Empty Containers - What Should I Do With Them?


When I’m conducting site inspections or training young staff members, one thing I focus on is containers of hazardous materials.  In California, most businesses will have a hazardous materials business plan with an inventory of chemicals they use, approved by their local environmental permitting agency (known as CUPAs, Certified Unified Permit Agencies).  This is a great starting point to looking at how the facility uses chemicals, what they store on site, and what might be hazards associated with those chemicals.

But what about empty containers?  I once came across an extensive collection of empty containers stashed in the basement of a highrise building, because the building manager couldn’t figure out how he was supposed to dispose of these containers and drums.

An empty container (make sure that it really IS empty) that was used to hold either motor oil or used oil is exempt from being regulated as a hazardous waste, as long as the container is sent to a licensed solid waste facility.  That means you should place the empty containers in the regular trash that is being sent to a landfill instead of into any recycling bins.  If the container is less than 5 gallons in capacity, there are no further requirements.

If you have empty containers that are 5 gallons or larger in capacity, you must mark on the container the date it was emptied, and you must dispose of the container within a year of that date.  In addition, for a period of three years after you get rid of them, you’ll need to keep records of the name, address, and telephone number of the facility where you sent these large empty containers.

You can find the regulation about empty chemical and oil containers in Title 22 of the California Code of Regulations, Section 66261.7.