CAPITAL DRUM, INC.

Our Mission

Capital Drum Inc. is committed to our customers and meeting their requirements. We will strive to perform error free work and realize continual improvement of our Quality System. We are also committed to providing the best service possible with high quality products at competitive prices.

Our Focus
Capital Drum Inc. is the leader of quality manufactured drum parts. It is our intention to assure customer satisfaction through on time delivery, high quality, and low cost without any compromise to the integrity of our products.

Our company’s training program ensures that the management commitment to quality is understood, implemented and maintained at all levels of the organization.

Our Customer Relationships
Long-term relationships will be sought by maintaining rigorous quality controls, innovative solutions, a responsive business attitude and reasonable pricing.

Our Employees
We will maintain an innovative and team-oriented working environment. In addition, by assuring that our employees are well informed and properly supported, we will provide a climate focused on the long term viability of our company.

Our Future
We must be focused in achieving and maintaining reasonable profitability to assure that the financial and human capital is available for sustained growth.


Capital Drum Products and Uses

The major commodities packaged for transportation in drums include corrosives, flammables, and chemicals, solids and oxidizers such as; solvents, petrochemicals, food products, agricultural chemicals, paints, coatings, acids, peroxide, and janitorial supplies.

All drums are manufactured in two styles, removable (open head, and non-removable (closed or tight) head appropriate to transport solid, semisolid and liquid substances. Which type used depends upon the customer’s needs, and the specific chemical and physical properties of the products to be shipped. The tight head drums are primarily used for shipping liquids, and removable head drums are used for various viscous liquids, dry and semisolid products, and a number of low vapor pressure liquids.

The department of Transportation (DOT) has authorized numerous container specifications for the transportation of hazardous materials. The extensive list of hazardous materials that are authorized to be packaged in containers is published in Title 49 of the Code of Federal Regulations (49 CFR) part 173. Under a memorandum of understanding between DOT and EPA, 49 CFR also includes regulations governing the transportation of hazardous wastes and hazardous polluting substances. These regulations cover shipment of packaged goods by land, sea, and air.

The scope of container specifications together with the extensive materials authorized to be packaged in containers by DOT reflects the range of construction styles and materials permissible to be used for a given product. Container specification for non-hazardous products not requiring a DOT specification container are covered by requirements of the Uniform Freight Classification (NMFC) tariffs for rail and highway movements.


Corporate Environmental Policy

Capital Drum, Inc. takes a comprehensive approach to environmental stewardship that maximizes recycling opportunities, minimizes waste and pollution, reduces energy consumption, and uses the latest in waste management strategies.

Capital Drum, Inc. is committed to social responsibility. We are always seeking ways to better integrate economic progress, social development and environmental concerns to ensure a better quality of life for future generations.

Furthermore, we will make continuous progress toward the vision of no accidents, injuries or harm to the environment and will report our health, safety and environment performance. We will lead our companies in ethical ways that increasingly benefit society, the economy and the environment while adhering to the following principles:


Guiding Principles

To provide drums that can be manufactured, transported, used and disposed of safely
To make health, safety, environment, and resource conservation critical consideration for all new and existing products and processes

To operate our facilities in a manner that protects the environment and the health and safety of our employees and the public

To work with customers, carriers, suppliers, distributors and contractors to foster the safe use, transport and disposal of waste

To lead in the development of responsible laws, regulations and standards that safeguard the community, workplace and environment

To encourage and assist others to adhere to these principles and practices


Drum Acceptance Policy

1.0 Steel Drum Reconditioning

1.1 Transportation of drums containing residues
Drums that have been used for transportation of hazardous materials that have not been cleaned and purged must be transported with all closures in place, with all original hazard markings and labels legible.

1.2 Acceptance of drums containing residues “empty” drums
The State of California, Department of Toxic Substances Control has adopted regulations addressing management of containers which previously held hazardous materials.

The adopted regulations (22 CCR 66261.7), set forth a definition of “empty container” and established management practice which, if met, would exempt “empty” containers from further regulation.

“California Empty” is an established standard which required the generator (the person who uses the contents of the container) to empty all the material possible from the container.

