What Do We Mean by “No More Direct-to-Scrap”?

Introduction

Thousands of companies throughout the United States regularly purchase products that are transported in industrial containers, such steel and plastic drums, as well as intermediate bulk containers.  A significant percentage of these containers carry chemicals and other materials regulated as hazardous by the Environmental Protection Agency and/or the Department of Transportation. 

After the regulated material in these containers has been used for production purposes, a small amount of residue inevitably remains in the container.  For example, imagine you are drinking a chocolate milk shake: When you finish, a small amount of residue always remains on the side and bottom of the soda glass.  This is exactly what happens when drums and IBCs are emptied in production processes, particularly if the material being emptied is viscous, like paint or ink.

Often, company managers do not understand that even small amounts of regulated residues must be managed in accordance with several federal laws and regulations designed to prevent environmental contamination and protect worker health and safety.  Some of these companies crush or shred their residue containers and send them to scrap processing facilities. 

These company managers may think they are doing the right thing by recycling, but in fact they may be putting their companies in serious legal jeopardy for failing to comply with environmental laws and regulations, including the Resource Conservation and Recovery Act (RCRA) and the Hazardous Materials Transportation Act (HMTA).  [Go here for a full discussion of these issues.]

Importantly, scrapping industrial containers before the end of their useful life actually harms the environment by preventing reuse.  Several studies have shown that industrial container reuse saves hundreds of millions of pounds of carbon emissions (CO2е) every year! [Go HERE to see these reports.]

What Should Your Company Do?

Companies should send all their empty residue containers to a reconditioner that is a member of the Reusable Industrial Packaging Association (RIPA).  RIPA members abide by a comprehensive Code of Operating Practice that ensures your empty containers are transported, stored, cleaned and reconditioned in a manner that complies with applicable laws and regulations.  Importantly, reconditioners strive to reuse all industrial containers after reconditioning.  Reuse is far more environmentally beneficial that scraping or disposal.   Containers that can’t be reused are cleaned and only then sent to a licensed scrap processor.

More Information

RIPA has developed information in several formats that will help companies understand their legal responsibilities related to the management of empty residue containers.  RIPA encourages companies to use these materials freely and, as such, has put no restrictions on their use.

A Discussion of the Federal EPA Empty Container Rule: Purpose and Application

Ending Direct-to-Scrap: The Case for Reconditioning Industrial Shipping Containers.ppt

“No More Direct-to-Scrap” Watch The Video: Here

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