Chemical Container Disposal for Non-Pest Trades

Why this matters

Pest control shops are drilled on container disposal because their whole product line is registered pesticides. Pool, cleaning, plumbing and HVAC shops use plenty of the same kind of product (pool chlorine, algaecide, mildew remover, disinfecting cleaners) and many that are not pesticides but are just as corrosive (muriatic acid, drain openers, acid coil cleaners). The empties end up in the van's trash bag, and two things go wrong there: a pool shock bucket with residue starts a dumpster fire, or a rinse gets poured somewhere it should not. The whole decision comes down to reading one line on the label and doing one rinse properly.

Safety first: the three ways an empty container hurts someone

Handle every chemical empty as if it were full until it is rinsed.

• Mixing. Residue from a chlorine product (sodium or calcium hypochlorite) meeting residue from an acid (muriatic acid, acid coil cleaner, some drain openers) or ammonia releases chlorine or chloramine gas. Never rinse two different products' containers into the same bucket, never nest one empty inside another, and never bag them together. If you smell chlorine while handling empties, stop, move upwind and into fresh air, and do not go back until the area has aired out; a smell that fades is not an all-clear, because chlorine dulls the sense of smell.
• Heat and fire. Calcium hypochlorite (granular or tablet pool shock) is a strong oxidizer. Residue in a pail, mixed with oil, organic debris, other chemicals or a small amount of water, can heat up and ignite, and these pails have started fires in vans, sheds and dumpsters. Keep cal hypo empties dry and alone until rinsed.
• Splash. Acids and strong alkalis (drain openers, coil cleaners) burn skin and eyes even as residue. Rinse wearing chemical splash goggles and the gloves the product's safety data sheet specifies, outdoors, with the container below face height. If it gets in an eye, flush with clean water for 15 minutes and then get the person to a clinician with the product label.

Step 1: Find out which kind of product it is

Look at the label for an EPA Registration Number ("EPA Reg. No." followed by digits). That number decides which rule controls the container.

• Registered pesticide. Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), any product that claims to kill, control or repel a pest, including bacteria, algae and mold, must be registered with EPA. In non-pest trades that catches pool chlorine and bromine sanitizers, algaecides, many mildew and mold removers, and disinfecting cleaners. For these, the label is law: "It is a violation of Federal law to use this product in a manner inconsistent with its labeling" appears on the label, and the storage and disposal section is part of the labeling. Whatever the label says to do with the empty container is what you are required to do, and states enforce it through their pesticide agencies.
• Not a registered pesticide. Muriatic acid sold for pH adjustment, drain openers, most coil cleaners without a disinfecting claim, descalers, sealants and adhesives. Their labels follow consumer product or workplace labeling rules, and the disposal directions are advice, not FIFRA law. The container is governed by the federal hazardous waste empty-container rule (40 CFR 261.7) and your state and local solid waste rules.

Step 2: Empty it completely

Use every bit of the product for its intended purpose. Pour, drain and scrape; for liquids, let the container drain upside down into the application (the pool, the mix tank, the drain being treated) until the flow drops to drips.

Why. For a non-registered product, a container that has been emptied by normal means and holds only a thin residue meets the federal "empty" standard, and an empty container is not hazardous waste whatever it held. The definition and its limits are spelled out in a sibling card; see related: Aerosol Cans and Pressurized Cylinders. A container with product sloshing in it is the product itself, in a different place, and leftover product is the shop's waste to classify. See related: Building the Shop Waste Stream Inventory.

Step 3: Rinse it, using the label's method

Most registered pesticide labels direct a triple rinse for small rigid containers, in standard wording:

1. Empty the remaining contents into the application or mix tank and drain for 10 seconds after the flow begins to drip.
2. Fill the container one-quarter full with water and recap.
3. Shake for 10 seconds.
4. Pour the rinse water (the rinsate) into the application or mix tank, or store it for later use. Drain for 10 seconds after the flow begins to drip.
5. Repeat steps 2 to 4 two more times.

Some labels allow a pressure rinse instead, and some say "do not reuse or refill this container; offer for recycling or dispose of in trash". Do what yours says.

For non-registered corrosives, the same triple rinse is the sensible default, with two adjustments. For a concentrated acid, add the rinse water to the container slowly and expect some heat. For a cal hypo pail, use a large volume of water, filling it rather than splashing a little in, because a small amount of water on concentrated oxidizer is the case that heats up.

