While the Environmental Protection Agency (EPA) was considering the solvent-contaminated wipe regulation, one of their concerns was allowing flexibility while minimizing the health and environmental impacts that these wipes presented. The final rule reflects their belief that both can be accomplished and that proper management begins well before the wipes hit the dock for laundering or disposal.
To be eligible for the exemption, both reusable and disposable solvent-contaminated wipes must be managed properly during their lifecycle. That means that while they are onsite at facilities, during transportation, and when they are laundered, dry cleaned, incinerated or land disposed, wipes must be handled according to the standards outlined in the regulation.
The definition of “wipe” includes absorbent mats. This opens up some opportunities for facilities that use absorbents to pick up solvent leaks, spills and overspray.
Containers and Labeling
Facilities that manage various forms of hazardous wastes are most likely familiar with the EPA’s closed container regulation that requires any container holding hazardous waste to be kept closed when wastes are not being added to or removed from the container. Solvent-contaminated wipes must be managed in the same manner.
According to the preamble of the regulation “closed containers serve to minimize emissions, prevent spills and reduce the risk of fires.” Because the solvents that are eligible for exemption under this standard are flammable, managing wipes contaminated with these solvents in closed containers is an appropriate practice that helps keep workers, the facility and the environment safe.
Because it could be inconvenient or impractical to completely seal a container after each wipe is added, during accumulation, a container is considered closed under this standard “when there is complete contact between the fitted lid and the rim.” When the container is full or when it is being readied for transport, it must then be completely and properly sealed.
To help facilities that may not generate large quantities of solvent-contaminated wipes, the regulation is performance-based and no single style of container or storage method is specified. Some examples suggested for onsite wipe storage include:
- Open-head drums with lids
- Other types of open-head containers with lids
- Containers with covers opened by a foot pedal
- Bags, provided they can meet the requirements of the standard
To help keep solvent-contaminated wipes segregated from other waste streams, containers must be properly labeled with the words “Excluded Solvent-Contaminated Wipes.” Facilities may use preprinted labels and bags with this verbiage, or they may hand-write the information on the container. The accumulation start date must also be marked on the container to ensure that wipes are not being accumulated at the generator’s site for more than 180 days.
Free Liquids
When the EPA was analyzing the impact of solvent-contaminated wipes on the environment, one of the parameters considered was that a majority of wipes that are landfilled are barely damp, and in some cases are mostly dry. The fact that, for the most part, the wipes weren’t “dripping” minimizes their potential to leach into landfills and cause pollution problems.
As the exemption was being considered, the EPA wanted to prevent containers full of liquid spent solvents with only a wipe or two added from entering landfills under the solvent-contaminated wipe exemption – because liquid wastes present a much larger leaching hazard than “dry” wastes. To ensure this, at the point when solvent-contaminated wipes are being transported off of the generator’s site, the wipes must have no free liquids.
Generators can use the Paint Filter Liquids Test (SW-846, Method 9095B) to determine if the wipes being sent for laundering, incineration or disposal meet the “no free liquids” criteria. This test method was chosen because many states already use it to test materials that will be disposed of in municipal solid waste landfills.
Facilities can use a variety of techniques to ensure that wipes will meet the Paint Filter Liquids Test. Wipes that are centrifuged, mechanically wrung, vacuum extracted or placed in screen-bottom drums to drain typically meet the requirements of the test.
Generators must document how they are meeting the “no free liquids” requirement as part of the recordkeeping protocol for this standard. Free liquid spent solvents that are removed from wipes are not eligible for the exemption and must be managed accordingly under EPA’s hazardous waste regulations in 40 CFR 260-273. Liquid spent solvent waste may also count toward a facility’s monthly RCRA generator status.
Properly managing solvent-contaminated wipes helps to keep the facility safer by minimizing the chance for wipes to present a slip and fall hazard, creating indoor air quality issues and contributing to a fire. It is also the first step in allowing facilities to claim the EPA’s exemption for this waste stream and minimize disposal and recycling costs.
You tell us: Still have questions about this reg change? Let us know what you’re struggling with in the comments section below so we can help!
4 Comments
Erniesays:
02/01/2016 at 8:36 pmHello,
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 pmHi 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.
Thanks,
Brittany
Diane Csays:
05/26/2016 at 2:52 pmHow 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 amHi 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:
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.
Thanks,
Brittany
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