New RCRA Exclusion for Solvent-contaminated Wipes
On July 31, 2013, at 78 FR 46448, the United States Environmental Protection Agency (EPA) promulgated a new final rule to relax hazardous waste management requirements for solvent-contaminated wipes (i.e., shop towels). Solvent-contaminated wipes that are laundered will be conditionally excluded from regulation as solid waste. Solvent-contaminated wipes that are discarded will be conditionally excluded from regulation as hazardous waste.
This rule comes after several years of consultation between the EPA and the regulated community. The purpose of this final rule is to provide a consistent regulatory framework appropriate to the level of risk posed by solvent-contaminated wipes. The aim is to protect human health and the environment, while reducing overall compliance costs. The rule will become effective at the Federal level on January 31, 2014. However, in most states and territories the exclusion will not become effective until the local waste management agency takes steps to formally adopt it.
Wipes contaminated with a solvent are one of the most common forms of waste in industrial sectors. They are used for cleaning and other purposes in industries from auto manufacture and repair to chemical processing, electronics, printing, furniture, and many others.
The EPA estimates tens of thousands of facilities use wipes as some part of their process, facilities that can benefit from this rulemaking. Managing contaminated wipes as non-hazardous waste can help facilities reduce the transport and disposal costs otherwise associated with having the wipes treated and disposed of as hazardous waste. Taking advantage of this exclusion will help minimize the amount of hazardous waste generated at a facility, which may in turn help reduce the facility’s generator status.
What Exactly Will Be Excluded
The solvent-contaminated wipe exclusions will apply to wipes that contain one or more of the solvents designated as hazardous waste in 40 CFR 261, Subpart C or D, specifically:
- The spent solvent descriptions F001 through F005 at 40 CFR 261.31 (e.g., spent acetone or spent benzene); or
- The corresponding P or U lists found at 40 CFR 261.33 (e.g., unused acetone or unused benzene).
The exclusion will also apply to:
- Wipes that exhibit a hazardous waste characteristic resulting from any of the before-mentioned solvents, or
- Wipes that exhibit a hazardous waste characteristic of ignitability when containing one or more non-listed solvents (e.g., isopropyl alcohol or ethanol).
Restrictions to the New Exclusion There are a few restrictions to the exclusion. Wipes that contain or are contaminated with solvents other than those listed in F001–F005 or the P and U lists are not eligible for exclusion. Likewise, wipes that exhibit a hazardous waste characteristic (toxicity, corrosivity, reactivity, ignitibility) due to non-listed solvents or non-solvent contaminants (i.e., oil, metal shavings, etc.) are also not eligible for exclusion. Lastly, trichloroethylene will not be afforded the exclusion in disposable wipes.
Managing Your Contaminated Wipes on Site
Whether the wipes will be laundered or discarded, the new exclusions are conditional. This means that in order to qualify for the exclusion the generator must manage the wipes in a sound manner before reuse or disposal.
The wipes may be accumulated for up to 180 days regardless of the facility’s hazardous waste generator status, and the wipes will have to be stored and transported in non-leaking, closed containers that contain no free liquids. Additionally, containers will need to be labeled with the words “Excluded Solvent-Contaminated Wipes.”
Lastly, generators must maintain documentation that includes the name and address of the laundry, dry cleaner, landfill, or combustor to which they send the wipes; some type of record to indicate that they complied with the 180-day time limit; and a description of the process used to determine there are no free liquids in the wipes.
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