What is IBC Reconditioning? Compliance in Collection, Triage and Reprocessing Brian P. Evoy Fibre Drums Sales, Inc. (DBA FDS Packaging, Inc.) TPSA Annual

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


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


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


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


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


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


IBC Triage(Inspection)


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


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


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


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


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


1. All placards, product labels, lanyards and others are removed.

All units will then undergo a pre-flush.



2. All markings and any graffiti are removed andlabel plates are cleaned.



3. Each unit is washed based on the last

contained content.



4. All units receive afreshwater rinse. The insides are

siphoned thoroughly. Each unit then goes

through adrying process.



5. Valve installation and

air differential testing is completed.


6. Final visualInspection and

Compliant Labeling



Cleaned and Organized Warehousing

All units built to customer specifications

Water Treatment


Water Treatment Equipment



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


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


IBC Rebottling - Refurbishing a Re-Used Cage


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


The cages are completely refurbished and readied for re-use

Receiving Inner Tanks & Preparing For Cage



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


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


IBC Remanufacturing


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


Meets all DOT (PHMSA) and EPA requirements

As Good as New

Factory sealed and Leakproofness tested inner receptacles

Reduces Liability

In Conclusion


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?????


Documents

What is IBC Reconditioning? Compliance in Collection, Triage and Reprocessing Brian P. Evoy Fibre Drums Sales, Inc. (DBA FDS Packaging, Inc.) TPSA Annual