If someone were to ask you to picture an empty container, chances are you’d probably think of a barrel, bottle, or box with nothing in it. And, in most cases, that would be an accurate depiction of an empty container. But if you work in a facility that handles hazardous materials and waste, you should know that this mental picture is no longer sufficient to define a container as empty. In this context, the word “empty” has a very specialized definition per EPA rules, and not understanding this definition can have significant consequences for your facility.
Empty vs. RCRA-Empty
While a simply empty container may conform to your mental picture, the RCRA has a different view which constitutes emptiness. Understanding this difference is critical because any containers which have held hazardous materials are subject to EPA regulations, even if they no longer hold those hazardous materials, until they can be defined as RCRA-empty. Once that container can be defined empty as per RCRA rules, it is no longer subject to regulation even if some residue remains in it.
Non-Acute Hazardous Waste
There are two different sets of criteria that determine whether a hazardous container is empty. The first set is for containers which had previously held non-acute hazardous waste (any waste that does not pose a threat to human health or the environment, yet is still hazardous in some way). In order for one of these containers to qualify as empty, all wastes that can be removed from the container using “commonly employed practices” have been, and
- Residue remains on the bottom of the container does not exceed 2.5 centimeters, or
- If the container is equal to or less than 110 gallons in capacity, no more than 3% of total capacity by weight remains, or
- If the container exceeds 110 gallons in capacity, no more than 0.3% of total capacity by weight remains.
Acute Hazardous Waste
For containers that had held acute hazardous waste (waste that poses a threat to human health and the environment even when properly managed), there are three methods that can make them considered empty in the eyes of the RCRA. Either:
- The container has been triple rinsed with a solvent that is capable of removing the waste, or
- Cleaned through another method that has been demonstrated in scientific literature or tests done by the waste generator to achieve an equivalent removal, or
- The inner liner preventing contact between the waste and the container has been removed.
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