Empty Drum/Tote Return Requirements

While many consider the pick-up and return of empty chemical packages (pails/drums/totes) as a service provided by their supplier, the Department of Transportation (USDOT) has specific regulations that must be followed for “empty” containers. Both hazardous and non-hazardous product container returns need to be handled in specific ways to ensure compliance with USDOT requirements. Although there are some differences for shipping empty hazardous and non-hazardous material containers, it is best to follow the same procedures for both classifications of products.

“Empty packages” are defined in the Federal Register under section 49 CFR 173.29. Only residues may remain in the container to be offered for returns, and the containers must be handled under the same manner as when the package was full. “Residues” are defined under 49 CFR 171.8 and require that the product has been unloaded to the maximum extent practicable and free of any hazardous vapors. Thus, ALL containers must have all closures in place (caps, bungs, gaskets, etc.) before they can be accepted for returns.

It is also the responsibility of the end use customer to initiate the return process, as any company returning a chemical container is defined as a “shipper” by USDOT. Whether the empty package is returned by the supplier’s own vehicle or a common carrier, it is the shipper who is ultimately legally responsible for the empty packaging to meet the USDOT regulations.

Coyne maintains a staff of Regulatory Specialists who can assist you should you have any questions regarding this process. Please feel free to contact your Coyne Environmental Applications Specialist to have a call arranged or call 1-800-523-1230 and ask for someone in Safety and Regulatory Affairs.

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