Environmental policies on accepting drums

Queen City Barrel, Cincinnati
[owner of Columbus Steel Drum]

Current environmental laws and regulations govern the practices followed in the disposition of used, empty steel or plastic drums. Under the Resource Conservation and Recovery Act of 1976 (RCRA) and the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), empty drums must be carefully managed by both drum users and recyclers.

The following pages present the policies covering the pick-up, transportation, purchase of or charges for used, empty steel, plastic and fibre drums offered to our company. We trust you will understand why we must follow these policies without exception. Please note that in some cases we PAY for drums picked-up; in others we must CHARGE. Please do not call for a pick-up unless you are familiar with our pricing.

The drum acceptance and rejection policies outlined in this letter reflect the current status of applicable regulations published by the U.S. Department of Transportation (DOT), the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administrations (OSHA), we will make every effort to keep you informed.

DRUM ACCEPTANCE POLICY

In short, drums offered for reconditioning must meet three major physical criteria; they must be (1) empty, (2) closed, and (3) labeled. In addition, they must not have contained acutely hazardous wastes. When offering drums for transportation, the drum user is asked to sign off on an Empty Drum Certification attesting that the criteria listed above have been met. This certification is both the users and the reconditioner's principal guarantee of compliance with RCRA and CERCLA. Finally, Queen City Barrel requests a Material Safety Data Sheet (MSDS) for each drum residue before raw drum shipment. Each of these empty drum criteria's is discussed in further detail below.

In cases where drums offered to Queen City Barrel do not meet all the acceptance criteria, please refer to the drum rejection policy outlined in the second part of this letter. The rejection policy describes the actions that will be taken to return any non-empty drums to the drum user.

Drums must be empty. Queen City Barrel will not accept drums that are not empty. While we understand that some minor residue of the drums prior contents will remain after normal emptying, how much is acceptable is decided by EPA's definition of a "RCRA-empty" container (40 CFR 261.7). This regulation says that the drum should be as empty as it can be using "the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping and aspirating..." Additionally, in no event may there be more than one inch (or 3 percent by weight) of residue left in the drum.

Different types of products require different degrees of emptying (for example, solvents vs. paints). The "one inch" rule applies only as an outside limit. It does not authorize all drums to have one inch of residue. The first part of the regulation must also be met -- the drums must be as empty as they can by using normal emptying methods. With all but a very few products (such as tar), this will result in far less than one inch of residue. As a practical matter, the rule means that if an opened drum is turned over, only a few drops of product will come out. The drum should be "drip dry".

Drums must be properly prepared for transportation. DOT regulations stated in 49 CFR 173.29 (a) require that an uncleaned, empty drum must be shipped;

  1. with "all openings, including removable heads and filling and vent holes, tightly closed," and...
  2. with the original label (describing the drum residue) legibly in place.

If you no longer have sufficient closures on hand for your used drums, our company may provide them (at your request) for a nominal cost. Any gashed, leaking or punctured, uncleaned drums must be over packed for shipment. Our company may also provide salvage drums for such use at your request. Labeling is the drum users responsibility.

There is no DOT placarding requirement for vehicles transporting empty drums -- see 49 CFR 173.29 (c) (1). Also, empty drums picked up by our trucks (or delivered by your trucks or contract carrier to our facility) are exempt from the DOT shipping paper requirement because such drums are "collected and transported for reconditioning, remanufacture or reuse." [As per 49 CFR 173.29 (c) (2).]

Drums must not have contained "Acutely Hazardous Waste." The EPA has published in 40 CFR 261.31, .32 and .33(e) list of wastes and commercial chemical products whose residues are considered to be "acutely hazardous." (These wastes are more commonly referred to as "F-," "K-," and "P-wastes.")

Queen City Barrel will pick-up drums containing any of these acutely hazardous waste residues only by special arrangement. These drums must be "triple-rinsed" by the emptier according to 40 CFR 261.7(b) (3) and a special certification to this end must be supplied by the drum user. Queen City Barrel can pick-up drums only after the shipper (on every load) certifies compliance with the above requirements. This certification is to be made in the form of an "Empty Drum Certification" form to be provided by our company. A copy of this certification, signed also by our company driver, is left with you after pick-up of your drums.

