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If an employer’s containers have been emptied according to the regulation at 40 Code of Regulations (CFR) 261.7, then they are considered to be “Resource Conservation and Recovery Act (RCRA) Empty,” meaning they are no longer regulated as containing hazardous waste. However, even “RCRA Empty” containers can have some residue left in them that could possibly react with other wastes. Therefore, employees need to use common sense when adding new wastes to the containers and not add materials that are incompatible with what had been in the container.
Check out Appendix V to Part 265 for Examples of Potentially Incompatible Waste. In addition, make sure the drum itself is compatible with the waste being added. The regulations for small and large quantity generators states, “The small quantity generator (SQG) must use a container made of or lined with materials that will not react with, and are otherwise compatible with, the hazardous waste to be accumulated, so that the ability of the container to contain the waste is not impaired.”