what is ibc reconditioning? compliance in collection, triage and reprocessing brian p. evoy fibre...
TRANSCRIPT
What is IBC Reconditioning? Compliance in Collection, Triage
and Reprocessing
Brian P. EvoyFibre Drums Sales, Inc.
(DBA FDS Packaging, Inc.)
TPSA Annual ConferenceMobile Riverview Plaza Hotel – Mobile, AL
February 6, 2013
Brian J. BilyeuCropland Containers, Inc.
Goal of Presentation
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
We want to communicate to everyone in the Agricultural Chemical Industry that sending empty totes to Reprocessors is:
Safe
Efficient and
Environmentally sound
AGENDA
1. Compliance with local and federal regulations and guidelines for empty bulk containers – IBC’s
2. IBC (Intermediate Bulk Container) Collection
3. Triage of IBCs
4. IBC Reprocessing – Inspection & Reconditioning
5. Water Treatment
6. IBC Rebottling, Remanufacturing & Recycling
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Educate ALL Emptiers – Empty “Means” Empty
We have ALL Emptiers sign a Tote Return Form
An “Agreement between IBC Refurbishes and Emptiers”
An “Empty IBC Certification” Form
The Reprocessor Assumes No Ownership of Any Container Unless All of Terms & Conditions of All Tote Return Forms Are Met
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Break it Down for the Emptier
We Train our staffs to point out the most
important terms and conditions of all
agreements with ALL Emptiers
Legally Empty
Reusable
Consequences of NON-Compliance
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Empty IBCs – Prior to Pick-up
We Request pictures representing the units that they
are wishing to be retrieved
Pictures enhance communication and reinforce tote
return forms
Doing this helps reduce the number of “Junk” or
“Heavy Units” shipped by the Emptier
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Empty IBC Certification
Triple Rinsing - "P-list" products specifically listed by name in
40 CFR 261.33 (e), EPA says the packaging is empty
only "if the packaging...has been triple-rinsed using a solvent
capable of removing the product, or has been cleaned by another
method shown to achieve equivalent removal.“
Triple Rinsed
EPA defines triple rinsing in 40 CFR 165.1
P-listed products require Triple Rinsing
All Triple Rinsed containers need to be marked or punctured
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
We emphasize the importance of Triple Rinsing…
“EMPTY” Applies to ALL Totes
Treat ALL Units Equally when referring to “EMPTY”
Empty IBC RCRA Empty IBC
RCRA Definition 40 CFR 261.7 (b)(1)(iii)(B) (B) No more than 0.3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is greater than 119 gallons in size
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
IBC Triage(Inspection)
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Triage Raw IBCs Correctly
Employees are trained on what to do with ALL totes being received that DO NOT meet an established “Empty” standard
IBC’s are unloaded off trucks, graded for condition as cutters, washers, heavies or scrap and recorded by type
“REJECT” stickers are used on the front valve side marking plates to identify any NON-Compliant heel and scrap totes before being moved to the quarantine area
This applies to all Hazardous & Non-Hazardous last contained IBC’s
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Rejected Units
We Designate an area for ALL rejected units
Ideally, it is a diked space
All units are marked as “Quarantined”
To assist with best record keeping:
We take digital pictures of ALL units showing
the date and time
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
We ALWAYS refer to these Non-Compliant heavy totes as “Product Shipped in Error Being Returned to Original Shipper and Owner of the Product”
IBC Reconditioning
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
IBC Inspection and Reconditioning
IBC’s are inspected for excessive residue and damage upon receipt
Serial numbers are recorded where appropriate
Missing or damaged component parts are recorded
Digital pictures are taken of any units that are triaged & categorized
All non-compliant units are immediately placed in quarantine
All washers are readied for IBC reconditioning
IBC’s are cleaned on the exterior, removing labels, unless otherwise specified by customer:
Chemical, heat gun, high-pressure hot water spray or steam
IBC’s are pre-rinsed with water whenever appropriate
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
IBC Inspection and Cleaning
IBC’s are cleaned on the interior and exterior: Hot caustic or chemical solution, or cold or hot high
pressure water
Interior & Exterior Washes – Both Fresh & Re-used cleaning options
Many utilize final steam or clean water rinse
Air drying and siphon or vacuuming
All fittings and bottle inspected
Air Differential Leakproofness Test
All passed or successfully tested IBC’s are given a final inspection
IBC’s are compliantly marked for Hazardous or Non-Hazardous
Non-Food Grade Re-use
We compliantly destroy any reconditioned units that fail the air test
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
1. All placards, product labels, lanyards and others are removed.
All units will then undergo a pre-flush.
