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How EPA Rules on Solvent-Contaminated Wipes Save You Time and Money

Kevin Webber - Oct 23, 2018 7:00:00 AM

Solvent-Contaminated-RagsManaging shop towels and disposable wipes is a common burden for many facilities, but are you wasting money by treating all your rags like hazardous waste?

Although any contaminated wipes, rags or towels are subject to legal management requirements, the Environmental Protection Agency (EPA) has conditionally excluded many solvent-contaminated rags and materials from the solid and hazardous waste regulations. Given that fact, how can your facility save time and reduce waste management costs by adhering to EPA rag rules?

Use the information below to navigate the legal regime for solvent-contaminated wipes in Alabama, which has adopted EPA rules and enforces them through the Alabama Department of Environmental Management (ADEM)

Do you operate in another state? Check the EPA state regulation resource to find out which legal framework applies to your facility.

What types of solvent-contaminated wipes are excluded?

For the purposes of EPA regulations, a wipe covers all types of cloths and rags that are commonly used in industrial contexts, including whole-cloth shop rags, disposable towels and any type of reusable wipe.

Those materials become a solvent-contaminated wipe when their use leads to being soiled with a solvent listed in the F-List, and some listed in the P-List or U-List. In that case, rags that would normally be considered hazardous or regulated waste because they exhibit hazardous characteristics are excluded from those regulations—as long as the characteristic results from a specifically excluded solvent (or if the only hazardous characteristic is ignitability).

If a contaminated wipe contains other types of hazardous waste or exhibits hazardous characteristics from non-solvent contamination, it won’t be excluded and must be treated as regulated or hazardous waste.

A fully knowledgeable and certified hazardous waste management provider is the best way for most facilities to properly monitor and categorize their contaminated rags and wipes.

Steps to properly handle your solvent-contaminated reusable wipes

Once you’ve properly identified and categorized your contaminated rags and reusable wipes, the following ADEM requirements must be strictly followed for those wipes to remain excluded:

  • All solvent-contaminated reusable wipes must be stored in liquid-proof, sealed containers that are kept closed unless wipes are being added or removed
  • Storage containers must be able to hold free liquid and must be labeled “Excluded Solvent-Contaminated Wipes”
  • Contaminated wipes may be stored for up to 180 days before they must be sent for proper cleaning and re-use
  • When sent for cleaning or transported off-site, all free liquid must be removed from the storage containers and managed in accordance with applicable regulations for that substance

As a waste generator, you’re required to maintain the following documentation related to the management of your excluded solvent-contaminated reusable wipes:

  • The name and address of the partner or facility that performs the cleaning or laundering of your excluded reusable wipes
  • Documented proof that you’ve adhered to the 180-day storage limit
  • Documented verification that all free liquids have been removed before transportation, and a complete description of the process used by your facility and its partners to achieve the same

Free liquid documentation must include, at minimum, the name of the person verifying the process including time and date, and the volume of free liquid removed from each container.

Your facility is responsible for ensuring all waste liquid is managed according to regulations, so it’s important to work with fully certified waste management and cleaning providers who can guarantee compliance.

Steps to properly handle your solvent-contaminated disposable wipes

Requirements for managing disposable wipes are very similar to those for reusable wipes, up to the point of transportation from your facility.

To adhere to ADEM regulations, your excluded disposable wipes must:

  • Not contain any amount of trichloroethylene
  • Be stored and transported in leak-proof containers capable of holding free liquid, properly labeled as containing “Excluded Solvent-Contaminated Wipes,” that are kept closed except when necessary to add or remove wipes
  • Be stored for no longer than 180 days, and have all free liquid removed and managed accordingly before transport

Working with a qualified waste management provider is the best way to ensure your waste pipeline is compliant, including in the storage and transportation of solvent-contaminated disposable wipes.

As a waste generator of disposable wipes, you’re required to maintain the following documentation:

  • The name and address of the facility receiving your solvent-contaminated disposable wipes, whether a landfill, combustor or other
  • Documented proof that you’ve adhered to the 180-day storage limit

You must retain separate documentation about free liquid presence and disposal for three years after the wipes were generated, including:

  • A full description of the process you’ve used to ensure no free liquids remain in the storage containers before they’re transported
  • The date and time of free liquid verification for each container, including the name of the person who verified
  • A record for the amount of free liquid removed from each container

The Benefits of Compliance

Once you’ve established a compliant management stream for your solvent-contaminated wipes and rags, and ensured you’re partnering with cleaning and disposal providers who can guarantee their own compliance, your facility will be in good standing where regulations are concerned.

By avoiding the more arduous steps often required when managing regulated hazardous waste, you can save time and money, while still enjoying the convenience of disposable and reusable cleaning materials.

Topics: Hazardous Waste

Kevin Webber

Kevin Webber

Articles written by Kevin Webber who is one of the partners at TriHaz Solutions.

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