Did you know that for the majority of today’s Spray Polyurethane Foam (SPF) contractors, the job isn’t completely done until the drum is properly disposed?
Sure, most contractors know that disposal of used SPF Drums must always proceed in accordance with the foam manufacturer’s instructions. However, do they all realize that since empty drums are potentially hazardous, it’s crucial that they be handled extremely carefully and by appropriately trained team members?
Understanding the Components
SPF components are typically made up of an “A” side — polymeric methylene diphenyl isocyanate, pMDI, or MDI-based diisocyanate — and a “B” side — polyol resin, polyol-based system with smaller amounts of catalyst(s), a blowing agent, flame retardant(s) and a surfactant.
These components are often purchased and shipped as a set or system of two drums, one for the “A” side and one for the “B” side. The drums may be color-coded red or black for the “A” side, and blue or another color for the “B” side. Each drum contains shipping papers, indicating the required shipping information for that chemical, as well as any relevant hazard communication labels.
Since most SPF systems are designed to be run at a 1-1 ratio, any components remaining when the job is completed should be in the same ratio. And at the end of a job, you should be left with two empty or Partially Empty Drums awaiting disposal.
So, what are you supposed to do with these?
Let’s Look at the Regulations
The disposal of solid wastes, including those that are deemed hazardous wastes, is regulated in the United States.
According to an expert from the Center for the Polyurethanes Industry, any SPF contractors disposing of empty or partially empty drums must identify and thoroughly understand the applicable regulations that govern waste disposal.
For example, in the U.S., the Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act (RCRA) is the primary governing federal statute. The EPA declares regulations under RCRA, and these regulations impose strict requirements upon hazardous waste generators concerning waste classification, waste accumulation, treatment and disposal, recordkeeping and emergency preparedness.
In addition, states and localities can have additional requirements, so SPF contractors should always check and understand federal, state and local requirements before proceeding with disposal of waste components, foam or drums.
Finally, with SPF, it’s important to understand that there are regulatory distinctions between the terms: hazardous and non-hazardous waste. Again, always refer to the manufacturer’s material safety data sheet (MSDS) to check each component of your SPF.
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