, they can also save you big bucks on shipping costs when disposing of hazardous waste. They’re particularly indicated for materials capable of corroding metal, and many do, including plain old H20, wherein the “O” part promotes oxidation, which is just a fancy name for rust. Also, water typically has traces of chlorine, a chemical that often doesn’t play well with others—particularly metals. (N.B. Where steel-like durability and anticorrosive properties are called for, look for steel drums lined with polyethylene.)

DOT requirements for hazardous waste removal

Trucking your hazmat material offsite to where it needs to go are wrought with regulatory peril. Especially since neither the EPA nor DOT specify a format for labeling chemical hazardous-waste containers. Instead, each requires specific information to be prominently displayed.

We’ve blogged previously about specific EPA requirements for onsite hazmat storage here. As to DOT requirements, the container must be clearly labeled as hazmat, and display this notice: HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority, or the U.S. Environmental Protection Agency.

Additionally, the container must clearly show your company’s name. Labeling must be durable, clearly visible, and in English (in case you were planning on French). It must be displayed on a contrasting color background and not be obscured by other labels, attachments, or advertising.

Labels must always be diamond-shaped, and their size must adhere to international standards, measuring at least 4″ x 4″ (100 mm) on each side, square-on-point.

The DOT uses nine categorical Hazmat placards or labels:

• Compressed gas
• Flammable & combustible liquid
• Flammable & reactive solids
• Oxidizers & organic peroxides
• Poisonous materials & infectious substances
• Radioactive materials
• Corrosives
• Miscellaneous

Hazmat Drum Disposal

Once emptied & cleaned to RCRA standards (known as “RCRA empty” to EPA hipsters), hazardous waste drum disposal can be the same as non-hazardous drums (i.e. more cheaply).

But this isn’t something you can achieve with a bucket, garden hose, and some Dawn®. When it comes to hazardous materials disposal, what appears empty & clean to you might not be considered so by the EPA. So the drums might themselves be subject to hazardous waste regulation, and inadvertently mishandling them can run you afoul of the law, even after you’ve worked hard to comply with all mandates for the hazmat itself.

In their inimitable and helpful way, the EPA prescribes three different “emptiness” standards that are necessary and sufficient for your drums to be RCRA empty and thereby eligible for declassification as hazmat:

Standard 1. Hazardous waste

Under this standard, a hazardous waste container (or its inner liner) is considered RCRA empty after all possible waste has been removed from it by pouring, pumping, or suction so that no more than one inch of residue remains. This is prosaically referred to as the one-inch rule. But wait—there’s more:

• For containers (or inner liners) up to and including 119 gallons capacity, applicable rules and regulations for hazardous material disposal still apply if what’s left represents more than three percent of the hazmat by weight.
• For containers (or inner liners) greater than 119 gallons capacity, applicable rules for hazardous material disposal still apply if what’s left represents more than three-tenths (0.3) of a percent of the hazmat by weight.

These RCRA standards are also typically applicable where the residual hazardous waste is a mixture of both solid and liquid waste.

Standard 2. Acute hazardous waste

Hazardous waste is called “acute” when it’s determined that even a small amount of exposure to it might severely affect human health, like being in the same room with a Kardashian.

Thereby, RCRA standards are more stringent. In effect, there can be no residue. Containers (or inner liners) that have contained acute toxic waste must be triple-rinsed with an appropriate solvent—or cleaned by another method that has been proven the equivalent of a triple-rinse.

But be advised: Specific federal guidance is conspicuously lacking about what constitutes a triple-rinse. Individual states and jurisdictions might have their own rules. As we’re fond of saying, you should get expert advice.

Standard 3. Compressed gas hazardous waste

Rules for residual compressed gas hazmat are less complicated. A container holding compressed gas is RCRA empty at the point where the pressure inside the container is equal to atmospheric pressure in practical terms. This, of course, requires opening the container—so that applicable rules, regulations, and common-sense precautions specific to the particular gaseous hazmat must be observed.

Managing residues

Hazardous wastes and or residue remaining in a container (or inner liner) deemed RCRA empty are exempt from EPA hazardous waste disposal rules. But you must determine whether removing the original waste (or its subsequent management) doesn’t produce hazardous waste. An example might be the residual mixture of waste and cleaning solvent (aka rinsate) left from a triple-wash regimen. Expert advice, anyone?

The upshot

Hazardous waste drum transportation is fraught with legal requirements that must be considered before the first barrel is placed on a flatbed and sent offsite. Ignorance of the law is not an excuse, and mistakes might be construed as criminal intent.

And at the end of a drums life expectancy, you can avoid the time and expense of handling drums as hazardous materials if you can make them RCRA empty, allowing you to pursue other recycling or reconditioning options. But as with all EPA regulations, caveats abound, and at the risk of redundancy: it’s important to get expert advice.

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