CAPITAL DRUM, INC.
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 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
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.
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:
To provide drums that can be manufactured, transported, used and disposed of safely
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
1.0 Steel Drum Reconditioning
1.1 Transportation of drums containing residues
1.2 Acceptance of drums containing residues “empty” drums
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
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
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
material or cleaned by another method which is proven to achieve equivalent removal to triple rinsing.
1.3 Empty drum certification
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 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
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.
If the top head is removed by cutting or unrolling, the side wall must be curled or beaded to accept an open head cover.
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
Drums must be expanded or re-rolled to restore original shape and contour.
Drums found to be leaking must be rejected or repaired by welding or brazing.
The interior coating or treatment, if required, must be applied and cured in accordance with the coating manufacturer’s specifications.
Performance Oriented Packaging Markings
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
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
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
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
5.3 Air Emissions
5.4 Employee protection
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).
Company vehicles and drivers
Equipment and floor areas shall be kept free of excessive deposits of residual material.
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