Triple rinsing a tote, step by step

When a tote must be triple rinsed

The federal rule has two paths. A container that held ordinary hazardous waste is empty when it is pumped out to the inch or 0.3% limit. A container that held an acute hazardous waste is different. Under 40 CFR 261.7(b)(3) it is empty only after triple rinsing with a solvent capable of removing the product, an equivalent cleaning, or removal of its inner liner.

Acute hazardous wastes are the short list of products the EPA treats as dangerous in very small amounts. Most water-treatment chemicals, food ingredients, buffers and cleaners in a 275 gallon tote are not on it. If the SDS or your EHS lead says the product is acute, this guide applies. If you are not sure, treat the tote as needing a determination before anything moves.

A rinse does not turn a chemical tote into a food tote. A triple-rinsed tote is still the original bottle, and it is not food grade unless its history is documented. See the triple-rinsed grade.

The seven steps

1. Confirm the product. Read the old label and the SDS. Triple rinsing is for acute hazardous waste, and most totes do not need it.
2. Drain it first. Pump or drain until nothing more comes out, then close the valve.
3. Choose the solvent. It must be able to remove the product. For a water-soluble product that is often water. The SDS and your EHS lead decide.
4. Rinse to a fraction of the volume. Add solvent to the fraction of the tote’s volume your EHS lead sets, close the fill cap and move the tote so the whole bottle is washed.
5. Drain into a waste container. The rinsate is waste and stays with the generator.
6. Repeat twice more, for three rinses in all.
7. Record it. Write the date, the solvent and the product, and keep the note with the tote.

Where the rinsate goes

The rinsate carries the product. It belongs to the generator, who has to manage it as the waste it is. That usually means a labelled container and a licensed hazardous-waste hauler, not a floor drain and not a storm inlet.

Which agency you answer to depends on where the site is: DOEE in the District, MDE in Maryland or Virginia DEQ. The three rulebooks names each one. Check with your hauler and with the agency before you rinse, so the rinsate has somewhere lawful to go.

After the third rinse

Run the Empty Check with the last contents set to acute and a heel of one inch or less. The ticket will say triple rinse required and offer no request. Once the rinse is done and written down, run the check again and choose triple rinsed and recorded. The ticket then offers a request with the condition triple-rinsed, and the tote and it goes to reconditioning or recycling according to its bottle and cage.

A cracked bottle, a valve that will not seal or a bent cage changes the answer. Those totes still have a next life. The galvanized steel cage can be rebottled or sent for steel, and the bottle goes to regrind.

What the rule says about rinsing

For a container that held a commercial chemical product on the acute hazardous list, 40 CFR 261.7(b)(3) gives three ways to be empty. The container can be triple rinsed with a solvent capable of removing the product, it can be cleaned by another method shown to achieve equivalent removal, or, if it had an inner liner that kept the product from touching the container, the liner can be removed.

The rule names the solvent test by its result, not by a brand: a rinse with a liquid that cannot dissolve the product has not met it. Water suits a water-soluble product and fails on an oil.

The rinsate is a waste

What comes out of the third rinse is not clean water. The rinsate carries the product that was on the walls, so the generator evaluates it as a waste and manages it that way. A site that plans to rinse a tote should plan where the rinsate goes first, because a 275 gallon tote needs a volume of rinse liquid that a floor drain is not meant to take.

If a tote is not triple rinsed, it is not empty and it is not a tote we can take. The Empty Check says so when you pick an acute product.

Planning a rinse before you start

Decide the solvent first, from the SDS and the product’s own solubility, not from what is nearest the tap. Decide where the rinsate will be held, in what container and under whose label. Decide how the tote will be turned, since a rinse that never reaches the corners has not rinsed them. Each of the three rinses should use a measured fraction of the tote’s capacity, and the tote should be drained completely between them.

Record the solvent, the volume of each rinse, the date and the person who did it. A record like that is what turns a clean-looking tote into one that can be called triple rinsed. Without it, a buyer has only a stain-free surface to go on.

When a rinse is not the answer

Some products do not respond to a rinse at all. A thick coating, a resin or a polymer may set on the wall and stay there, and rinsing it again just moves liquid across a stain. In that case the tote is not empty under the rinse option, and the choices narrow to an equivalent cleaning method or disposal as hazardous waste. Ask the hauler before spending time and solvent on a rinse that cannot succeed.

Safety during a rinse

Rinsing puts a person near an open tote and a splashing liquid. Wear the protective equipment named on the sheet, work where fumes can clear, and keep the tote earthed if the solvent is flammable. Never climb on the cage to reach the fill cap. Use a spray lance or a rotating nozzle that reaches the walls from outside the opening.