News Blog Posts Tagged as Silver

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.

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.

A 5-STEP GUIDE TO MAXIMIZING RECOVERY & RETURNS

You know precious metal fines lurk in every corner of your shop. You scour your work surfaces, clean out your sink traps and even tear up the carpeting every few years, sending it all to a refiner and hoping for a worthwhile return.

But are you doing everything you can to recover that valuable “bonus” metal? Here are five steps to ensure you’re getting value from every square inch of your manufacturing facility.

1. Don’t leave money on the bench.

Maximizing your refining returns starts with maximizing your collection of precious metal debris—in bench sweeps, floor sweeps, polishing dusts, ultrasonic sludge, and other areas.

Here are some tips for capturing as much precious metal as possible:

• Designate vacuum cleaners specifically for collecting bench
and buffer sweeps, so the concentration of precious metals
is not diluted with other debris. Make sure the vacuums use
HEPA filters, which can easily be sent to a refiner.

• Install commercial sink trap systems designed to recover
fine particulates from wastewater.

• Cover wooden floors, which have cracks that easily trap and
hold precious metal fines. Carpets or linoleum flooring work
well, since they can be sent to a refiner for metal recovery.
Consider using carpet remnants in areas that produce large
quantities of dust, like in front of the buffer—you can send out
remnants easily and more often than carpeting.

• Replace wooden bench tops with nonporous material. And
when it’s time to replace the bench, send the old one to the
refiner. Or, if you prefer to keep the wooden top, periodically
sand down the top layer and collect the resulting wood dust.

• Filter solutions from ultrasonics, steamers and plating units.

In Jewelry Metals: A Guide to Working with Common
Alloys, Jim Binnion suggests using a coffee filter to strain used
solution into a container, then using paper towels to wipe the
remaining sludge out of the solution tank. Be sure to include
the coffee filter and paper towels with your sweeps.

• Place floor mats at the exits of work areas that generate
a lot of dust, to collect precious particles from the soles of
shoes. The mats can then be sent out for refining.

• Remember that masks, gloves, aprons, and shop towels can
all collect precious metal fines. Rinse or wash them regularly
in dedicated sinks with filtration systems, and be sure to include them in your refining lot when it’s time to replace them.

2. Invest in professional equipment.

Consider investing in specialized dust collectors and precious
metal recovery systems to maximize your capture of superfine
filings and sweeps. This equipment also helps keep your work
areas clean.

These systems range from compact bench dust collectors to
semi-enclosed work chambers, table-top polishing cabinets,
and high-capacity dust collectors with powerful suction and
ultrafine filters. Recovery systems that are adaptable to various
vacuum units can be more cost-efficient for smaller jewelry
manufacturers. Remember that all vacuum filters, along with
buffing wheels, can be sent to a refiner.

Sometimes, sourcing outside help to collect debris can be
cost-effective. For instance, if you’re not ready to incur the cost
of carpet replacement, you can hire a carpet cleaning service
to do a deep clean and give you the residue

3. Home in on your best sources.

Evaluating your internal systems can help you identify areas
where precious metal collection could be improved. One way
to do this is by segregating material collection into separate
streams and monitoring the results that come back from the
refiner. Are you capturing more or less metal in, say, your
polishing stations or dust collectors? Once you’ve identified
underperforming areas, consider investing in equipment or
processes to improve collection.

Don’t forget the human piece of this equation. It’s crucial to train
your employees in proper collection practices, to ensure they
don’t do things like mopping the floors and dumping wastewater down unfiltered drains. Everyone on the manufacturing floor should understand their impact on, and responsibility for, recovering precious metal debris.

4. Segregate precious metals.

Segregating metals makes your refiner’s job easier and produces a better return. Mixed metals and materials require extra steps in refining, which can result in higher processing costs for the refiner and a smaller payment percentage for you.

• Keep sweeps containing gold and silver separate from
sweeps with platinum group metals (platinum, palladium
and rhodium).

• Segregate higher-grade bench sweeps from lower-grade
floor sweeps—as the precious metal percentage goes
down, so does your return. For instance, you could have
98% gold content in high-grade sweeps, diluted down to
90% by mixing with a low-grade lot. Because it’s more
difficult to separate out the precious metals, the value of
your lot is reduced.

• Remove ferrous metals such as iron and steel from your lots
using high-power rare earth magnets.

• While larger manufacturers may designate separate parts
of their facilities for different types of metal, this isn’t an
option for some smaller shops. In that case, it’s a good idea
to do a deep cleaning as you switch from one metal to the
next, to avoid contamination. Store the debris separately,
adding to the designated lots each time you clean.

Segregating lots by metal types is not always cost-efficient for
small manufacturers, since the fees for processing individual
lots may be greater than the returns. For larger-volume sweeps,
however, it makes good sense to segregate.

5. Don’t get lost in transportation.

While this might sound obvious, we’ve seen sweeps containers
arrive in less than ideal condition, putting the contents—and
the customer’s return—at risk. Make sure containers are tightly
sealed, and consider covering cardboard boxes with plastic
wrap. (We’ve received gaylord boxes that were punctured in
transit and leaking precious materials.) Some manufacturers
ship refining lots in metal drums with serialized tags and
security devices, to ensure the containers stay closed and the
contents are accounted for.

While it’s a good idea to post weights on the outside of each
box or container, avoid writing things like “gold sweeps” or
“high-value lots” (yes, we’ve seen that, too.) For security purposes, it’s better not to tell people what’s inside your containers.

Remember that sweeps containing hazardous materials are
subject to transport regulations. Be sure to work with reputable
transport companies that can help you identify hazardous
materials and abide by the regulations, to protect not just your
sweeps, but also your business.

BONUS: 

Recover more. Worry less.

Recovering your precious metals since 1919.

1-800-556-7296

Our warmest congratulations to John King who was this year’s recipient of The Precious Metals Association of North America, Jack Gannon Industry Leadership Award.

Fantastic award ceremony held at the Capitol Hill Club in DC.

A wonderful opportunity to recognize the many career accomplishments of great colleague and friend.

 2018 Jack Gannon Industry Leader Award