It’s been a decade in the making, but the EPA has recently issued a final rule regarding the management of certain solvent-contaminated wipes. Whether your facility has reusable shop towels, disposable wipes, or even absorbent mats, this rule may affect the way you manage these items onsite and how to recycle or dispose of them. The rule becomes effective January 31, 2014.
What Is a Wipe?
The rule defines a wipe as “a woven or non-woven shop towel, rag, pad or swab made of wood pulp, fabric, cotton, polyester blends or other material” [40 CFR 260.10].
Traditionally, wipes are used to apply a liquid or to remove contaminants from a surface, but the EPA clarifies that wipes may also be used to clean up spills. That means that absorbent mat pads used to clean up any of the solvents affected by this regulation could be managed under this conditional exclusion.
What Is a Solvent-Contaminated Wipe?
Solvent-contaminated wipes include wipes that:
- Contain one or more F001 through F005 listed solvents included in 40 CFR 261.31, or the corresponding P- and U-listed solvents included in 40 CFR 261.33
- Exhibit a characteristic from 40 CFR 261, Subpart C, when the characteristic is from a solvent listed in Part 261
- Exhibit the characteristic of ignitability in 40 CFR 261.21 due to the presence of one or more solvents not listed in Part 261
Wipes that are contaminated with trichloroethylene are not eligible for management under this exemption. Wipes that are contaminated with other hazardous materials, for example, corrosive liquids or other hazardous liquids that are not specifically listed are also ineligible.
How Are Solvent-Contaminated Wipes Managed Under This Rule?
To be eligible for the conditional exemption, both reusable and disposable wipes must be stored, handled and managed properly:
- All solvent-contaminated wipes must be kept in non-leaking, closed containers.
- A container is considered closed when there is complete contact between the fitted lid and the rim.
- Bags and containers with covers operated by foot pedals may meet this definition for onsite storage, but not for transport, recycling or disposal.
- The container must be labeled “Excluded Solvent-Contaminated Wipes.”
- The wipes must not be accumulated longer than 180 days. (The accumulation start date must be marked on the container to verify this.)
- At the point of transport, the wipes may not contain any free liquids as determined by a paint filter liquids test (EPA Test Method 9095B).
- Centrifuging, mechanical wringing, screen-bottom drums, microwave technology and vacuum extractors may be used to remove free liquids from wipes.
- Generators must maintain documentation that they are managing excluded solvent-contaminated wipes.
How Do You Dispose or Recycle Solvent-Contaminated Wipes?
If the wipes contain only the exempted solvents, and if they have been managed properly, they are eligible for exclusion. The spent wipes can now be laundered or disposed of in one of the following ways:
- Reusable wipes must be sent to laundries or dry cleaners that are regulated under Section 301 (effluent discharge restrictions) and 402 (permitting requirements,) or section 307 (indirect discharge to a POTW) of the CWA. The laundry or dry cleaner must manage any free liquids in accordance with RCRA hazardous waste requirements.
- Disposable wipes may be sent to landfills regulated under 40 CFR 258, 264 or 265. Disposable wipes may also be incinerated in licensed combustion units.
- Any free liquids discovered by a launderer, landfill or incinerator must be managed in accordance with RCRA hazardous waste requirements.
Does the EPA Have Any More Information?
Absolutely! Check out this page with all the info about the new rule and this diagram to see if your state has adopted the new rule yet.
You tell us: How does the new rule affect you? Let us know in the comments section below!
16 Comments
KennyRsays:
09/30/2013 at 8:56 amDoes 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 pmYes, 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 pmDid we have a part number for the pre-printed labels? Thanks!
Karensays:
04/29/2014 at 4:06 pmHi Tina,
We do – it’s product SGN1090 and it will be available for sale starting this Thursday.
Jensays:
05/01/2014 at 9:53 amTina,
You can now purchase SGN1090 – the Solvent-Contaminated Wipes Label – on newpig.com!
Thanks
Jen
Tim Msays:
02/18/2015 at 9:09 amI 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 pmHi 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 amYou 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 amJanet,
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 amIs 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 amHi 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
Shawn Dumassays:
05/10/2017 at 1:42 pmI like the printed stickers. SGN1090
It would help us if a place was provided to indicate the accumulation start date to help ensure we are under the 180 Days.
It would be a nice add to also see ” No Free Liquids ” on the stickers as a polite reminder in the work space.
Any indication that printed bags for the F-Listed Solvents will be coming soon?
Brittanysays:
05/10/2017 at 4:36 pmHi Shawn, thanks so much for these suggestions. I have already shared them with our signs and labels product manager.
I will also ask about the printed bags for the F-Listed Solvents.
Stay tuned!
Thanks,
Brittany
Brittanysays:
05/12/2017 at 9:26 amShawn,
We currently offer two bags for solvent-contaminated wipes: BAG114 and BAG115. These can be used to store and transport wipes contaminated with F-listed solvents.
If this is not what you’re looking for please let us know and we will get you what you need.
Thanks,
Brittany
Joysays:
10/25/2018 at 6:37 amMy company plans to use a collection bags inside of another sealed container for disposal of the paper wipes we use. The chemical that we use on the wipes is a flammable. My question is does that container need to be able to be grounded??
Karensays:
11/15/2018 at 12:23 pmHi Joy, thank you for your comment!
OSHA has regulations for the use, storage and transfer of flammable liquids, but there is nothing specific to the transfer of flammable solids like a solvent-soaked wipe. However, fugitive vapors can still be present when wipes are being transferred into or out of a collection container, so it is still a good idea to ground the container. Plastic bags have an inherent static charge. To help minimize the static potential when using a bag to line a collection container, put a small hole in the bag to allow the grounding clip to make complete contact with the metal container. To further minimize hazards, place the container in a well-ventilated area with at least 50% relative humidity.
Please let us know if you have any other questions.
Thanks,
Karen
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