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TOP-DRUMS: Managing Drums

REV: 12/05/02

SCOPE:  This procedure covers the policy of managing drums containing hazardous / non-hazardous ingredients (as specified in TOP-HAZCM).  This procedure meets solid and hazardous waste compliance requirements for proper drum management.  The term "drum" is to be construed in the broadest sense of "container" if a hazardous waste is encountered in some vessel other than a drum.

STEP

WHO

WHEN

INFO TO USE

WHAT TO DO

RESULTS
1 Warehouse worker Upon receipt of hazardous material Material Safety Data Sheet (MSDS); Hazardous material; receiver; labels on drums; National Fire Prevention Association (NFPA) label Review receiver; make sure NFPA label is filled out and affixed to every drum; store drums in holding area designated by Environmental Coordinator* Drums properly identified and stored in holding area
2 Anyone using product from drum Whenever using a product from drum MSDS; manufacturer's instructions; NFPA label Follow instructions on MSDS; use product as instructed Product properly used
3a Anyone using product from a drum Drum empty Empty drum; MSDS; drum handling policy Contact the Maintenance Supervisor Maintenance Supervisor informed of need to remove waste container to holding area
3b Maintenance worker Upon notification of empty container from departmental employee Empty drum; MSDS; drum handling policy Seal empty drum; place drum in secured "holding area" for empty drums; assure label is still affixed to drum; if label is not secure or if legibility is doubtful, notify Environmental Coordinator so proper arrangements can be made to remove old label and make new label and affix to container Empty drum properly stored in secured "holding area" awaiting removal from premises; arrangements made to replace old or unreadable labels
4 Manager, Supervisor or Warehouse worker Upon need to re-order approved product MSDS; drums stored in "holding area" Place order with vendor; request vendor to accept empty drums upon delivery of new order (for purposes of recycling); if vendor will not accept return of drums, notify Environmental Coordinator Order placed for approved material; removal of empty drums coordinated by vendor for recycling
5 Environmental Coordinator Upon notification from Supervisor or Foreman that vendor will not accept return of drums Notification Properly classify and manifest drums according to TOP-WASTE; make arrangements to have empty waste containers properly disposed of Empty drums classified, manifested, and properly disposed of

* The Human Resources Manager performs the duties of the Environmental Coordinator. 

 

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