A roll-off box is considered a container under RCRA. A container is any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled (40 CFR §260.10). A roll-off box is a portable device. Therefore, if a roll-off box is used to store, transport, treat, dispose of, or otherwise handle hazardous waste, it is considered a hazardous waste container under RCRA (Memo, Lowrance to Ullrich; July 13, 1989 (RCRA Online # 11442)).
The memo referenced above is available in the RCRA Online Database at the following URL: