Friday, December 26, 2008

Proper Empty Barrel Preparation

Proper emptying of every container is the most important aspect of in-plant responsible container management. It affects the cost, regulatory compliance , and legal ability.Cost - The residue of costly material left in the containers can represent enormous lost profits to manufacturing companies. This is virgin product that has been paid for and yet discarded and unused, when left in a container. Generators should remove as much product as possible every time.Regulatory Compliance for most products only containers meeting the EPA "EMPTY" definition (40CFR261.7) escape classification as hazardous wastes. Used containers which are hazardous face staggering costs of legal disposal far more than through disposition when empty containers are processed by container reconditioners.Legal Liability Persons arranging for disposition of non-empty containers may be considered to have "arranged for disposal or treatment........of hazardous substances" or to have engaged in the "abandonment or discard" of unclean containers. Both of these terms are from the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (42 USC 9601), or "Superfund" and both activities establish strict, retroactive, joint and several liabilities for any subsequent contamination and environmental response costs.

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