News Blog Archives for July of 2020

For you and for us, things like used plating solutions, filters, and resins represent valuable materials to recover. To the U.S. EPA and DOT, they constitute hazardous waste, or at least regulated recyclable materials. And all hazardous waste generators, from jewelers to electronics manufacturers, bear full responsibility for its storage and transportation.
But when it comes to shipping hazardous waste, many businesses still get a few things wrong.

While EPA regulates onsite hazardous wastes under RCRA, DOT regulates hazardous waste transportation. DOT requires that hazardous waste be classified, described, packaged, marked, labeled, and in condition for shipment according to its guidelines. When you ship materials to a refiner, failing to meet DOT requirements can result in hefty fines, reducing any revenue you generate through precious metal recovery.

By familiarizing yourself with these regulations, you’ll be better equipped to stay within the legal boundaries for shipping hazardous waste. You can also make better choices
for your business, including the companies you partner with for shipping and refining—decisions that can ultimately affect your bottom line.

To help you navigate the regulations and meet DOT shipping requirements, we’ve created the five-step checklist below. Note that steps 3, 4, and 5 include a few of the most common
mistakes we see shippers make.

1. Determine Whether Your Material is Hazardous Waste

DOT defines hazardous waste in 49 CFR part 171.8 as “any material that is subject to the Hazardous Waste Manifest Requirements of the U.S. Environmental Protection Agency specified in 40 CFR part 262.” This means that DOT considers your materials to be hazardous waste only if they must be shipped on a manifest under the federal RCRA waste requirements.

To determine whether your material falls under those requirements, answer these questions:

1. Is it a solid waste, according to the EPA definition?
2. Is it excluded from regulation under 40 CFR part 261.4?
3. Does it meet any of the descriptions under the list of hazardous wastes in subpart D of 40 CFR part 261?

Thanks to an exemption in subpart F of 40 CFR part 266, recyclable materials from which “economically significant” amounts of precious metals are recovered are exempt from
full hazardous waste regulation. For your materials to qualify, you must receive an economic return valuable enough to cover the costs of recycling. However, you still have to comply
with all of the shipping requirements listed below, in addition to EPA’s record-keeping requirements.

2. Obtain an EPA ID Number (if you don’t already have one)

The EPA hazardous waste generator identification number allows EPA to track hazardous waste from cradle to grave. Whether or not you need an EPA ID number depends on
how much hazardous waste you generate per month, which determines your hazardous waste generator category.

If you generate more than 1,000 kg (2,200 lbs) per month, you are classified as a Large Quantity Generator (LQG) and you must obtain an EPA ID number.

If you’re a Small Quantity Generator (SQG), EPA does not require an ID number, but your state might, so it’s always best to also know the state-specific requirements.

You can find instructions and forms for obtaining an EPA ID number here.  

                                 

3. Fill Out the Hazardous Waste Manifest

The Uniform Hazardous Waste Manifest is designed to meet both EPA and DOT documentation requirements for shipping hazardous waste. It contains information
about the hazardous materials being transported (classification, reportable quantity, etc.), emergency contact information, the generator’s EPA ID number, and more. If you’re not tired of reading regulatory documents yet, you can find manifest requirements and instructions in Subpart C of 49 CFR part 172.

Fortunately, EPA rolled out the Hazardous Waste E-Manifest System in 2018 to replace its previously paper-intensive process. You can learn more about how the system works at the
EPA website and create an e-manifest using the RCRAInfo site.

Keep in mind, DOT still requires that transporters carry paper copies of the manifest. If you use the e-manifest system, simply print out a copy from the RCRAInfo site. (DOT recognizes electronic signatures specifically for e-manifests.)

Common Mistakes

One of the most frequently cited paperwork violations is a failure to properly describe the hazardous material. Be sure to consult the Hazardous Materials Table for proper shipping
descriptions and classifications, along with guidance for packaging and handling requirements.

For us, the most common mistakes we see on manifests are pretty simple:

• A shipper forgets to sign the manifest. Happens more than you think!
• The manifest has the wrong package count, in which case you’ll get a call from us to resolve it.
• The manifest shows an incorrect quantity of materials in a package, such as how much of a drum is full.

4. Choose the Right Packaging

General requirements for hazardous waste shipments and packaging are covered in 49 CFR 171.2(g) and 49 CFR part 173. DOT also offers a fairly easy to read summary here.

The Hazardous Materials Table in section 3 specifies the type of packaging required for each form of hazardous waste. For some materials, such as lithium cells and batteries, you may be required to use UN performance packaging.

If that’s the case, check out this guide to performance packaging from the Pipeline and Hazardous Materials Safety Administration (PHMSA). This two-page pdf shows you how to interpret codes and markings and includes a convenient list of volume conversion factors.

Common Mistakes

One of the most common shipping mistakes we’ve seen companies make is putting their material in improper packaging. That could mean using a poly drum when a steel drum
is required, or (this one makes us scratch our heads) putting liquids in a cardboard box instead of a drum.

