Can rinsed out drums be reused for different wastes?

By: Lisa Neuberger

Publication: Environmental Regulatory Alert

Date Posted: 01/06/2021

Reused Hazardous Waste Drums Q&A

Question: Can rinsed out drums be reused for different wastes?

Answer: If your containers have been emptied according to the regulation at 40 CFR 261.7, then they are considered to be “RCRA Empty,” meaning they are no longer regulated as containing hazardous waste. However, even “RCRA Empty” containers can have some residue left in them that could possibly react with other wastes. Therefore, you need to use common sense when adding new wastes to the containers and not add materials that you know are incompatible with what had been in the container.

In addition, make sure the drum itself is compatible with the waste you’re adding. The regulations for small and large quantity generators tell you, “The small quantity generator must use a container made of or lined with materials that will not react with, and are otherwise compatible with, the hazardous waste to be accumulated, so that the ability of the container to contain the waste is not impaired.”

About the author
Lisa Neuberger - EH&S Editor

Lisa joined J. J. Keller & Associates, Inc. in 2008. She serves as a resource for customers on environmental, health, and safety topics, and has a passion for the safe management of hazardous waste. She specializes in OSHA’s workplace injury and illness recordkeeping and reporting, flammable liquids, and sanitation standards and in EPA’s solid and hazardous waste regulations.

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