A final rule issued by USEPA on July 31, 2013 addresses the management of solvent-contaminated wipes. In the final rule, USEPA conditionally excludes from the definition of solid waste solvent-contaminated wipes that are cleaned and reused, and conditionally excludes from the definition of hazardous waste solvent-contaminated wipes that are disposed. The rules affect nearly 100,000 generators and handlers of an estimated 2.2 billion rags and wipes per year. EPA estimated in 2003 that 88% of these were reusable.
Proper management of solvent wipes has been debated since the early 1980’s. Petitions filed by Kimberly Clark (1985) and Scott Paper (1987) led to an EPA 1994 memo deferring to the States with authorized RCRA programs. Printing industry efforts toward standardization led to a 2003 proposed rule. Following a 2009 Risk Assessment, minor changes to the 2003 proposal were finalized and published on July 31, 2013. The new rules will take in effect six months from publication, on January 31, 2014.
To maintain the conditional exclusion, certain management practices must be followed:
- Store in non-leaking, closed containers
- Label containers “Excluded Solvent-Contaminated Wipes”
- Document accumulation less than 180 days
- No free liquids per Paint Filter Liquids Test (9095B)
- Document procedure employed to assure no free liquids
- Free liquids managed as solid or hazardous waste
- Document reusables sent to handler (laundry, dry cleaner) with permitted discharge
- Document disposables to permitted handler (combustor, landfill)
During accumulation, a closed container means the cover makes complete contact between the fitted lid and the rim, even if not sealed. Containers with flip-top or spring loaded lids or with a self-closing swinging door may be acceptable during accumulation. Bags may be considered closed when the neck of the bag is sealed preventing emission of solvent vapors. No container may leak free liquid. After accumulation and during transportation, a container must be sealed with rings clamped or bolted to the container.
The conditional exclusion may apply to solvent-contaminated wipes which contain listed solvents or exhibit a hazardous waste characteristic. Free liquid spent solvent is not excluded nor are wipes containing listed waste other than solvent or that exhibit a characteristic from other than solvent. Wipes contaminated with trichloroethylene are not excluded.
You should also check with your state for rules that they may have regarding solvent-contaminated wipes, since many state requirements are more stringent than the federal program. If you have any questions about RCRA Waste Determination requirements, please contact the Chicago office at 630-541-0626.