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
2. All markings and any graffiti are removed andlabel plates are cleaned.
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
3. Each unit is washed based on the last
contained content.
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
4. All units receive afreshwater rinse. The insides are
siphoned thoroughly. Each unit then goes
through adrying process.
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
5. Valve installation and
air differential testing is completed.
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
6. Final visualInspection and
Compliant Labeling
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Cleaned and Organized Warehousing
All units built to customer specifications
Water Treatment
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Water Treatment Equipment
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Water Treatment
Solutions for solids & liquids are vast
Wastewater is a moving target and no two process waters are alike
Reprocessors utilize different chemistries when processing wastewater depending on the composition of the generations
Reprocessors must comply with local laws and local Water Reclamation Authorities for discharging
Reprocessors submit samplings to their regional Water Reclamation Authorities on a continuous basis as determined by local authorities
EHS Personnel audit Reprocessor’s facilities frequently and all have varying expectations
The chemistries and the processes are ever evolving but the goal is always Compliance
What is IBC Rebottling?
Benefits of IBC Rebottling
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Inner receptacle is determined scrap while cage in left is good re-usable condition
No cross contamination of previous products
No further UV degradation of plastic
Resets the DOT 2.5 year life
Upon Receiving the IBC the bottles are graded. Any bottle that is brittle, cut, punctured or stained beyond reuse will be
compliantly destroyed The inner receptacles are cut and bailed or shredded into grind The bailed or ground plastic is sold to compliant vendors that reproduce non
food grade items such as corner protectors, drain tile or pallets.
IBC Rebottling
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
IBC Rebottling - Refurbishing a Re-Used Cage
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Cleaning label plates
All original product labels and any markings are destroyed
Adhesive or graffiti removed from cage and marking plates
High Pressure Hot Wash of cage
Cleaning of plastic corner protectors
Repairing bent or damaged cages
Replacing or tightening hardware on the cages
Cleaning and straightening out top bars before reinstalling
Painting or touching up where ever oxidation or rust is evident
IBC Cage Repair
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
The cages are completely refurbished and readied for re-use
Receiving Inner Tanks & Preparing For Cage
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
IBC Rebottling - Six Sided IBC Bottle Inspection
When receiving new replacement bottles (inner receptacles) for use in IBC reprocessing operations A six-sided visual inspection must be performed by a plant
employee on each bottle after it is removed from the delivery truck.
Scrutiny of all four sides, the top and bottom of the bottle.
The purpose is to check for damage caused in transit that may result in the bottle being unusable
Any damage is immediately reported to a Supervisor & quarantined
All employees are trained to execute the 6 sided inspection and adhere to a written training SOP
Rebottled - Repaired IBC
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
This activity is specific to a single manufacturer’s composite
components
The manufacturer of the cage and the inner tank are the same
IBC Remanufacturing
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
IBC Remanufacturing
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
The activity is specific to a cross-bottled or hybrid IBC, where
different manufacturer’s composite component parts are used
The manufacturer of the inner receptacle is not the same as the
manufacturer of the cage
Benefits of a Completed New Rebottled IBC
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Meets all DOT (PHMSA) and EPA requirements
As Good as New
Factory sealed and Leakproofness tested inner receptacles
Reduces Liability
In Conclusion
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13
Industrial and Agricultural Chemical Companies are using more and more Reconditioned and Rebottled Composite Blow Molded IBC’s as they are excellent containers
When handled properly, IBC’s are proven capable of multiple Re-uses
RIPA Members comply with all Local, State and Federal Regulating Agencies including: DOT (PHMSA), EPA and OSHA
We encourage you to use RIPA members to collect and reprocess or recycle your empty IBC’s
We welcome any opportunities and are ready for building a sustainable business partnership with your Industry
Thank you for this opportunity and for your
attention.
Questions?????
TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13