TOP-DRUMS

Trinity Operating Procedures - TOPs

TOP-DRUMS: Managing Drums

Rev: 12/06/2017

Scope: This procedure covers the policy of managing drums containing hazardous / non-hazardous ingredients (as specified in TOP-HAZCM). This procedure meets solid and hazardous waste compliance requirements for proper drum management. The term "drum" is to be construed in the broadest sense of "container" if a hazardous waste is encountered in some vessel other than a drum.

Procedure:

STEP WHO WHEN INFO TO USE WHAT TO DO

1 Maintenance Supervisor Upon receipt of hazardous material Safety Data Sheet (SDS); Hazardous material; receiver; labels on drums; National Fire Prevention Association (NFPA) label Review receiver; make sure NFPA label is filled out and affixed to every drum; store drums in holding area designated by Environmental Coordinator

2 Anyone using product from drum Whenever using a product from drum SDS; manufacturer's instructions; NFPA label Follow instructions on SDS; use product as instructed

3 Anyone using product from a drum Drum empty Empty drum; SDS; drum handling policy Inform Maintenance Engineerand/orEnvironmental Coordinator of need to remove waste container to holding area.

4 Maintenance Engineer / Environmental Coordinator Upon notification of empty container from departmental employee Empty drum; SDS; drum handling policy Seal empty drum; place drum in secured "holding area" for empty drums; assure label is still affixed to drum; if label is not secure or if legibility is doubtful, proper arrangements can be made to remove old label and make new label and affix to container.

5 Any manager or supervisor Upon need to re-order approved product SDS; drums stored in "holding area" Place order with vendor; request vendor to accept empty drums upon delivery of new order (for purposes of recycling); if vendor will not accept return of drums, notify Environmental Coordinator

6 Environmental Coordinator Upon notification from supervisor or foreman that vendor will not accept return of drums Notification Properly classify and manifest drums according to TOP-WASTE; make arrangements to have empty waste containers properly disposed of

Revision history:

Release Date	Description of Change	Owner	Approver
12/06/2017	Updated to comply with revised Quality Manual and new TOPs format.	Tim Ellis	Todd Sheppard

Documents are controlled only when viewed on-line at trinityforge.com in the original English -- printed copies or translations are not controlled documents.
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STEP	WHO	WHEN	INFO TO USE	WHAT TO DO
1	Maintenance Supervisor	Upon receipt of hazardous material	Safety Data Sheet (SDS); Hazardous material; receiver; labels on drums; National Fire Prevention Association (NFPA) label	Review receiver; make sure NFPA label is filled out and affixed to every drum; store drums in holding area designated by Environmental Coordinator
2	Anyone using product from drum	Whenever using a product from drum	SDS; manufacturer's instructions; NFPA label	Follow instructions on SDS; use product as instructed
3	Anyone using product from a drum	Drum empty	Empty drum; SDS; drum handling policy	Inform Maintenance Engineerand/orEnvironmental Coordinator of need to remove waste container to holding area.
4	Maintenance Engineer / Environmental Coordinator	Upon notification of empty container from departmental employee	Empty drum; SDS; drum handling policy	Seal empty drum; place drum in secured "holding area" for empty drums; assure label is still affixed to drum; if label is not secure or if legibility is doubtful, proper arrangements can be made to remove old label and make new label and affix to container.
5	Any manager or supervisor	Upon need to re-order approved product	SDS; drums stored in "holding area"	Place order with vendor; request vendor to accept empty drums upon delivery of new order (for purposes of recycling); if vendor will not accept return of drums, notify Environmental Coordinator
6	Environmental Coordinator	Upon notification from supervisor or foreman that vendor will not accept return of drums	Notification	Properly classify and manifest drums according to TOP-WASTE; make arrangements to have empty waste containers properly disposed of