Properly managing hazardous waste does not end once the container is emptied. The U.S. Environmental Protection Agency (EPA) has established clear regulations that define when a drum that once held hazardous materials can be considered “empty.” Understanding these rules is essential for maintaining compliance, ensuring workplace safety, and preventing environmental contamination. Whether your facility uses hazmat drums, a 55 gallon hazmat drum, or DOT approved hazmat containers, following the EPA’s empty container rule is a crucial step in responsible hazardous waste management.
Gorilla Drum provides safe, compliant, and efficient solutions for managing and transporting hazardous waste drums, offering advanced alternatives for modern industrial operations.
Understanding the EPA Definition of an Empty Drum
The EPA’s “empty container rule” applies to containers that once held hazardous materials, including hazardous waste, chemicals, and regulated substances. According to 40 CFR §261.7, a drum or container is considered empty when:
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All pourable materials have been removed using normal methods such as tilting or draining.
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No more than one inch (2.5 cm) of residue remains at the bottom.
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No more than 3% by weight of the total capacity remains if the container is 119 gallons or smaller.
These criteria ensure that leftover residue is minimal and no longer presents a significant hazard during handling, recycling, or disposal. Once a container meets these conditions, it is no longer regulated as hazardous waste under EPA standards.
Why the EPA Rule Matters
The EPA rule for empty drums helps prevent environmental contamination and promotes proper recycling or reuse of containers. Even small amounts of residue from a hazardous waste drum can pose health risks or lead to pollution if not handled properly.
Following the EPA rule ensures:
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Compliance with federal and state environmental regulations
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Reduced liability for improper disposal
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Safe handling and transportation of used containers
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Prevention of contamination or accidental exposure
Failure to meet these requirements can result in fines, cleanup costs, and potential environmental violations.
Containers That Must Follow the Rule
The EPA empty container rule applies to any container that held a hazardous material, including:
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55 gallon hazmat drum containers
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Hazmat barrels or chemical barrels
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UN rated hazmat drums used for transport or storage
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DOT approved hazmat containers for waste collection
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Any container used for storing hazardous liquids or solids
Even containers that appear dry or clean may still contain residue that qualifies as hazardous waste. Proper draining, inspection, and documentation are essential before declaring a drum “empty.”
How to Properly Manage an Empty Drum
Facilities should follow a structured process to ensure compliance with EPA and DOT guidelines.
Step 1: Drain and Remove Residue
Completely drain the drum using conventional methods such as pumping, tilting, or gravity draining. Pourable materials must be fully removed, leaving only small amounts of residue that meet EPA thresholds.
Step 2: Verify Compliance
Inspect the container to ensure that no more than one inch or 3% of the waste remains. For non-pourable materials like solids or sludge, scrape out as much as possible.
Step 3: Label the Container
Once confirmed empty, clearly label the drum to indicate its status. Proper labeling prevents confusion and ensures the container is handled correctly in the future.
Step 4: Store Safely Until Reuse or Disposal
Store empty containers in a secure area away from active waste streams. Use appropriate containment and avoid stacking damaged drums to prevent leaks or accidents.
Guidance on proper storage can be found in the Safe Storage And Transport Of Chemical And Waste Drums resource, which provides best practices for handling chemical and waste containers safely.
Step 5: Recycle or Dispose of Properly
Empty containers may be sent for recycling, reconditioning, or scrapping if they meet EPA criteria. Drums that still contain hazardous residue must be managed as hazardous waste.
Special Considerations for Hazardous Waste
When managing empty hazardous waste containers, additional precautions apply. Some residues, particularly from acutely hazardous waste, may require more stringent cleaning methods. For example, containers that held highly toxic or reactive substances must be triple-rinsed or otherwise cleaned according to EPA and local regulations before they are considered empty.
Facilities should also confirm that all residues are compatible with the intended reuse or recycling process. If containers are reused for non-hazardous materials, thorough cleaning and verification are mandatory to prevent cross-contamination.
The Role of UN and DOT Compliance
Even when a drum is empty, it may still fall under certain transportation rules if any residue remains. UN rated hazmat drums and DOT approved hazmat containers are designed to withstand handling and transport stresses, reducing the likelihood of leaks during transit.
Facilities that reuse or ship empty containers should ensure they continue to meet UN and DOT performance standards, including secure closures, proper labeling, and integrity checks. These steps maintain safety during the entire waste management process.
Selecting the Right Drums for Waste Storage
The EPA’s empty drum rule also highlights the importance of using the right containers from the start. Choosing drums designed for your specific waste type ensures safer storage, easier cleaning, and simpler compliance when the drum reaches the end of its life cycle.
For help choosing the right container, review the Guide To Choosing The Right Hazmat Drums For Waste Storage. This resource explains how to select hazmat drums based on material compatibility, waste classification, and regulatory requirements.
Gorilla Drum: A Modern Solution for Safer Waste Management
Traditional steel or plastic drums can be heavy, cumbersome, and costly to clean or dispose of once empty. Gorilla Drum offers a next-generation alternative for managing hazardous waste safely and efficiently.
Gorilla Drum is:
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Collapsible for reduced storage space
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Lightweight yet durable for easy handling
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UN and DOT compliant for hazardous waste transport
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Designed with reinforced zipper closures and lift loops for convenience
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Ideal for both liquids and solids
These innovative containers simplify compliance with EPA rules by making waste handling and storage more efficient while maintaining safety and performance standards.
Final Thoughts
The EPA rule for empty drums ensures that containers once used for hazardous materials are properly managed, cleaned, and labeled before disposal or reuse. Following these guidelines protects workers, the environment, and your facility from regulatory violations.
Whether your operation handles hazardous liquids, solids, or mixed waste, Gorilla Drum provides compliant, easy-to-use solutions for safe chemical drum storage and transport.
For more information or to discuss compliant waste storage options, call +1 800-758-8079.