Environmental and Transportation Regulations Demand Intact, Drip Dry Drums

Customers in nearly every industry receive 55-gallon drums of oil, lubricants or chemicals from SCL on a regular basis. From automotive to construction, agriculture to industrial manufacturing plants, 55-gallon drum deliveries are a crucial part of doing business.

But what about when those drums are empty? Can SCL drivers simply exchange an empty drum for a full one?

The short answer is yes – but it depends.

While SCL and its suppliers visually inspect all containers prior to filling to ensure both cleanliness and product integrity, the extraction apparatus or pump used by end users oftentimes presents an issue regarding our exchange criteria. As a precaution, most manufacturers design pumps with downtubes that sit slightly elevated from the bottom, inadvertently leaving some fluid remaining. This ensures pumps do not pick up any potential foreign materials resting at the bottom that could find its way into an operator’s machine.

As a result, most drums, once they are deemed “empty” by customers, often have about 1- to 2-inches of product still left in the bottom. According to state and federal regulations, “if” that product will no longer be used for its original intended purposes, it is then deemed hazardous waste and must then be transported and disposed of in accordance with appropriate regulations.

“At that point, as much as we’d like to take our customers’ word that the material in those drums is the original material, we cannot assume that liability,” said SCL Regional Manager Brett Leggitt, who oversees all compliance for northern California. “The chain of custody of that drum has been lost and we cannot vouch for its contents based on anyone’s word or good intentions. Our drivers are also not licensed to transport hazardous material, so it’s just safer and easier for everyone if drums are empty when they are picked up.”

Drip Dry Drums and Cost Savings

Aside from regulations prohibiting SCL drivers from taking drums that contain any unused product, the practice amounts to wasted money for customers, Leggitt said.

In order to ensure you get the most out of every drum, the best practice is to empty any remaining product from drums into 5-gallon pails and then use that product in the application relevant to your business.

That way no one has the added burden of disposing of hazardous waste and businesses get the most out of product they’ve already purchased.

“If you’ve got 3 gallons left in that drum and product is $15 per gallon, that’s $45 you’re potentially throwing away,” Leggitt said. “By using a pail, our customers can turn around and use that product. They’re not losing money and our drivers can take the empty drum from them and deliver it to a recycling facility.”

In order for drums to be compliant for pick-up by SCL drivers:

• They must be drip dry.

•  They must not contain any waste oil.

• They must be intact (no holes) with bungs in place.

• They must not contain excessive rust or corrosion.

• If plastic, they must only have been used for DEF or coolant. All metal drums, regardless of brand or provider, may be picked up if standards above are met.

Making it Easier for Customers

SCL drivers are trained to make the entire process as easy on customers as possible, many times carrying extra bungs or caps to ensure drip dry drums can be taken in the event the original caps were lost.

If drums have been used for waste oil, SCL drivers cannot take them. SCL can, however, help customers get the required EPA ID number (which are issued online at no cost) and contact a certified waste hauler who is licensed to handle waste oil.

“Our goal here is not be an adversary to our customers; our goal is to help them dispose of their waste properly and make the entire process as seamless as possible,” Leggitt said. “We just have to do so in a way where we’re keeping environmental and safety regulations top priority.”

For more information on EPA regulations or to obtain an EPA ID number for drums that have been utilized for waste oil or those that are not intact, customers can visit www.dtsc.ca.gov.

Customers can also view SCL’s full Drum Return Policy here.

Contact an SCL Consultant today

In a wide range of automotive, industrial and commercial sectors, SCL remains steadfast on its commitment to product and industry knowledge, performance satisfaction and superior logistics. We protect and optimize the machines that keep our country moving. For more information on how we help can help with services including bulk purchasing or managing inventory, contact an SCL expert today.