While many consider the pick-up and return of empty chemical packages (pails/drums/totes) as a service provided by their supplier, the Department of Transportation (USDOT) has specific regulations that must be followed for “empty” containers to be transported. Both hazardous and non-hazardous product container returns need to be handled in specific ways to ensure compliance with USDOT requirements. Although there are some differences for shipping empty hazardous and non-hazardous material containers, it is best to follow the same procedures for both classifications of products to ensure compliance.
“Empty packages” are defined in the Federal Register under section 49 CFR 173.29. Only residues may remain in the container to be offered for returns, and the containers must be handled under the same manner as when the package was full. “Residues” are defined under 49 CFR 171.8 and require that the product has been unloaded to the maximum extent practicable and free of any hazardous vapors. In addition, ALL containers must have all closures in place (caps, bungs, gaskets, etc.) before they can be accepted for returns. A summary of these requirements is as follows:
- All waste must be removed by pouring, pumping, or by means of suction: and
- No more than one inch (1”) or 2.5 centimeters of residual remain in the container or container inner liner: or
- No more than three percent (3%) by weight of the total capacity of the container remains in the container or inner liner if the container weight is less than or equal to 119 gallons in size: or
- No more than 0.3 percent (0.3%) by weight of the total capacity remains in the container or inner liner if the container is greater than 119 gallons in size.
NOTE: The empty by weight standards are often used when there is a mixture of solid and liquid waste in the container. Also, some thick viscous products may continue to settle to the bottom over time due to the nature of the product. A < 1” measurement today may in fact be greater over time.
It is also the responsibility of the end use customer to initiate the return process, as any company returning a chemical container is defined as a “shipper” by USDOT. Whether the empty package is returned by the supplier’s own vehicle or a common carrier, it is the shipper who is ultimately legally responsible for the empty packaging to meet the USDOT regulations.
Coyne maintains a staff of Regulatory Specialists who can assist you should you have any questions regarding this process. Please feel free to contact your Coyne Environmental Applications Specialist to arrange a call or call 1-800-523-1230 and ask for someone in Safety and Regulatory Affairs.
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