Disposal of Empty TDI Drums
Committed to Safe Handling, Storage and Disposal of Diisocyanates
Diisocyanate producers make safe handling, storing and disposing of diisocyanates an industry-wide priority. ACC member companies take great care when disposing of all waste materials—whether at their own sites or when assisting customers. Waste disposal is highly regulated at federal, state and local levels. Waste toluene diisocyanate (TDI) handling is required to be in compliance with U.S. environmental laws and in accordance with the manufacturer’s Safety Data Sheet (SDS).
When purchasing TDI or TDI products in 55-gallon steel drums, it is important to follow proper procedures and have an appropriate plan established for disposing of the drums once they are empty. Empty drums must be stored in a clean, dry, secure area until arrangements are made to dispose of them correctly. Even empty drums not properly managed can lead to many problems for the company responsible for their care. Empty TDI drums that have not been decontaminated with a neutralization solution will still contain a residue of TDI and must be handled with care.
Unused or off-spec TDI is listed as a U223 hazardous waste under Section 261.33(f) of EPA’s RCRA regulations. As a listed hazardous waste, unused or off-spec TDI requires special handling for disposal. Additionally, shipments of RCRA empty drums are subject to U.S. Department of Transportation (DOT) hazardous material regulations unless the container is completely cleaned and purged of the material so that no hazard exists (See 49 CFR § 173.29). Compliance with RCRA’s “one-inch residue” rule does not meet DOT’s standard of “cleaned and purged.” If a container is shipped with residue, then under DOT regulations all labeling, marking, packaging, and shipping paper requirements and placarding must be followed.
A common method for disposal of empty drums is to contract a professional drum re-conditioner. A state by state listing of drum re-conditioners can be obtained from the Reusable Industrial Packaging Association. Providing a Safety Data Sheet (SDS) for the TDI product along with the drum helps ensure the re-conditioner will have information on the drum’s previous contents.
Drums may also be sent to a scrap dealer, an incinerator, or a landfill but may need to be decontaminated, then punctured or crushed to prevent reuse. Instructions can be obtained from the scrap dealer or incinerator company on how to prepare the drums for transport, and refer to the manufacturer’s recommendations on how to decontaminate TDI drums as appropriate.
Regardless of the procedure used, empty all drums as defined by RCRA, 40 CFR § 261.7 before they leave the TDI user’s facility. This means that all liquid waste within the drum has been removed from the drum by the generator using common practices such as pouring, pumping, and aspirating (no free liquid can remain inside the drum). Unless TDI liquid from a partially filled drum is reused in a process, the liquid from the drum would meet the definition of a U223 hazardous waste. For closed head drums with contents that cannot be poured, there can be no more than one inch of residue in the drum, or no more than 3 percent by net weight stuck to the bottom, top, and sides. Emptying a drum until it is “drip dry” is generally considered a practice commonly employed to remove material from this type of drum.
In summary, there are three options available for disposing of steel drums that contained TDI. Disposal must be in compliance with all applicable federal, state, and local laws and regulations.
If the empty drums are sent to scrap metal recyclers or approved landfills, they may request that the drums be thoroughly decontaminated with a neutralizing solution prior to disposal. NOTE: A treatment permit may be required if the drum does not meet the definition of “RCRA empty”. Contact your TDI supplier for information on recommended neutralization/ decontamination solutions. After using a decontamination solution, carbon dioxide gas may be released during the neutralization process so often bungs are loosely applied to the drum until the drum can be destroyed. Crushing the empty TDI drums, after they are internally decontaminated, will prevent re-use.
To help ensure proper disposal of drums, consider one of the options below:
- a professional drum re-conditioner
- a professional scrap metal recycler, or
- an approved landfill that complies with all federal, state and local laws and regulations. In addition, it is important to understand whether the landfill has any special restrictions. For example, certain landfills have a ban on accepting recognizable drums and other containers over a certain size. In some cases, processors may be able to destroy the drums (i.e., using a drum crusher) and send them to a landfill. Still, sending empty drums to a landfill can pose long-term liability issues if the landfill is ever found to be contaminated. Careful diligence is warranted when using this procedure).
