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Question of the Week: DOT Rules for Reusing Drums for Shipping Hazardous Waste

Posted on 7/19/2011 by James Griffin

Q. As a small manufacturer, we buy lots of chemicals each month to use as solvents, purifiers, or catalysts. When we’re done, we ship the used chemicals back to the supplier for recycling and, in many cases, eventual reuse.
 
Most of the time, when we return-ship this hazardous waste, we refill the waste material into the same drums in which we received the chemicals. Since we don’t have to buy or store new drums for the outgoing shipment or dispose of the now empty drums we receive, we save a lot of time and money.
 
Knowing that the U.S. Department of Transportation has rules for safely reusing hazmat packages, what regulations let us reuse drums for shipping hazardous waste?
 
A. Normally, when you want to reuse a packaging for hazmat, you must follow steps to make sure that the package is basically “as good as new.” Among other things, this requires you to inspect the package before reuse for any reduction in integrity, such as:
 
  • Incompatible residues, or
  • Any ruptures or other damage.
  • For drums, the outer layer must meet minimum thickness requirements.
 
If the drum does not pass inspection, you must recondition and apply a new specification marking to it before reuse.
 
Additionally, for a non-bulk package intended for liquid, the shipper must perform a leakproofness test. [49 CFR 173.28] Needless to say, not all facilities have access to pressure-testing equipment, or are equipped and certified to recondition drums. Since reusing drums for hazardous waste shipments is a common practice, the DOT provided an alternative set of rules for reusing packages to ship waste materials.
 
In order to qualify for this relief, you must follow 5 steps as proscribed by 49 CFR 173.12(c):
 
  1. Must still be an authorized packaging under 49 CFR 173 packing regulations
  2. Transport by Highway only
  3. Must be inspected for leaks prior to transport, 24 hrs. after it has been filled and closed
  4. Must be loaded, unloaded, and transported by shipper, consignee, private, or contract carrier.
  5. The package may only be transported using this relief once
In short, you get a one-time relief from leak-testing to ship your used material back out as a waste material; if the hazards of the material have not changed, you let it sit for 24 hours after filling, and then you transport it only by truck, using an appropriate carrier.
 
Note: The Federal EPA rules on reuse of packages are less stringent than the DOT rules for shipping purposes. However, you may want to check with your state and local EPA inspector to see if there are additional reuse rules unique to your area.
 

Tags: DOT, hazardous waste, hazmat shipping

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