3EPA
United SIMM
Environmental Protection
Agency
Office of
Solid Wast* and
Emergency Response
DIRECTIVE NUMBER: 9441.01(80)
TITLE: Hazardous Waste Regulation of Empty Drums for Reuse
and Reconditioning
APPROVAL DATE: 5-30-80
EFFECTIVE DATE: 5.30-80
ORIGINATING OFFICE: Osw
Q FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or OAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART A - GENERAL
DOC: 9441.01(80)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Containers
40 CFR 261.6, 261.7(b), 261.33(c), 261.33(e)
Hazardous Waste Regulation of Empty Drums for Reuse and
Reconditioning
Morris Hershson, President, National Barrel and Drum Association,
Inc.
Alan S. Corson, Chief, Waste Characterization Branch, Hazardous
and Industrial Waste Division
#9441.01(80)
5-30-80
Emptied containers which previously held chemical products or manufacturing
chemical intermediates listed in § 261.33(e) are listed as hazardous wastes
[pursuant to §261.33(c)] unless they are triple rinsed or decontaminated by
another, method that has been shown to achieve equivalent removal. If these
drums are not "empty" they are subject to the RCRA hazardous waste management
system with respect to transportation and storage prior to use, reuse, recycling,
or reclamation [§261.7(b)].
Delivery of emptied drums to a dealer does not .exempt the drums from
hazardous waste regulations because the dealer is not a user, reuser, recycler,
or reclaimer. (See §261.7 for a complete description of the standards for
residues of hazardous waste in empty containers.)
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9441.01 (80)
GOLIO \/.\STT!
NV3Q
"r. '-orris ilorshson
^resident, 'National Barrel and
r>run Association, Inc.
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2. Is such a shipment equally exenpt 15 it is oriqinally
delivered to a dealer an
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