Three standards were set based on the type of material present in the container:

Containers with pourable hazardous materials
No drums may be accepted that are not empty. For containers which held a material which can be readily poured, all material must be removed by any practicable means possible using practices commonly employed to remove materials from drums, (including pouring, pumping and aspirating) before the container can be considered empty.

An acceptable interim definition by local regulators is interpreted to be, if you can see any part of the interior bottom of the drum, the drum can be considered “empty”.

Containers with non-pou-rable hazardous materials
Containers which previously held hazardous materials which are non pourable, no hazardous material shall remain in the container that can be removed by physical methods including scraping and chipping.

This standard applies to hazardous materials which pour slowly or do not pour at all from the container, including, but not limited to, viscous materials, solids which have “cake up” inside the container, and non-pourable sludge’s.

Containers with acute or extremely hazardous waste
Containers which previously held acute or extremely hazardous waste are considered empty if the container has been triple rinsed using a solvent capable of removing the

material or cleaned by another method which is proven to achieve equivalent removal to triple rinsing.

1.3 Empty drum certification
Empty Drum Certification is written documentation executed by the drum emptier and Capital Drum, Inc.

It is a legal business record which documents that the drums are empty in accordance with California’s definition of empty (22 CCR 66261.7); and, have been properly prepared for transportation (49 CFR 173.29).

Every person providing drums containing any residues to Capital Drum, Inc. regardless of prior contents, shall sign an “Empty Drum Certification” (see Appendix, Exhibit 1) on each occasion that drums are offered, verifying that the drums are empty in accordance with the explanation of that term in 1.2 above.

Management personnel will review the Pick-up Work Order auditing the source of drums, pickup date, and drum count; also, the Empty Drum Certification shall be reviewed for completeness.

1.4 Rejection of drums that are not empty
Drums containing residues of prior contents, that are to be loaded on Capital Drum’s trucks by Capital drum’s employees, may be rejected if they appear to be unduly heavy because of the unintended retention of product.

Drums brought to Capital Drum, Inc. plant, or loaded onto Capital Drum’s vehicle by the emptier’s employees, may be rejected at Capital Drum, Inc. site, if, upon internal inspection, they are found to be not empty.

Rejected drums shall be returned to the emptier as product and the emptier shall be advised on the reason for the rejection. (see Appendix, Exhibit II).

Temporary storage of rejected drums awaiting return to the emptier will be securely stored in a designated trailer.

A Work Order will note the volume of drums rejected and the disposition of the drums (i.e. returned to the emptier or picked up by same).

1.5 Inspection of incoming drums
Capital Drum, Inc. must inspect each raw drum when it is unloaded from transportation equipment.

All drums must be inspected to make certain they are empty, (in accordance with the explanation of that term in section 1.2, and, if not, processed in accordance with section

1.4 above), to determine the original specification of the drum, and to determine whether the drum is damaged or un-reconditionable and therefore must be scrapped.

2.0 Open Head Drum Processing

2.1 Preparation
Open and closed head drums from which the top heads have been removed will be submitted for processing.

If the top head is removed by cutting or unrolling, the side wall must be curled or beaded to accept an open head cover.

Reclamation
When thermal processing is utilized, drums with covers removed must be conveyed through the drum reclamation furnace in an inverted position which subjects both the interior and exterior of the drum to temperatures sufficient to prepare the drum for abrasive cleaning. All former contents and corrosion must be removed.

The charred material and former linings and coatings, as well as rust, must be removed through abrasive blasting on the interior and exterior, reducing the drum to bare metal.

Shape and Contour
The contour of the drum must be mechanically restored. Chimes must be mechanically straightened to reform and reseal them.

Drums must be expanded or re-rolled to restore original shape and contour.

Leak Proofness
When required by applicable regulations, each open head drum, except its removable head and adjacent bead area, must be leak tested.

The drum shall be completely immersed in water and application of an internal air pressure of at least 3 kPa (p.s.i.) for Packing Group II and III drums and 7 kPa (p.s.i) for Packing Group I drums, for at least 5 seconds, or by using DOT approved alternative test measures of equal sensitivity.

Drums found to be leaking must be rejected or repaired by welding or brazing.

