Guides for the person standing next to the tote

Start here

Start with RCRA empty, which sets the rule. Then measuring the heel, which is how you apply it, and the Empty Check, which does the arithmetic.

If the tote held an acute hazardous waste, read triple rinsing. If you are not sure which agency to call, read the three rulebooks.

How the guides are written

Each one starts with the answer, names the rule and says what to do next. Where a guide cites a law, standard or agency, it links the source and shows the date it was last reviewed. They are general guidance and not legal advice, and each one says to check with your hauler and with DOEE, MDE or Virginia DEQ.

The guides on the UN plate, last contents and the cage and bottle are for reading the tote itself. The ones on rainwater and pickup readiness are for what comes after.

In this section

• RCRA emptyWhat 40 CFR 261.7 says for containers over 119 gallons: one inch or 0.3% by weight, worked out for 275 and 330 gallon totes.
• Triple rinsingWhen a tote must be triple rinsed (acute hazardous waste), what solvent to use, and where the rinsate goes.
• Cleaning a toteRinsing on site versus professional washing and reconditioning: what each removes, and why a rinsed chemical tote is not food grade.
• Three rulebooksDOEE, MDE and Virginia DEQ: who regulates hazardous waste in each part of the DC metro, and when a used tote counts as waste.
• The UN plateWhat 31HA1, the packing-group letter, the manufacture date and the retest date on a tote's plate mean for reuse and recycling.
• Last contents and the SDSWhy the last contents decide a tote's next life, where to find them on the label or SDS, and what to send with a pickup request.
• Cage and bottleWhen a tote cannot be reused, the HDPE bottle goes to regrind and the galvanized steel cage to rebottling or steel recycling.
• Recycling HDPEHDPE resin code 2: how a tote bottle is shredded, washed and turned into regrind, and what keeps a bottle out of recycling.
• RainwaterHow much rain a roof sends to a tote, why the tote must have a food-grade history, screening against mosquitoes and winter draining.
• Pickup-ready checklistCaps and valve closed, old label on, SDS to hand, cage intact and room for a forklift or pallet jack: the checklist before a truck comes.
• Storing empties outsideKeeping emptied totes outdoors until pickup: caps on, sun and UV, stacking empties, and keeping rain out of a tote that held chemicals.
• Measuring the heelHow to measure residue in a tote through the fill cap, convert inches to gallons and pounds, and compare it with the RCRA-empty limit.