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Air Indoor Resources - Hazardous Waste Management

Appropriate Container

A hazardous waste container is considered a portable device used to store, transport, treat, dispose, or otherwise handle waste (40 CFR Part 260.10). The container used depends on the type of waste you plan to place in the container. The container definition is broad to encompass all different types of containers used to handle hazardous waste. EPA Training Modules, Introduction to Containers (PDF) 40 CFR Parts 264/265, Subpart I: 261.7, outlines container compliance per the hazardous waste rules.

The containers must be in good condition; compatible with waste stored within; closed, unless adding or removing contents; not leaking; and labeled “Hazardous Waste.” It is required to routinely inspect drums and containers for rust, defects, and leaks. The web site Material and Chemical Compatibility is a database that allows you to determine compatibility for certain materials and chemicals.

The most common Department of Transportation (DOT) container used to store hazardous waste is a metal (or plastic) 55-gallon drum with either a closed-top, bunged drum (DOT 17E) for liquids; or open top, ringed drum (DOT 17H) for solids, but are now respectively known as “1A1" and "1A2" drums. The new drums are now constructed of lighter gauge steel, but have more secure joining of individual parts of the drum.

Other common container types include: tanker trucks, railroad cars, various sized polyethylene plastic or metal drums, pails, fiber drums, and even test tubes. The container must be sturdy, leakproof, and meet DOT specifications for materials and construction. Additionally, these containers must be made of, or lined with, nonreactive materials for the type of waste you plan to store.

The technical definition of “RCRA empty container” is a container that previously held non-acute hazardous waste and:

  • All wastes are removed using practices commonly employed industry-wide;
  • Less than one inch of residue remains in container or liner;
  • Less than three percent by weight remains in a container with a capacity of 119 gallons or less; and
  • Less than 0.3 percent by weight remains in a container with a capacity of over 119 gallons.

Empty Container Certification is a written document executed by the empty container custodians and/or 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. A certificate must be signed every time a container is picked up.

Shipment preparation for empty containers requires the labels to be in situ, especially the precautionary information, which is required by DOT regulation (49 CFR 173.29) for any container formerly containing hazardous materials. These labels are needed to communicate to all custodians of empty containers important safety information until the containers are cleaned by reconditioners or processors for scrap recycling. Labels should never be removed or painted over unless the drums have been cleaned and purged at the reconditioner’s plant. All openings including removable heads 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.

See DEP’s Small Quantity Generator’s Container Storage Checklist (Word)

Contact Information

Wendy Murphy
325 West Gaines Street
Suite, 1054
Tallahassee, FL 32399
Phone: (850) 245-9295