Where the rinsate goes. Back into the use. Pool chemical rinsate goes into the pool the product was for, which is application according to the label. Drain opener rinsate goes down the drain line it was used to treat. Coil cleaner rinsate goes into the sprayer for the next coil. Never onto the ground, into a gutter or a storm drain; storm drains run untreated to creeks, and a discharge there is a Clean Water Act and local ordinance problem. See related: Wash Water and the Storm Drain Rule.

What breaks if you skip the rinse. The container carries the hazard into whatever it touches next: a recycling truck, a dumpster, the van floor.

Step 4: Dispose of the rinsed container where the label and the hauler allow

A rinsed, dry, capped container usually goes one of three ways:

• Recycling, where the label says "offer for recycling" and a program will take it. Many curbside programs refuse containers that held pesticides; agricultural container recycling programs that take rinsed HDPE pesticide jugs exist in many states, often through county extension or a dealer.
• Trash, where the label permits it, the container is empty and rinsed, and the hauler does not exclude it.
• Household hazardous waste or a hazardous waste vendor, for a container you could not empty or rinse, such as a jug of hardened product or a can of uncured solvent adhesive.

Puncture or crush rinsed rigid containers if the label directs it, so nobody reuses them. Cured sealant and caulk in a tube is a solid and generally goes in the trash; a tube or can of liquid solvent-based product is leftover product, not an empty. See related: Paint, Solvent and Finish Waste.

Worked example: one gate, two containers

The gate is Step 1: does the label carry an EPA Registration Number? A pool route tech ends a Friday with empties in the van, and the first two resolve oppositely.

Container A: a one-gallon algaecide jug. The label carries an EPA Reg. No., so it is a registered pesticide and its directions are binding. The storage and disposal section reads: "Nonrefillable container. Do not reuse or refill this container. Triple rinse container promptly after emptying. Then offer for recycling if available or puncture and dispose of in a sanitary landfill, or by other procedures approved by state and local authorities."

The tech triple-rinses it at the last stop, three rinses at one-quarter full with pool water, shake 10 seconds, drain 10 seconds after the drip each time, and pours each rinsate into that customer's pool, which is the application. The jug is dry by evening. The county runs an agricultural container recycling day monthly; the shop has a bin for rinsed pesticide jugs, labeled, and the jug goes in it. Because the label said "promptly", the rinse happened at the job, not three days later at the shop when the residue had dried.

Container B: a one-gallon muriatic acid jug used to lower the pool's pH. No EPA Reg. No.: muriatic acid sold for pH adjustment is not a registered pesticide, so the label's disposal suggestion is advice and the container falls under the empty-container rule and the local hauler's rules. The tech drains it into the pool at the deep end per the acid's directions, then triple-rinses at the truck, goggles and acid gloves on, adding water slowly. The rinsate goes into the pool. The rinsed jug is HDPE, the local recycling program takes HDPE, and it goes in the shop's recycling bin.

What the gate changed. Both containers got the same physical rinse. The difference is who decides the ending. For A, the label decides, and if it had said "do not recycle, dispose of in trash", the curbside recycling bin would have been use inconsistent with labeling. For B, the shop and its hauler decide within the empty-container rule.

The third container the tech almost bagged. A cal hypo shock pail with a crust of granules in the bottom. It carries an EPA Reg. No. (calcium hypochlorite pool sanitizers are registered), so its label controls: "completely empty", "rinse thoroughly" and then recycle or trash. The tech's habit had been to drop these pails in the van trash bag with the day's other empties, which is the mixing-and-fire scenario. This time it got emptied into the pool, filled with water, swirled, dumped into the pool, repeated, and left upside down to dry before it went anywhere near other containers.

What would change it. Some states regulate pesticide container disposal beyond the label, and California treats some rinsed containers and rinsates under its own hazardous waste rules; your state pesticide agency's container page says. A plumbing shop with a half-used jug of sulfuric acid drain opener it no longer stocks does not have an empty container at all: that is leftover product for a hazardous waste vendor or a household hazardous waste program that accepts business waste.

How to verify you got it right

Look in the van trash at the end of a week. Every chemical container in it should be dry, capped and rinsed, and no pool shock pail should be in a bag with anything else. Spot-check three registered-product labels against where their empties actually went. And ask a tech where the rinsate from the last acid jug went; the answer should be a pool, a drain line or a sprayer, never the street.

References

• Federal Insecticide, Fungicide, and Rodenticide Act, 7 U.S.C. 136j (use inconsistent with labeling)
• 40 CFR 261.7, residues of hazardous waste in empty containers
• Your state pesticide regulatory agency's container disposal guidance
• See related: Pool and Cleaning Chemical Incompatibility in Storage; Reading a Safety Data Sheet: The Sections That Matter