2019 Drum Policy

Based on information received from Reusable Industrial Packaging Association (RIPA), we were recently made aware that the Department of Transportation is initiating an empty container management investigation program aimed to identify companies that are shipping containers that do not meet the RCRA empty container rule. 

Considering this action, Revchem Composites has updated our Empty Drum Pick Up Policy.   Our intent is to educate and protect both you and our team members while ensuring we are compliant with all current regulations.   

• Containers must be completely empty in accordance with California Code of Regulations, Title 22, section 66261.7, or the applicable regulations from your state.
  • For containers that held material that can be readily poured, all material must be removed by any practical means (including draining, pouring, pumping, or aspirating) before the container can be considered empty. In regards to draining, a container is empty when there is no longer a continuous stream of material coming from the opening when the container is held in any orientation.
  • For containers that previously held materials that are non-pourable, no hazardous material shall remain in the container that can feasibly be removed by physical methods including scraping, and chipping, but not rinsing. This standard applies to all materials that pour slowly or don’t pour at all from the container, including, but not limited to, viscous materials, solids which have “caked up” inside the container, and non-pourable sludges.
• All caps and labels must be in place and valves must be closed. DOT 49 CFR 173.29 states that all openings of the empty containers must be closed with bungs tightened and all markings and labels must be must be in place and visible as if the container was full of its original contents. 
• Outside of drum must be free of all residue unless it is completely dry to the touch.
• Revchem will require the drums ship on a bill of lading and the shipper signs and certifies that the drums are empty and meet all of the above specifications. Our drivers will have blank bills of lading with them so you can continue to request pick-ups while our driver is at your facility making a delivery.  However, advance notice is always appreciated.
• Effective January 1, 2019, Revchem will no longer accept competitors empty drums.

Image description to come.