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As
an EHS manager, you have to make sure that your workers handle these rags
safely, and you also must ensure their proper management for reuse or
disposal.
In 2013,
the EPA published a rule that allows some flexibility for managing
solvent-contaminated wipes.
Note. Check with
your state environmental agency to see if your state has adopted the
Solvent-Contaminated Wipes final rule.
You Can Toss or Wash Wipes,
If …
If you go
through the waste determination process and figure out that the wipes are a
solid or hazardous waste, and you decide to toss them, you can’t just throw
them in the trash. If hazardous, you must contract with a treatment, storage,
and disposal facility (TSDF) and a hazardous waste transporter (among other
storage requirements) before you send them off. Make sure you don’t treat
them yourself unless you want to be classified as a TSDF.
But here
is where the federal rule provides you with some flexibility:
Solvent-contaminated wipes that are determined to be hazardous are exempt
from the definition of hazardous waste (and therefore can be thrown out),
provided certain conditions are met concerning container management, a time
limit, free liquids, recordkeeping, and the disposal facility to which the
wipes are sent.
The
key here is the solvent. If after you use the wipe, if it contains a
F001–F005-listed solvent or its corresponding P- or U-listed solvent (check
40 CFR 261.31 and 40 CFR 261.33 to see if the solvent you use is a listed
hazardous waste), it may be eligible for the exclusion from the definition of
hazardous waste. In addition, you may be eligible for the exemption if (1)
the solvent exhibits a hazardous characteristic resulting from being listed
or (2) if it exhibits only the hazardous ignitability characteristic because
of solvents that are not listed wastes. Just make sure that there are no free
liquids in the wipes themselves or in the container holding them and that
your wipes are not hazardous because of the presence of trichloroethylene.
Wipes with trichloroethylene are ineligible for the exclusion from the
definition of solid waste and must be managed as a hazardous waste.
The rule
also provides flexibility should you decide to clean and reuse your wipes.
Solvent-contaminated wipes sent for cleaning and reuse are exempt from being
solid wastes provided certain conditions are met concerning container
management, a time limit, free liquids, recordkeeping, and the laundry or
dry-cleaning facility to which the wipes are sent.
So, here’s
what to do if you’ve decided that the best option for managing your
solvent-contaminated wipes is to get them exempt from EPA’s definition of
solid (nonhazardous) and/or hazardous waste.
Step 1. Contract with an
eligible laundry or landfill.
If your
solvent-contaminated wipes are excluded from the solid waste definition, they
must be sent for cleaning and reuse to a laundry or dry cleaner whose
discharge, if any, is regulated under the Clean Water Act.
Solvent-contaminated
wipes that are sent for disposal but are excluded from the definition of
hazardous waste must be sent to a landfill that is either a municipal solid
waste landfill or a hazardous waste landfill. Other options are to send the
wipes to a municipal waste combustor or other combustion facility or to a
hazardous waste combustor, boiler, or industrial furnace. Wherever you send
them, make sure that the facility is following the regulations applicable to
it.
The
following Steps 2 through 5 apply to both the solid waste and hazardous waste
exclusions.
Step 2. Set up containers.
Follow
these instructions for containers used to accumulate, store, and transport
solvent-contaminated wipes.
- The
wipes must be contained in nonleaking, closed containers.
- The
containers must be labeled “Excluded Solvent-Contaminated Wipes.”
- The
containers must be able to contain free liquids should free liquids
occur.
- The
container must be sealed with all lids properly and securely affixed to
the container and all openings tightly bound or closed to prevent leaks
and emissions when any of the following occur:
- The container is full.
- When
the solvent-contaminated wipes are no longer being accumulated.
- When the container is being transported.
Step 3. Observe time limits
for accumulating solvent-contaminated wipes.
As a
generator of solvent-contaminated wipes, you may accumulate the wipes for up
to 180 days from the start date of accumulation for each container before
being sent for cleaning or disposal.
Step 4. Say no to free
liquids.
The
solvent-contaminated wipes must contain no free liquids at the point of being
sent for cleaning or disposal.
Note:
Any free liquids removed from the solvent-contaminated wipes or from the
container holding the wipes must be managed according to the applicable
hazardous waste regulations.
Step 5. Keep good records.
As a generator,
you must maintain at your site documentation that contains:
- Name and
address of the laundry, dry cleaner, landfill, or combustor that is
receiving the solvent-contaminated wipes;
- Documentation
that the 180-day accumulation time limit in is being met; and
- Description
of the process you are using to ensure the solvent-contaminated wipes
contain no free liquids at the point of being transported for disposal.
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