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BMPs for Reusing Your 55-Gallon Drums

Hazardous Waste Management
by Kelly Lagana
"Since many 55-gallon drums may contain, or may have contained, hazardous materials that could contaminate groundwater or lead to personnel health and safety concerns, it is imperative that operators of solid waste facilities be informed about the best management practices for collecting and processing these drums."

Drums not properly managed can lead to expensive liabilities for communities or businesses, such as testing, removal, and disposal, as well as contaminated soil and groundwater that will also have to be disposed of properly or treated. For example, open drums that contain a residual product and that are allowed to collect rainwater – may overflow, leading to their contents being tested and handled as a hazardous waste.

Collection of Drums

Drums collected for reuse or recycling should arrive at the facility empty. Not “empty” in the sense that it appears to be empty, but “legally empty” – empty in accordance with the RCRA empty container standards at 40 CFR 261.7. This “RCRA empty” standard means that all wastes have been removed from the drum by the generator using common practices such as pouring, pumping, and aspirating for liquids (no free liquid can remain). For closed head drums with contents that cannot be poured, there can be no more than 1 inch of residue in the drum, or no more than 3 percent of net weight stuck to the bottom, top, and sides.

Collection and reuse of drums that have contained acutely hazardous materials, like pesticides or cyanides, is discouraged as the drums will contain residues of prior materials unless they are "triple rinsed." In addition, the residue on the bottom of one drum should not be added to the residue of another drum as this may lead to the mixing of incompatible materials or the accumulation of a hazardous waste mixture.

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Drums Being Used or Collected for Reuse

Address the following if your drums are being used or are destined to be reused by solid waste facilities:

  • Drums should be empty, with no residual materials inside, on the top or outside.
  • Drums should be structurally sound, without big dents or rust.
  • Drums should be located in areas clearly visible to prevent damage from motor vehicles.
  • Open head drums should be covered with lids sealed by heavy-duty, bolt clamps, snap rings, or bungs.
  • Drums should be placed off the ground on an impermeable surface in a covered containment area to prevent corrosion and discharges to groundwater.
  • Drums should be stored away from the eaves of a roof and any heat sources.
  • Drums should be located away from wetlands, surface water, wells, property lines, flood zones, and drainage areas.
  • Drums should not be covered with other materials where they may become forgotten, knocked over, or develop unseen leaks.
  • Drums being used should be labeled and face outward so as to be easily read, and accessible year-round in case of fire, removal or spills.
  • Drums should be regularly inspected for structural integrity, e.g., rust, cracks, or leaks.

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Drums for Scrap Metal Recycling

Drums collected for recycling as scrap metal should meet the following criteria:

  • Empty drums should have the top and bottom removed by the generator before being accepted by the facility to prevent the accumulation of rainwater. A torch should not be used to remove the top or bottom of a drum as the drum may contain a flammable gas and could explode. Mechanical openers are commercially available and that should be used to accomplish this task.
  • Drums should be clean.
  • Drums should be flattened to save space.

Many communities that collect used oil for recycling, use drums to collect and store the used oil and/or used oil filters. Drums containing used oil must be labeled "Used Oil for Recycle," and drums containing used oil filters should be labeled “Used Oil Filters.”

The Bottom Line

All drums should be managed to prevent contamination. Keep your drums sealed, easily accessible,  and labeled, and frequently inspect them for possible leaks or spills.

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