If requested to decontaminate a TDI drum, contact the product manufacturer for guidance.
WARNING: Empty drums should not be burned or cut open with a gas or electric torch, as toxic decomposition products may be liberated. It is also important to not allow a drum to be re-used for any purpose including storage of other liquid chemical products, trash burning, grill pits, or water collection.
TDI (CAS# 26471-62-5) is listed as a hazardous waste (No. U223) under 40 CFR § 261.33(f) of U.S. Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act (RCRA) regulations and EPA requires special handling for disposal. The residue from decontaminating a TDI spill is also classified as a hazardous waste under RCRA Section 261.33(d).
For a listing of CAS numbers for various TDI formulations, visit TDI Synonyms, Acronyms, and CAS Registry Numbers.
Resources on Disposal of TDI
- Disposal of Empty Drums Containing Polyurethane Chemicals
This poster was developed to provide general guidelines for disposal of empty drums. This file is designed to be a 2-foot by 3-foot poster, available for download in full-size, high-resolution files which are ready-to-print. (2016)
- Guidelines for the Responsible Disposal of Wastes and Containers from Polyurethane Processing
This technical bulletin is designed to help processors of polyurethane chemicals responsibly manage waste chemicals and empty containers. In particular, this bulletin focuses on chemicals used in polyurethane processing operations that may be regulated as hazardous waste. (AX-151, 2014)
- Working with TDI: What You Should Know
An easy-to-read, 6-page brochure which describes health effects, first-aid tips, and safe practices when handling TDI. (AX-202, 2012) | (Spanish)
- Guidelines for Receiving and Unloading TDI
This 38-page technical guideline provides basic principles to users receiving, unloading and handling TDI and/or various grades. (AX-188, 2014) | (Spanish) | (French)
- Guidance for Melting Toluene Diisocyanates (TDI) in Drums
This guidance provides general information on how to heat drums to melt frozen or fused TDI. (AX-364, 2012) | (Spanish)
CPI offers a variety of additional resources regarding health and safety information for diisocyanates and polyurethanes.
Visit CPI’s Products, Resources and Document Library for a complete list of resources.
Government and Other Resources
- EPA Hazardous Waste – learn about hazard waste and the regulations that govern it.
- DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) – regulates the safe movement of hazardous chemicals.
- Reusable Industrial Packaging Association (RIPA) – trade association representing over 90% of the industrial packaging reconditioning industry in North American including many manufacturers of steel, plastic and fiber drums, as well as intermediate bulk containers. RIPA members collect, clean and restore used industrial packaging and return them to service as shipping containers.
Resources for Purchase
- MDI and TDI: Safety, Health and the Environment: A Source Book and Practical Guide – by D. C. Allport (Editor), D. S. Gilbert (Editor), S. M. Outterside (Editor): MDI and TDI are polymer building blocks used in large quantities and have a variety of applications in industry. MDI and TDI are subject to stringent health and safety regulations. This book covers important topics concerning MDI and TDI and provides comprehensive coverage on the health and environmental science associated with these. Among these topics, neutralization, decontamination and disposal of DII wastes are covered extensively.
Legal notice: This document provides general guidance only; users must independently determine appropriate practice relative to their own circumstances and applicable law. Neither the American Chemistry Council (ACC), nor member companies of the Diisocyanates Panel make any warranty or representation, either express or implied, with respect to the accuracy or completeness of the information contained in this material; nor do ACC or the Panel member companies assume any liability or responsibility for any use, misuse or reliance on any information in the document. New information may be developed subsequent to publication that renders information contained herein incomplete or inaccurate. NO WARRANTIES ARE GIVEN; ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE ARE EXPRESSLY EXCLUDED