A question from someone in industry about empty oil drums (April 18, 2017):
Hello my name is <<Name>> and I work for <<Company>>, I have a simple question we use 55 gallon metal and plastic drums to contain our oil and have to pay a large sum of money to have them disposed of. If we meet the RCRA empty container requirements can we cut these drums in half and dispose of them or is there some sort of training we would need to go through or an inspection process so that we can simply throw them away ourselves or what do you suggest?
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My reply that same day:
Thank you for contacting me. I will do my best to answer your questions below.
- It is most likely that your oil is not a hazardous waste upon disposal per EPA regulations (state or federal) and is not a hazardous material when offered for transportation per PHMSA/USDOT regulations. A Safety Data Sheet could confirm this assumption.
- If the oil is neither a hazardous waste nor a hazardous material then the drums themselves are not subject to regulation for their disposal nor their transportation off-site.
- As a non-regulated material you have many options for the empty drums (still containing some oil residue):
- Discard as a waste – Check with your landfill and state regulations to determine their position on containers. Many landfills don’t like to see empty containers; you may need to chop them up first. PLEASE REFER TO THE WARNING BELOW BEFORE YOU PERFORM ANY ACTIVITY ON EMPTY DRUMS.
- Recycle – Especially those of metal may be of interest to scrap metal recyclers.
- Reclamation – Especially the steel drums may be of interest to drum reclaimers.
- NOTE: state regulations regarding empty containers may be more strict (e.g. California & Texas). It has been awhile since I have done training in <<State>> but I am not aware of any state regulations for empty containers. More research would confirm this assumption.
- Is the supplier of the oil interested in taking the drums back for reuse?
- The RCRA Empty Exclusion from USEPA Hazardous Waste Regulation
- USDOT Requirements for the Shipment of an Empty Packaging
- BE VERY CAREFUL WITH EMPTY DRUMS: “Once you get an ignition source, boom!”