Inspection
Drums must be inspected for deterioration and those having visible pitting, significant reduction in parent metal thickness from rust or corrosion, other metal defects, or which have not been returned to original shape and contour, must be rejected.

Closures
All closures must be removed, cleaned, and reinserted with suitable new gaskets. Bungs and flanges must show no damaged threads and must ensure a leak-proof seal. Closing rings must be reformed and cleaned, or replaced.

Surface Coating
The drum must be painted with a new exterior coating to provide a protective and decorative finish.

The interior coating or treatment, if required, must be applied and cured in accordance with the coating manufacturer’s specifications.

Performance Oriented Packaging Markings
The completed drum must be marked on the top or side with the “First Line” UN mark, Capital Drum’s identification number or registered symbol, the year of testing, a reference to the nation in which the reconditioning was performed (USA), the letter “R”, and the letter “L” for drums that have been successfully leak-proofed tested.

If the original manufacturer’s durable full UN marking has been removed in the reconditioning process, it must be replaced by the re-conditioner before the drum may be used again to transport hazardous materials.

Capital Drum’s replacement mark may show a performance level below that originally marked by the drum manufacturer, but in no case may Capital Drum mark a higher performance level than was embossed on the bottom of the drum as part of its original “birth certificate”.

Capital Drum’s identify marking constitutes a certification that the drum meets all applicable regulations.

3.0 Remanufactured Drums
Remanufacture is the conversion of a DOT specification drum into UN drums, from one UN type to another type, or which have had integral structural components replaced.

For example, conversion of 1A1 non-removable head drums to 1A2 removable head drums.

All requirements applicable to the manufacturer of new drums apply to these drums.

4.0 Rejected Drums
Drums that have been rejected during the inspection processes and cannot be repaired for hazardous materials service are to be cleaned and directed to non-hazardous material service or prepared for scrap.

When preparing drums for scrap, the drum interior and exterior must be cleaned using an effective cleaning agent or must be thermally neutralized in the drum reclamation

furnace, thereby removing all foreign matter, prior residues, labels and decorative coatings, and the drum then must be mechanically or hydraulically crushed or shredded.

5.0 Environment and Employee Protection

5.1 Storage of drums containing residues
Un-reconditioned drums must be stored with all closures in place, and must be inspected periodically to assure no residual contents are leaking.

All drums that are obviously unfit for reconditioning should be rejected immediately and should be prepared for scrap in accordance with Section 4.0 of this procedure.

Destructive corrosion of drum inventory from atmospheric and ground moisture must be avoided.

5.2 Accumulated residues from drums
All wastes generated in the reconditioning process must be managed in full compliance with applicable regulations governing such wastes.

5.3 Air Emissions
Emissions to the atmosphere must meet applicable air pollution regulations for our geographical area, as well as compliance with the Operating Permit conditions established by the Placer County Air Pollution Control District.

5.4 Employee protection
Exposure of employees to any chemicals in the workplace, including the contents of incoming drums, must be reduced to the extent practicable.

Incoming drums temporarily stored awaiting the reconditioning process, will be stored with all closures in place, and with all original hazard markings and labels legible.

At a minimum, this necessitates that Capital Drum will provide and require the use of effective Personal Protective Equipment (PPE).

Training
Employees must be trained in the proper performance of their jobs, including awareness of the hazards of the process chemicals to which they are exposed and of the importance of compliance with this Code and all government regulations.

Company vehicles and drivers
Capital Drum, Inc. shall employ drivers to operate company vehicles in compliance with the standards of the Federal Highway Administration on the qualification of drivers, including provisions relating to alcohol or other substance abuse. Company vehicles shall be maintained in safe operating condition.


Fire safety
All practical precautions against fires must be implemented, including having adequate fire extinguishing capability, contingency planning, effective coordination with local emergency response authorities, and good housekeeping to minimize opportunities for ignition and to facilitate employee evacuation in emergencies.

Equipment and floor areas shall be kept free of excessive deposits of residual material.

Grounds maintenance
Practical measures must be taken to ensure every area where drums are stored is audited for cleanliness including drum leaks onto the soil due to corrosion from atmospheric or ground moisture.

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