Empty Drum Certification Policy
Introduction
At Cowley Containers Corp., we enforce a stringent Empty Drum Certification Policy to ensure compliance with federal regulations and uphold our commitment to environmental responsibility. This policy governs the acceptance and processing of empty drums and IBC (Intermediate Bulk Container) containers, ensuring they meet the necessary criteria before undergoing reconditioning.
Certification Process
1. Documentation Requirement
- Providers of drums or IBC containers must submit an “Empty Drum Certification” for each delivery. This document serves as a legal affirmation that the containers are empty according to the definitions set by the Department of Transportation (DOT) and Environmental Protection Agency (EPA).
2. Criteria for “Empty”
- A drum or container is considered empty when all residues have been removed that can be removed using practices commonly employed to empty containers, including pouring, pumping, and aspirating. For pourable substances, no residue should remain that can flow out of the container when positioned vertically.
3. Specific Guidelines for Non-Pourable Materials
- In the case of non-pourable materials (e.g., viscous substances, solids, sludges), no material shall remain that can be removed by physical methods like scraping or chipping.
Certification Review and Validation
- Certification Audit: Upon receiving containers, Cowley Containers Corp. management will review each Empty Drum Certification for completeness and adherence to the standards.
- Verification of Contents: The source, date of pickup, and count of drums will be audited against the certification provided.
Rejection of Non-Compliant Drums
- Inspection Standards: Each drum or container will undergo an internal inspection upon arrival.
- Non-Compliance Handling: Drums found to be non-compliant with the “empty” criteria will be rejected. Reasons for rejection will be communicated to the provider.
- Return of Non-Compliant Drums: Rejected drums will be returned to the emptier as a product, and appropriate documentation will be maintained.
Record Keeping and Compliance
- Legal Compliance: This policy is designed to comply with 49 CFR 173.29 and other relevant regulations.
- Documentation and Records: Detailed records of all Empty Drum Certifications and associated audits will be maintained as part of our legal and environmental compliance procedures.
Environmental and Safety Considerations
- Safety Assurance: The policy aims to prevent the handling and transport of potentially hazardous residues, ensuring the safety of our employees, clients, and the environment.
- Promotion of Recycling and Reuse: By enforcing this policy, we advocate for the recycling and reuse of containers, aligning with our commitment to sustainability.
Conclusion and Contact Information
Adherence to the Empty Drum Certification Policy is critical for the safety and efficiency of our operations at Cowley Containers Corp. For further information or clarification on this policy, please reach out to us.
Contact Us for More Information:
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