Standard Operating Procedures (SOPs) for utilisation of hazardous wastes contaminated barrels and containersaremandatory for the proper Hazardous Waste Management (HWM) Authorisation for handling hazardous wastes related to contaminated barrels and containers to ensure the safety of workers, the environment, and the public. A two-stage cleaning process is required to reuse contaminated barrels, drums, or containers. First, the items must be washed with hot water, a caustic solution, or a detergent. The caustic solution should be no more robust than a 2% concentration. Next, a fixed nozzle should clean the items with fresh water. If you’re producing plastic granules, you must follow the same two-stage cleaning process, followed by shredding. After treatment, the wastewater must be recycled. In this article, we will understand the SoP applicable to the utilisation of hazardous wastes contaminated barrels and containers by businesses that store/discard/ reuse or recycle such items.
SOPs for Utilisation of Hazardous Wastes Contaminated Barrels and Containers
- When storing and handling contaminated barrels, the unit must only obtain those that are compatible with cold/hot water, detergents, or caustic solutions and do not produce flammable or toxic gases. The SPCB must authorise the transportation of contaminated containers.
- Barrels, containers, or drums contaminated with chemicals from pharmaceuticals, food processing, cosmetics, textiles, paint formulation, and beverage industries can be cleaned if they don’t display characteristics of Class C3, C4, C5, C6, and C11 of Schedule II of HOWM Rules, 2016, and don’t release toxic gases upon contact with air or water.
- To prevent rainwater intrusion, the unit must have separate covered storage areas for contaminated and cleaned containers. The sheds must have a proper slope and spillage collection pit to gather spillages and floor washings, which will be sent to the Effluent Treatment Plant for treatment.
- A designated area for the utilisation of hazardous wastes should be for dry-draining drums contaminated with oils and lubricants. The drums must be inverted on a sawdust bed for 2-3 hours before washing. The oil and lubricant-soaked dust will be collected and sent to a TSDF for disposal, and the liquid effluent will be directed to the Effluent Treatment Plant for treatment.
- To ensure worker safety when opening drums containing chemicals that may release vapours, the following measures must be taken:
- The cap of the drum should only be opened in a well-ventilated area.
- Personnel handling the drum should wear protective gas masks while opening it.
- Exhaust/suction blowers should be provided in the shed area where the drums will be opened and where they will be hung upside down.
- Maintain a manifest system and logbook, and label all contaminated drums with the source, date of receipt, and chemicals/hazardous waste stored.
- Ensure that residual material in drums is safely transferred into a separate container for storage and disposal at a Treatment Storage and Disposal Facility (TSDF) before cleaning contaminated containers/drums/barrels.
- Install nozzles with multiple jets to ensure that water reaches the entire inner surface of the containers.
- Provide a bund wall along the container storage and washing area with a proper slope and collection pit for channelisation of spillages to the Effluent Treatment Plant for further treatment and utilisation of hazardous wastes.
- A separate area should be available for washing the outer surface of containers with a hose pipe, proper drainage, and a collection pit. The effluent generated should be treated, recycled, or sent for further treatment and disposal.
- The unit should aim for zero discharge and recycle treated wastewater in the washing process.
- The effluent generated should be treated by neutralisation, coagulation, sedimentation, aeration, and filtration and recycled in the washing process.
- The unit can consider becoming a Common Effluent Treatment Plant (CETP) member for final treatment and disposal.
- If an evaporator is used, its flow should be regulated based on its heating capacity, and the vent of the vacuum pump should be elevated. Multi-Effect Evaporator (MEE) is preferred over a simple evaporator. Water flow meters shall be installed at the inlet to the evaporator and the inlet to ETP. The pre-existing labels on the drums/containers should be removed physically or with solvent and then with paint, and the cleaned containers should be labelled with the following prominent text:
“Drum Cleaned by: M/s
Use only for industrial purposes
“NOT FOR STORAGE OF ANY FOOD MATERIAL“
Note: The requirement for labelling is not applicable if the cleaned drums are dismantled, shredded, and recycled as a part of the utilisation of hazardous waste containers.
- All personnel involved in plant operations must wear appropriate personal protective equipment such as masks, safety gloves, goggles, and safety shoes.
