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Andy J
Andy James is the Sustainability Manager at New Pig, where he is responsible for New Pig Training. In that role, he has the rare opportunity to bring together his decade of experience in research and messaging for Fortune 500 clients with his lifelong passion for education and motion design. Andy is also a Course Author and Instructor at The Pennsylvania State University, where he teaches a master's course on sustainability-driven innovation for the College of Earth and Mineral Sciences.
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4 Comments
Peter Glaesmansays:
10/06/2015 at 1:52 pmWhat is typically used as, “description of the process the generator is using to meet the “no free liquids” requirement”?
Thanks
Brittanysays:
10/09/2015 at 10:58 amHi Peter,
Basically, if an inspector came to your facility and wanted documentation on how you are ensuring the wipes you’re managing under the new solvent-contaminated wiper management rule aren’t sent away for disposal with free liquids in them, you are required to show them something that explains this. A couple ways to rid wipes of free liquids include centrifuge, a gravity drain and physically wringing out the wipes. It doesn’t usually matter how you get the free liquids out of the wipes, just that you do before sending to a launderer or landfill.
Please leave another comment if you have any further questions.
Thanks,
Brittany
Jamessays:
01/11/2016 at 8:39 pmSo if in the documentation, we indicate that our method of meeting “no free liquids” is “mechanical wringing,” would that suffice?
Considering a site only has a few excluded solvent contaminated wipe drums, before disposal we just have to wring them out to ensure no liquid is sent.
Brittanysays:
01/12/2016 at 8:45 pmHi James,
Thank you for your comment!
Mechanical wringing is a valid method to help ensure that your solvent-contaminated wipes have no free liquids. As part of your documentation, you may want to include a copy of your SOP or any other written guidelines, training materials, etc., that are used to train workers to wring the wipes.
The “no free liquids” requirement applies to wipes that are ready to leave the facility for recycling or disposal. So, you wouldn’t necessarily have to wring them at each collection point. You could wring them at a central location – as long as it is done prior to the wipes leaving the facility. Just remember to keep the collection containers closed and properly labeled throughout the process. Also note that any liquids that you reclaim throught wringing the wipes are not exempt and need to be properly managed.
Do you have any other questions about solvent-contaminated wipes? If so, just leave another comment below!
Thanks,
Brittany
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