 

                                

5. Mark & Label Your Packages

This step provides crucial information for transporters, including orientation arrows, the nature of the waste (corrosive, flammable liquid or solid, etc.), shipper’s contact info and ID
number, hazardous material class, and more. DOT requirements for markings are listed in Subpart D of 49 CFR part 172, while labeling requirements are in Subpart E. PHMSA
also provides a handy markings, labeling, and placarding guide with general guidelines and visual examples.

While it’s important to follow the letter of the law when it comes to labeling, use some common sense, too. For instance, labels should be placed in a clear and visible
location on packages—that way, if an emergency response crew needs to get the information contained on a label, it’s quick and easy to find. Likewise, any
markings should be durable, in English, and not obscured by other markings
or labels.

Common Mistakes

There’s just one labeling mistake we see the most often: someone puts the wrong label on the wrong drum. It might seem like a minor slip-up, but the purpose of these labels is to communicate crucial information to everyone who handles your hazardous waste.

One Last Common Mistake

Here’s a word of advice that comes from years of fielding panicked calls from customers: Pay attention to the storage deadline for hazardous waste. EPA puts a limit on how much
hazardous waste you can accumulate onsite before it must be transported to a certified disposal facility. And, as you already know, shipping is hard to arrange at the last minute.

SQGs are allowed to store hazardous waste onsite for 180 days, according to 40 CFR section 262.16, while LQGs are limited to 90 days, per 40 CFR section 262.17. However,
if it’s day 89 and you suddenly realize you need to get the hazardous waste off-site tomorrow, you may not be able to find a shipping company with a suitable truck in the
area. So, we recommend you plan ahead and prearrange shipping, based on your expected hazardous waste accumulation.

Reclaiming precious metals through refining is a great way to put money back in your business… and sloppy shipping is a great way to reduce your returns. To help ensure your refining lots arrive in one safe and valuable piece, we’ve compiled a list of the top six mistakes that can sabotage your shipments and hurt your revenue.

1. Overloading your containers

We’ve seen some badly overstuffed boxes get to our dock and collapse as soon they’re unloaded. If that happens at our facility, our staff will sweep up as much of the debris as
possible to recover every ounce of your precious metal. But if it happens at another stage in transit, you could lose a fair amount of value.

Remember that freight gets handled many times as shipping trucks pass through terminals, loading and unloading cargo. If your box bursts somewhere in transit, there’s no guarantee the carrier will try to pick up every little bit of lost material.

2. Using wimpy packaging

Here’s a common theme: a customer fills a cardboard box with small parts, the box gets nicked by a forklift in transit, and parts are spilling out the bottom by the time the box arrives at our facility. This can be avoided by using metal drums or wooden crates—just don’t forget to inspect them for weak spots.

If you’re going with cardboard boxes, know that not all gaylord boxes are created equal. Forks can easily penetrate single- or double-walled boxes, so if you’re using cardboard,
make sure it’s triple-walled.

                                        

3. Stacking non-stackable pallets

Some people opt to stack pallets to save on shipping costs, since they’re using one pallet space instead of two. But if your shipment includes heavy materials and your pallets aren’t specifically designed to be stacked, you risk breaking the lower pallet and damaging your
freight.

If you’re trying to save space, do everything you can to keep your pallet compact. Try stacking an extra row of boxes on top of a pallet, or pack your boxes more densely to
eliminate empty spaces.

4. Shipping everything in your dumpster

As best you can, try to keep plain old garbage out of your refining lots—you should be shipping only recoverable materials. It’s better if a refiner can get to work without having
to first remove extraneous junk, especially if you’re getting charged by the pound for processing. Some refiners will charge higher fees and give you less metal accountability if
your lots are too diluted.

5. Playing the “mystery sender” game

This sounds like a no-brainer, but we’ve received shipments with no identifying
information. Make sure you put a name and phone number on the outside of every box. This
could be your company name or, if you’re concerned about security, the name of an individual. That way, if a box gets orphaned, someone can reach you.

If you’re shipping five boxes, each one needs a reference number and contact info.
Also, if you’re reusing gaylord boxes from another company, please remember to change the identifying info from their info to yours! Yeah, we’ve seen that mistake too.

                                          

6. Revealing the contents

Even if you’re shipping low-value material, you never want anybody to see what’s inside your shipment. If you’re sending a gaylord box full of scrap, cover the top with cardboard
and stretch-wrap the entire box to hide the contents. Consider using black stretch wrap for another layer of security.

Also, never write anything on the box that indicates high-value contents. We’ve seen people write “gold scrap” directly on their shipments, which is a great way to let thieves know what’s inside. Even worse, we’ve seen shipments come in open containers with clear plastic wrap, clearly showing the precious metal cargo. Might as well put a neon “Steal Me!” sign on there, too.

Don’t rely on a thief not understanding periodic table abbreviations. A quick Google search for “Au” and your lot could be gone before it leaves the shipping dock.