- The effluent must be monitored quarterly for the parameters specified in the Consent issued by the concerned State Pollution Control Board (SPCB). This monitoring must be done through a laboratory accredited by NABL/EPA, and reports must be submitted quarterly to the concerned SPCB.
- The unit must submit quarterly and annual information on the quantity of used drums procured and cleaned, their source, mode of cleaning (i.e. detergent/caustic solution), quantity of wastewater generated, treated, and recycled, and residue generated (i.e. left-over residue, evaporator residue, and ETP sludge) or resources conserved (specifying the details like type and quantity of resources conserved) to the concerned SPCB.
- The residue generated from drums, evaporator, and sludge generated from ETP must be packaged and temporarily stored in a dedicated hazardous waste storage area and sent to the TSDF within 90 days from the generation of waste as per the conditions stipulated under consent/authorisation issued by the concerned SPCB.
- The unit shall maintain a passbook issued by the concerned SPCB wherein each procurement detail of contaminated barrels/containers/drums as follows shall be entered:
Address of the used Drum supplier
Date of dispatch
Seal and signature of the sender Date of receipt in the premises
- The unit is required to keep a record of the cleaned contaminated drums and the generated residues after the utilisation of hazardous wastes and submit annual returns to SPCB as per Form 3 and Form 4, respectively, as per the rules of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
- The unit shall maintain a logbook containing information such as the source of procurement, quantity, the number of drums cleaned/quantity of granules produced, hazardous waste generation, disposal, and emission and effluent analysis reports, if applicable.
- If there are environmental damages caused by the improper handling of hazardous waste, including accidental spillage during generation, storage, processing, transportation, and disposal. In that case, the unit is responsible for implementing immediate response measures, conducting an environmental site assessment, and remediating contaminated soil/groundwater/sediment, as per the “Guidelines on Implementing Liabilities for Environmental Damages due to Handling & Disposal of Hazardous Wastes and Penalty” published by CPCB.
Application for issue of HWM Authorization and Utilisation of hazardous wastes
The application for HWM Authorisation must be in accordance with Rule 6 of the Hazardous and Other Wastes Rules, 2016. The following authorities are involved in the process of providing authorisation for hazardous waste management:
- The Central Pollution Control Board
- The State Pollution Control Board/pollution control committee
- The Directorate General of Foreign Trade
- The Port Authority and Customs Authority
- The Ministry of Environment, Forest, and Climate Change
Documents Required For Authorisation of Hazardous Wastes
The documents required are as follows:
- Copies of the Aadhaar Card and PAN Card of the applicant;
- GST certificate;
- Proof of ownership or rental/lease agreement;
- Factory or trade license;
- Electricity bill;
- Layout plan;
- Certificate of incorporation (if applicable);
- Memorandum of Association (MOA) and Articles of Association (AOA) (if applicable);
- Board resolution appointing an authorised person.
Stages in the Application Process
- Step 1: Filing an Application
In order to acquire Hazardous Waste Management Authorization, an application has to be made to the concerned SPCB/PCCs at the OCMMS portal per Form I.
- Step 2: Review the Application
After receiving a complete application, SPCB/PCC will conduct an inquiry into the regulations given in the Rules and inspect the document submitted by the applicant, followed by site inspection.
- Step 3: Grant of License
At last, if there are no queries in the application and all issues raised during the inspection have been resolved, the authorisation is granted accompanied by a copy of the field visit report to the applicant.
Standard Operating Procedures (SOPs) for the utilisation of hazardous wastes are essential guidelines for handling hazardous wastes contaminated barrels and containers to ensure the safety of workers, the environment, and the public. The SOPs should cover the procedures for handling, storing, transporting, and disposing of hazardous waste containers. The SOPs should also include information on the types of hazardous wastes and the corresponding regulations that govern their handling and disposal. The personnel responsible for handling and utilisation of hazardous wastes should be trained in the procedures outlined in the SOPs and follow them strictly. Therefore, expert advice is recommended while dealing with hazardous waste to avoid legal complications.
Read Our Article: Hazardous Waste Management Authorization Norms: An Overview