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April, 2008

RCRA Empty Drums

Q. Can automobile recyclers except RCRA empty drums for recycling? If they can, how would they handle the residual of hazardous waste that is generated from the accumulation of small quantities of waste in each drum during shredding or crushing?

A. EPA and the container reuse/recycling industry believes that if the residue left in a drum is one inch or less that it is not hazardous. See the following text at

http://www.reusablepackaging.org/Docs/Recycling%20Commments%20to%20EPA.doc

In promulgating the definition of “empty” container (Nov. 25, 1980), EPA stated in the rule’s preamble that “the small amount of hazardous waste residue that remains in individual empty, unrinsed containers does not pose a substantial hazard to human health or the environment.” (45 Fed. Reg. 78525)