• EPA Passes Solvent-Contaminated Wipes Management Rule
  • Karen

    Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 100 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) trainer and hazmat technician. She also serves on the Blair County, Pa., LEPC and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenh@newpig.com.

  • KennyRsays:
    09/30/2013 at 8:56 am Reply

    Does New Pig sell any solvent contaminated wipes waste containers? I’m looking for appropriate metal cans for accumulation, and labeled bags for throwing contents into dumpster at the plant. Help!

    • Karen Hamelsays:
      10/02/2013 at 7:22 pm Reply

      Yes, New Pig sells latching lids that can be placed on top of steel drums to help you comply with the requirement for solvent-contaminated wipers to be stored in closed containers. We have lids to fit anything from a 5-gallon pail up to an 85-gallon drum/container.

      We are currently working on pre-printed labels that can be attached to drums, bags and other containers that will contain the correct verbiage and allow you to record your accumulation start date, as well as bags that will be correctly labeled.

  • Tina Crumsays:
    04/29/2014 at 12:59 pm Reply

    Did we have a part number for the pre-printed labels? Thanks!

    • Karensays:
      04/29/2014 at 4:06 pm Reply

      Hi Tina,

      We do – it’s product SGN1090 and it will be available for sale starting this Thursday.

  • Tim Msays:
    02/18/2015 at 9:09 am Reply

    I understand the rule is that the container (satellite) must be marked with “Excluded Solvent-Contaminated Wipes.”
    The question comes in the disposable drum liner, does the bag you put in the regular trash need to be marked with the same wording? EPA is really grey on this part of it. I do not see why they would require this since once it goes in the trash it goes to the landfill and nobody will ever see it again. Suggestions?

    • Karensays:
      02/19/2015 at 12:00 pm Reply

      Hi Tim,
       
      Our suggestion would be to label the bag properly so that you are in full compliance with the regulation.
       
      If you are using a disposable drum liner inside your properly-labeled collection container, it technically does not need to be labeled while it is onsite, as long as it remains inside the collection container which is labeled. However, if the drum liner will be taken out of the properly labeled collection container and used to store and/or transport the solvent-contaminated wipes to the landfill, it does need to be properly labeled.
       
      The regulatory citation that addresses the proper labeling of the ‘trash bag’ for disposable wipes is 40 CFR 261.4(b)(18). “Solvent-contaminated wipes, when accumulated, stored, and transported, are contained in non-leaking, closed containers that are labeled “Excluded Solvent-Contaminated Wipes.” (italics added.) Thus, when the bag hits the dumpster must be properly labeled because the hauler will transport it to the landfill.
       
      Note also that it’s not quite as simple as just tossing the bag of spent wipes in the trash and forgetting about it. In addition to having no free liquids [40 CFR 261.4(b)(18)(i)] and proper labeling for the bag, 40 CFR 261.4(b)(18)(v) mandates that generators to keep a record of the name and address of the landfill receiving the wipes, as well as some other recordkeeping requirements.
       
      If the wipes are reusable and will be going to a launderer, 40 CFR 261.4(a)(26)(i) still requires wipes to be “accumulated, stored, and transported” in non-leaking closed containers that are labeled “Excluded Solvent-Contaminated Wipes.”
       
      Please let us know if this helps you. And if you have any more questions, don’t hesitate to call us at 1-800-HOT-HOGS or email me at karenh@newpig.com.
       
      Thanks,
      Karen

  • Janetsays:
    04/20/2015 at 11:44 am Reply

    You talked a lot about transportation to a laundry facility. Do you know if the solvent-contaminated wipes fall under any hazmat class if transportation is by common carrier (Can’t get a clear answer from anyone)

    • Karen Hamelsays:
      04/23/2015 at 8:31 am Reply

      Janet,

      Like any hazardous material that is being transported, solvent-contaminated wipes need to be evaluated for hazards before shipment.

      Thanks,
      Karen

  • Ranaesays:
    05/20/2015 at 10:38 am Reply

    Is a manifest required to transport solvent soaked rags to the laundry? Also, What are the rules (RCRA, CAA, OSHA)and BMPs for containing vapors from these materials?

    • Karen Hamelsays:
      05/21/2015 at 8:29 am Reply

      Hi Ranae, thanks so much for your comment.
       
      Because the DOT (not EPA) regulates transportation of hazardous materials, DOT rules would still apply to shipments of greater than a reportable quantity of a solvent contained in the rags or wipes. Remember that to qualify for the RCRA exemption, the wipes need to be able to pass the paint filter test and have no free liquids. Because of these two requirements, most wipe shipments should not exceed a reportable quantity and should be able to be made without a manifest.
       
      To help contain vapors and to qualify for this RCRA exemption, solvent-contaminated rags and wipes must be kept in closed containers since they are onsite. This Best Management Practice (BMP) is similar to RCRA’s closed container requirements (40 CFR 264.173), Subpart CC regulations [40 CFR 264.1086(c)(ii)] and Clean Air Act (CAA) requirements.
       
      For OSHA compliance, a closed container would be an administrative control and would be a good choice to help avert the health risks of inhaling solvent vapors. A closed container also helps to avoid a fire safety risk that may be presented by an open container of rags or wipes containing flammable liquids.
       
      Thanks,
      Karen

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