IP News Monthly Issue 4

ISSUE 4

IP News

Chemical Residues: Risk and barrier to re-conditioning, re-manufacture, or re-cycling

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By Lonnie Jaycox


In last month’s Industrial Packaging News I proposed that ultimately, for the industrial packaging manufactures and users, the highest priority for a sustainability program, is to focus on diversion of these packagings from landfills.  I believe this to be true from both a long-term cost and regulatory perspective.  Extended Producer Responsibility regulations will impose both cost and regulatory burdens.

Regardless of the relative merits of recycling packaging materials, or re-using (reconditioning) packaging; one significant problem affects both these diversion strategies: chemical residues in the packages.  This is particularly a problem with some low value, hazardous materials.  When the material in the package has very high economic value to the purchaser, procedures - often quite extensive - are employed to retrieve all the product from the package.  But, with commodity chemicals, often less care is taken; and there may even be an economic advantage to make larger heels someone else’s problem.  Thus, often package re-conditioners/recyclers too often are dealing with “heavies”.  Packages with a significant amount of residual chemicals.

It needs to be noted that these residual chemicals represent environmental and safety hazards for packaging crushed or shredded for recycling, as much as for packages destined for re-conditioning.  When the packages are crushed or shredded, they no longer can perform the containment function and residual chemicals can create risks, even in the case where a recycling process will ultimately destroy the hazardous residue.  Residues are still contaminants to all downstream processes other than dedicated chemical recovery.

The most common regulations surrounding residues contain different standards for residue removal:

  • For DOT, in 49 CFR Hazardous Materials Regulations (HMR) we see requirements that a hazardous materials packaging containing a residue must be treated and transported in the same manner as when it had more material in it.  RCRA “empty” is not empty for DOT.  An “empty” packaging under 49 CFR, has never been used; or if it has been filled with a hazardous material must be “sufficiently cleaned of residue and purged of vapors to remove any potential hazard”, or; “Is refilled with a material which is not hazardous to such an extent that any residue remaining in the packaging no longer poses a hazard”.  [See 49 CFR 173.29].  There is relief from certain aspects of the HMR, for offerors of non-empty packages containing residue, both in the regulations and by Special Permits that facilitate transportation for re-conditioning, remanufacture, or re-use.  But, it must be remembered that these are exceptions to the HMR, and must be specifically followed for regulatory relief.

  • Under FIFRA regulations by EPA we see elaborate requirements for effectively removing pesticide type residues from packages based on the nature of the products.  Including triple rinsing and/or pressure washing procedures to remove hazardous residues. [See: 40 CFR Subpart H, applicable sections]

  • And finally, we have all dealt with the definition of RCRA “empty”, which is the source of much industry confusion; because it does not mean empty.  Residues are allowed under this regulation, with the package being deemed “empty” by an offeror.  RCRA does have provisions for triple rinsing for listed acutely hazardous wastes; but exceptions exist for many hazardous material residues to remain in the packages for removal from the facility where the product was used. [See: 40 CFR 261.7]


I have been involved in many cases where confusion about RCRA “empty” and DOT “empty” created significant regulatory and safety problems that were difficult to sort out to everyone’s satisfaction.  And, recently, this issue has resulted in significant safety related incidents that have regulators and industry reviewing both regulations and procedures for dealing with residual chemicals in packaging. 


For packaging manufacturers, focus on certain design characteristics that facilitate ready emptying of industrial packagings should always be kept in mind.  The more readily a user of packaging can remove all the product from it; the more value it will have for a customer; and, the more likely it will be to allow that package ready and safe entry into the systems that can divert it from landfills.  Facilitating safe and effective re-cycling, re-conditioning, re-use, and re-manufacture of packaging will result in lower long-term costs associated with programs like Extended Producer Responsibility.


However, it must be acknowledged in the industry that the best place for the removal of the chemical hazard of the contents of an industrial packaging is in the facility where the chemical is routinely used.  Appropriate equipment, trained staff, routine practice, and awareness of the nature of the hazards and the proper handling of these chemicals is most developed in the facilities where they are used daily as part of the normal work flow; and here residual materials represent economic value to the user.

Whether through a specific Responsible Container Management Program, or as part of a larger Product Stewardship Policy; efforts to reduce or eliminate hazards associated with residual chemical products from industrial packagings can reduce risks associated with personal safety, liability from downstream incidents, regulatory scrutiny, and costs associated with returned “heavies”.  An internal program to reduce residuals in outbound packages will also create more disposal options for packaging generators.  This could lead to cost reductions, particularly in an environment of greater regulatory enforcement, and possible changes in the regulations seen as necessary to improve safety.  RCRA “empty” could well be a regulatory exception that would be reexamined in light of recent incidents.  This would result in any process efforts to reduce residuals in packagings a prudent investment of effort.

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The IP News Monthly Interview

Jenni Bracken


Interview with
Jenni Bracken, Downstream Marketing Director, Cordstrap USA Inc.

Each month we interview a key player in the industrial packaging sector. For this issue, we’ve been talking to the Downstream Marketing Director for Cordstrap USA Inc., Jenni Bracken.

 

Tell us a little about Cordstrap:

Cordstrap is the world leader in the protection of cargo in transit. Our mission is to keep cargo safe – by providing solutions that ensure our customers’ products are secure on rail, sea, road and air.

With international manufacturing locations and operations in over 50 countries worldwide, Cordstrap combines an innovative product suite tailored to the needs of our customers across Chemical, Food & Beverage, & Building & Construction industries with a collaborative approach and the best quality training, application expertise and legislative insights.

Many of the world’s leading multi-national companies trust Cordstrap to secure their cargo, with CTU code compliant and AAR approved solutions for all global shipping challenges.

Check out this neat video of our proud history in cargo securing.

How long have Cordstrap been operating in the US market and how does it differ from Europe?

Our US operations opened in 2002 with facilities in Racine - our home base for our customer success and tool repair teams, along with seven distribution centers throughout North America.

We also recently established our new regional HQ in Rosemont, IL, under the leadership of our North American President – Donna McPherson.

Under Donna’s leadership, we will base every decision around one question – “why is this good for the customer?” In North America the focus will be on building a strong, consultative approach, with the customer at the center of everything that we do– and a strong infrastructure of support around them. Ensuring we deliver precisely tailored solutions, both now and in the future.

Donna has a straightforward, energetic approach. Her first question is usually “What customer problem are you solving, and how can I help?”. This focus – along with Cordstrap’s evolving products and solutions – will build ever-stronger partnerships with our North American customers.

What are the greatest challenges facing the industry over the next few years? 

As the world leader in cargo securing, Cordstrap are in constant dialogue with surveyors, insurance companies and port authorities. When questioned regarding container security, the answers were shocking. They revealed that only 2% of containers are being checked in ports – and that 25% of controlled containers are poorly secured. 60% of import containers were found to be insufficiently secured – a very worrying statistic when 65% of all container accidents are known to relate to poor securing or stuffing.

Cargo securing needs to be taken more seriously than it currently is worldwide – and with bigger ships bringing increasing container weights, stack heights and higher accelerator forces into play, securing inside containers becomes a key area of focus

Cargo securing needs to be an integral business topic from a perspective of

-        Damage Reduction & control

-        Efficiency in Cargo Handling and loading

-        Regulatory Compliance

-        Supply Chain Optimization

Customers are looking for cargo and environmental safety and ease of use when loading and unloading containers. CTU Code compliance or AAR approval is essential as well. Ultimately, cost is also a critical factor.

Cordstrap are positioned to provide customers with a certified product solution to address the need for optimal security, compliance & efficiency by our customers.

What innovations can you site as being particularly effective?

We have a great innovation in container cargo securing, a technological break-through – solution called Cornerlash®. This  is a solution developed by Cordstrap for the transport of various (non) hazardous chemicals packed in containers. The system is unique in using the strongest part of the container – the corner posts - to secure the cargo.

The development of CornerLash® was prompted by examining issues which customers face when transporting hazardous and non-hazardous products across the globe.

Suitable for many types of loads, from drums, big bags, IBCs, 50lb bags and other soft packaging, Conerlash® solution ensures cargo is secured in the safest and most efficient way possible.

Key features are:

·     Fast & Easy application – securing a container with Cornerlash® takes only 10 minutes, with lashing that is cut to length and requires no excessive preparation.

·    Optimal security – Cornerlash® uses the strongest part of the container – the corner posts- to provide optimal security for heavy loads of up to 30 tons in transit.

You have celebrated your 50th birthday and operate in over 50 locations, what is next for Cordstrap?

We are a healthy and fast-growing business. We are very positive about the future because we believe we have considerable growth opportunities within our core market.  The future for Cordstrap is a continuation of the past, a continuation of our mission to convert the world’s cargo securing to better, safer, more effective solutions. It’s a continuation of direct customer relationships, which provides tailored solutions to meet customer needs and help pave the way for future innovation. And it’s about leadership. We believe very strongly in the need for safety in cargo securing, keeping the world’s cargo safe, and making sure that the workers who are securing cargo or transporting cargo are safe. As a result, we believe Cordstrap is well positioned to continue to lead the industry globally.

 

 

Our sincere thanks to Jenni in taking part in this month's interview.