But that doesn’t mean complying with RCRA container management regulations doesn’t come with their own set of headaches. Here are 11 expert container compliance tips to help you out.
#1 Ensure containers are sturdy and strong enough to withstand side or bottom shock, when full, without leaking waste. Rust, other corrosion, or dents in seam areas indicate a container may not be strong enough to use.
#2 Ensure that a full container will not release waste even when dropped or overturned. To meet this requirement, any containers that hold free liquid must be liquid-tight, even when overturned.
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#3 Is the container lid easily closable for employees? The additional cost of spring-loaded snap rings, funnels with valves, or similar equipment may be a cost-effective means of ensuring containers are closed.
#4 To prevent waste spills from destroying a label, place the label on the side of the container, but not directly under the bung. To protect labels, cover them with clear packing tape or a clear finish or enclose them in a plastic pouch designed for that purpose.
#5 For quick identification, put all marks and labels on the same side of the container (but not under the bung).
# 6 Before shipping, check to make sure containers and labels meet DOT requirements for that waste.
#7 Hang your container inspection log on a clipboard in the storage area. When it is full, file it in your permanent records for at least 3 years.
#8 When storing an empty container outside, place it on its side to prevent accumulation of rainwater and melting snow.
#9 Snow can fill curbed outdoor storage areas; remove it when sidewalks are shoveled.
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#10 A rule of thumb to differentiate satellite accumulation containers from storage containers: Satellite accumulation containers will generally be either emptied into another container or moved to a storage area when full, while storage containers will generally be shipped off-site as is when full.
#11 You may choose to place a date on a satellite accumulation container when you begin to use it to help you track how quickly the waste is generated. If you do, clearly identify the container as a satellite accumulation container to avoid confusing it with a storage container.
Note: These tips are from Fact Sheet No. 1.04/1.05, Label and Store Hazardous Wastes prepared by the Minnesota Pollution Control Agency (MPCA). This fact sheet summarizes the Minnesota hazardous waste container rules for generators found in Minnesota Rules 7045.0270 and 7045.0292. However, because the Minnesota regulations closely follow the federal rules, with some more stringent requirements, the compliance tips should apply to most persons using a container to store or accumulate hazardous waste. Although the tips reflect the requirements of many states, they can also stand on their own as good business practices.
See tomorrow’s Advisor to find out what NOT to do when managing containers. We’ll have a compilation of the most common container violations found by EPA inspectors.