The container is empty, but is it RCRA empty?
from EHS Daily Advisor
Although it sounds like a trick question, it's not. A container that seems empty of all its hazardous waste contents may not be empty enough to avoid being managed as a hazardous waste. The Resource Conservation and Recovery Act (RCRA) hazardous waste regulations set forth a standard at 40 CFR 261.7 that determines whether your container is empty enough to avoid hazardous waste regulation — whether it is what is referred to as "RCRA empty." If the standard is met, the container is exempt from most of the RCRA hazardous waste management requirements.
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