The US Environmental Protection Agency’s (EPA) new Federal Solvent-Contaminated Wipe Rule became effective January 23, 2014. It provides a consistent regulatory framework for handling solvent-contaminated disposable and reusable wipes, which presently is addressed by individual state policies.
The rule reduces compliance costs by excluding wipes that are managed according to the rule from the hazardous waste regulations. Since the rule is “de-regulatory,” each state must adopt the rule for it to become effective; until a facility’s state agency formally adopts it, the current state policy must be followed. Several states have already adopted the rule and many more will do so throughout 2014.
The rule modifies hazardous waste-management regulations to exclude solvent-contaminated wipes that are cleaned at industrial laundries or dry cleaners and reused as a solid waste and wipes sent for disposal to a municipal solid waste landfill or solid waste combustor will not be classified as a hazardous waste. To be excluded, the wipes must only be contaminated with certain solvents and specific procedures must be followed during generation and disposal.
EPA defined a “solvent-contaminated wipe” as a shop towel, rag, pad or swab, and cloths commonly used in some automatic blanket wash systems that after use or after cleaning up a spill, contains a solvent that would be considered hazardous waste either because it is specifically identified or “listed” in the hazardous waste regulations or because it exhibits the characteristic of ignitability (flashpoint <140oF).
There are two important exclusion conditions to be aware of:
• Disposable wipes used with trichloroethylene are not eligible for the exclusion because trichloroethylene may pose a significant risk to human health and the environment when disposed in a lined landfill. These must be managed as a hazardous waste.
• Reusable wipes need to be sent to laundries or dry cleaners whose discharge, if any, are regulated under the Clean Water Act. Disposable wipes need to be sent to regulated combustors (e.g., incinerators that burn garbage), municipal solid waste landfills, or hazardous waste landfills.
To be excluded under the rule, the following requirements must be met:
• Labeled and Non-Leaking Containers must be used during collection, storage, and disposal. The words: “Excluded Solvent-Contaminated Wipes” must be on all containers.
• Closed Containers must be used during the collection or accumulation of the towels in the production, maintenance, or other areas where they are used. EPA defined “closed container” as a lid being in complete contact with the container except when adding or removing wipes.
• Sealed Containers must be used when accumulation containers are full, when wipes are no longer being accumulated, and during transportation. The container should have a locked lid, be a non-leaking laundry bag for reusables, or a garbage bag for disposables. These containers must also be labeled.
• Accumulation Time is the time a facility has to send a container of solvent contaminated wipes for cleaning or disposal after the first wipe enters the container, and is limited to 180 days. Records must be maintained to document compliance.
• No Free Liquids may be present in solvent-contaminated wipes at the point they are being sent for cleaning on site, or being sent off site for cleaning or disposal. In order to meet the performance standard, the wipes must pass EPA’s “Paint Filter Liquids Test.”
• Documentation must be kept on the name and address of the destination facility (laundry, combustor, or landfill), how the 180-day accumulation time limit is being met, and a description of the process used to meet the “no free liquids” condition.
More information, please feel free to contact the EHS Department at EHS@printing.org or 1-800-910-4283, ext. 794.
Gary Jones is vice president of EHS Affairs and Caitlin Seiler is manager of EHS Affairs at PIA.