When is a hazmat container deemed “RCRA Empty?”

The EPA prescribes three different “emptiness” standards that are necessary and sufficient to avoid hazardous material removal regulations. One is simply for “hazardous waste,” another for “acute hazardous waste,” and a third for “compressed gas hazardous waste.” Part of the challenge with deeming a container "empty" is that you must determine whether removal of the original waste (or its subsequent management) doesn’t in itself produce a hazardous waste. An example might be the residual mixture of waste and cleaning solvent (aka rinsate) left from a triple-wash regimen.