EPA Discusses Rag Rule
On July 31, 2013, the US EPA promulgated a new final rule to relax hazardous waste management requirements for solvent-contaminated wipes (i.e., shop towels). Under this rulemaking, solvent-contaminated wipes that are laundered are conditionally excluded from regulation as solid waste, and discarded solvent-contaminated wipes are conditionally excluded from regulation as hazardous waste.
The EPA recently held a webinar to discuss the relatively new Solvent-Contaminated Wipes Rule. The webinar was hosted by Amanda Kohler and Mary Beth Sheridan of the US EPA and attended by dozens of State regulators, industry groups, regulated businesses, and other stakeholders. During the webinar, the hosts discussed the background of the solvent-contaminated wipe waste stream and the history of this rulemaking, and then answered questions from stakeholders.
Background of Solvent-contaminated Wipes
Until the final rule was published, there was no official EPA system for managing solvent-contaminated wipes and rags. They aren’t quite covered by either the contained-in policy or the mixture rule (40 CFR 261.3(a)(2)(iv)).
In 1994 (RO11813), the US EPA made it its official policy to defer the identification of solvent-contaminated wipes as hazardous waste to EPA Regions and the states. In 2003, the US EPA proposed Federal regulations (68 FR 65586) to create a uniform national standard for managing these wipes as special wastes under Subtitle C of the Resource Conservation and Recovery Act (RCRA). The 2013 final rule created this national standard, offering conditional exclusions from RCRA for certain solvent-contaminated wipes.
The rule is currently in effect in Alaska, Iowa, and in Indian Country and other territories where the US EPA directly implements RCRA. Some authorized states, namely Pennsylvania, New Jersey, Virginia, North Carolina, Illinois, and Florida, have also adopted the rule. See this map from the US EPA.
The EPA intends to update its Frequently Asked Questions for solvent-contaminated wipe soon.
Key Takeaways from the EPA’s Webinar
- The exclusion is conditional and includes explicit instructions for managing and disposing or recycling shop towels. If handlers violate one or more of the conditions of the exclusion, the wipes become subject to RCRA regulation from their point of generation.
- The storage and containment rules are flexible and performance-based; they do not specify a type or material for storage containers. There is no quantity limit, only a 180-day time limit for accumulating solvent-contaminated wipes.
- Reusable wipes can be laundered on site, provided the on-site laundry discharges under a Clean Water Act permit or agreement.
- Mats, mops, uniforms, and other personal protective equipment cannot be managed under the solvent-contaminated wipe rule, because the EPA did not consider them under the scope of the rule.
- Handlers may not add absorbents to containers accumulating solvent-contaminated wipes.
- When wipes are co-contaminated with oil and solvents, they may be managed under the solvent-contaminated wipe rule as long as (1) the oil is not listed hazardous waste and (2) the wipes only exhibit the characteristic of ignitability (and thus do not exhibit the characteristic of corrosivity, toxicity, or reactivity).
For more information, click here for the solvent-contaminated wipes rule.
Projected Effect and Cost Savings
According to the US EPA, if this rule is implemented nationally, it will impact:
- Over 90,000 facilities generating solvent-contaminated wipes, most of them small quantity generators;
- Over 3,000 solid waste management landfills and combustors; and
- Over 300 industrial laundries and dry cleaners.
The US EPA estimates about $18 million in net waste management savings and 4 to 10 million in peripheral benefits if this rule is adopted and implemented nationwide.
Be confident your site is in compliance with the latest RCRA hazardous waste regulations, including the new rules for shop towels and developing standards for electronic Manifests! For annual training on the EPA’s core requirements for managing and storing hazardous waste on site, Lion presents the Hazardous/Toxic Waste Management Workshop in cities nationwide. An online course and Refresher online course are also available.
Seeking new management strategies or recycling options to minimize waste and cut costs? The Advanced Hazardous Waste Management Workshop also covers the RCRA rules that generators must know, with an emphasis on strategies to streamline your operations, to keep waste “out of the system” of RCRA, and to treat waste on site without a RCRA permit.
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