• Managing Solvent-Contaminated Wipes
  • Brittany

    Brittany Svoboda is the Technical Content Administrator at New Pig, where she is responsible for creating and editing content to help customers comply with regulations, select the appropriate products for their applications, stay safe and protect their environments.

  • Erniesays:
    02/01/2016 at 8:36 pm Reply

    Regarding labeling of drums with Solvent-Contaminated Wipes . . . please provide specifics on labeling of the drums.
    Do we only need it to say “Solvent-Contaminated Wipes”?
    Do it also need to have a “Flammable” label?

    • Brittanysays:
      02/01/2016 at 8:38 pm Reply

      Hi Ernie,

      Thanks for your comment. Under the federal exemption, you are only required to label the drums with the words “Excluded Solvent-Contaminated Wipes.” Adding the word “flammable” to the drum is not required nor is it really necessary because the wipes are excluded from hazardous waste disposal as a result of the new rule.

      Please keep in mind that some states might have more stringent labeling requirements than the EPA. You should check with your state and local authorities before making a final determination.

      Hope this information helps! Do you have any other questions about drum labeling or solvent-contaminated wipes? If so, feel free to leave another comment.


  • Diane Csays:
    05/26/2016 at 2:52 pm Reply

    How are generators meeting the documentation requirement below? What constitutes documentation?
    “Generators must document how they are meeting the “no free liquids” requirement”

    • Brittanysays:
      06/06/2016 at 11:06 am Reply

      Hi Diane,

      Thanks for your comment! To answer your question about how long to keep documentation about how you’re meeting the ‘no free liquids’ requirement – you should keep it as long as you’re generating solvent-contaminated wipes. But, documentation about the actual shipments of wipes offsite only needs to be kept for 3 years.

      Documentation can be either written or electronic and it simply needs to describe the process or processes being used to ensure that any solvent-contaminated wipes leaving the facility contain no free liquids.

      Remember that the regulation does not require you to test every wipe leaving the facility, but you must ensure that every wipe leaving the facility would pass the paint filter test, if it did happen to be tested. The documentation requirement is just your statement about how you intend to meet that requirement, which may contain statements such as:

      • “Wipes are mechanically wrung out prior to being placed in the disposal/recycling container.”
      • “Wipes are centrifuged prior to shipping.”
      • “Wipes are placed in a closed draining station prior to collection.”

      The most important parts of this statement are that (1) it reflects what your operators are actually doing to comply and (2) the method chosen is a valid way to ensure that the wipes have no free liquids when they leave the facility.

      Hope this information helps! If you have any other questions please leave another comment.


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