Queen City Barrel requests an MSDS for each drum residue you will be sending to our site. These MSDS's need not be sent with every shipment, rather a one-time bulk shipment of MSDS's for your company's residues may be sent to the attention of our Environmental Manager and held on file. (However, if you feel that it would be easier to send the sheets with the drum shipments, that option is also available. Arrangements should be made beforehand with our Environmental Manager.)

The MSD sheets allow our company to offer the safe handling and emergency response information to our employees according to OSHA's Hazard Communication Standard (29 CFR 1910.1200). In addition, maintaining a complete MSDS file for each customer allows our company to ensure that your residues are compatible with our raw drum handling and cleaning procedures.

If you are unsure whether or not your MSDS's are on file with our company, please contact either our Environmental Manager or our Customer Accounts Representative.

Our drivers will stack and load drums in their trailers. Our offer to pick-up drums is based on suppliers placing the drums "on the tailgate." Otherwise, in cases where a trailer is "dropped" at a supplier's plant, all loading will be done by the supplier's personnel. Remember, it is always the generator's responsibility to ensure that all drums offered for transportation meet DOT and EPA requirements.

Incoming raw drums are inspected at our receiving yard to ensure that they are empty, closed and labeled. Drums that are not empty are set aside and specified steps are taken to return the drum to the customer (see our Drum Rejection Policy below). Unclosed or unlabeled drums are noted, and the customer is contacted to prevent such transportation in the future.

This yard inspection is also used to assign a value due to many factors. Some major factors affecting drum's value are:

  1. The gauge of metal used for construction;
  2. The DOT or UN specification status;
  3. The nature of residues of previous contents, difficulty of removal, and steps necessary to handle safely and dispose of these residues;
  4. The degree of damage and overall condition of the drum; and
  5. Queen City's current inventory and need.

Because of one or more of these factors, some drums have no value and we must charge for their proper disposal. This disposal charge is used to cover costs for cleaning before sending the "Junk" drum to a steel scrap recycler. All cleaning, handling and disposal is done according to applicable environmental and transportation requirements.

Drums unloaded at our facility may be rejected if during the receiving yard inspection they are found not to be empty. Our Yard Supervisor will relay any "Heavy" drum identifying information (trailer number, date and drum contents) to the Environmental Manager and will set the heavy drum(s) in a designated, contained concrete dock.

Upon receipt of this information, the Environmental Manager or Customer Accounts Representative will contact the customer directly and inform the drum user that the drum needs to be returned for further emptying. Drum return is the drum user's responsibility. The user will be given the option of either picking up the heavy drum(s) within a week of notification, or the heavy drum(s) will be returned by common carrier, freight collect.

Before return, the drum will be labeled with the following statement: THIS DRUM IS BEING REJECTED AND RETURNED BECAUSE IT STILL CONTAINS EXCESSIVE AMOUNTS OF VALUABLE PRODUCT AND IS NOT EMPTY ACCORDING TO EPA'S DEFINITION IN 40 CFR 261.7. PLEASE EMPTY, DEFACE THIS NOTICE, AND RETURN. A handling charge of $20 will be assessed for every heavy drum received at the Queen City site. An additional charge of $65 will be made for any overpacks needed. Overpacks will be used for any leaking drum and for all drums to be returned by common carrier.

SUMMARY

All drums offered for reconditioning to Queen City Barrel must be empty, closed and labeled according to various environmental and transportation regulations. In addition, any drums that previously contained acutely hazardous waste must have been triple-rinsed. Certification that these criteria have been met will accompany each load of drums sent for shipment. Also, an MSDS for each drum residue offered to Queen City Barrel must be provided by the drum user prior to shipment.

Incoming raw drums will be inspected at the QCB site for compliance with all drum acceptance criteria. A drum value will also be confirmed at this time. Any drums not meeting the drum acceptance criteria will be returned to the user at his cost.

If you have any questions about criteria or procedures mentioned in this letter, please do not hesitate to call Ron Hodel, Corporate Manager of Environmental Affairs at (513) 921-8811.

For more information, visit www.qcbarrel.com.

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