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"Empty" in 200 Words or Less: EH&S Alphabet Soup

describe the imageIf you're in the EH&S field, you're probably using hundreds (maybe even thousands) of acronyms on a day-to-day basis. With so much regulatory jargon, it's easy to forget or misuse a word here or there. So here it is. We're giving you a word a week based on your requests in hopes of generating some vocabulary-based discussion in the EH&S community. 

Determining if a container is empty isn't as simple as opening it and looking to see what's inside for the EPA. RCRA's standards for an empty containerare not the norm.The rules for "empty" according to RCRA are as follows.

If the container was filled with compressed gas, it can only become empty when the inside returns to normal atmospheric pressure. For acute hazardous waste, the liner must be removed, or triple rinsing must have occured, or another method of removing the hazard must have taken place if triple rinsing is inappropriate. For other hazardous waste, an industry accepted method of disposal must have taken place and no more than 2.5 cm of waste can still be in the container or no more than 3% of the container's weight for containers under 110 gallons. Definitely not as easy as eyeballing it. 

Why does it matter if a container is "empty" or not? The answer is simple, since empty containers no longer contain hazardous waste, these regulations are also used to determine when containers are no longer subject to the RCRA requirements.