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COMPLIANCE SECTION

Solvent-Contaminated Industrial Wipes: Proposed Rulemaking

The United States Environmental Protection Agency (US EPA) has issued a proposed rule that would allow for conditional exclusions for solvent-contaminated industrial wipes (such as reusable shop towels, rags, disposable wipes and paper towels) from hazardous waste and solid waste definitions. The proposed rule was published in the Federal Register on 11/20/03 and is available for review at the US EPA's website at: http://www.epa.gov/epaoswer/hazwaste/id/solvents/wipes.htm. The US EPA anticipates that up to 164,000 facilities will be impacted by the proposed rule.

Specifically, US EPA is proposing the following:

To conditionally exclude from the definition of hazardous waste disposable industrial wipes that are contaminated with hazardous solvents and are going to disposal (disposable industrial wipes).
To conditionally exclude from the definition of solid waste reusable industrial shop towels and rags that are contaminated with hazardous solvents and are sent for laundering or dry cleaning (reusable industrial wipes).

There are some conditions for these exclusions, however, which are described in the table below:

Table A: Conditions Applicable to Disposable Solvent-Contaminated Wipes
Activity/Issue	Disposing in Licensed Non-hazardous Waste Landfill	Managed at Municipal Waste Combustor
Material Accumulation and Management	Must accumulate, store and manage the solvent-contaminated wipes in a non-leaking covered container.	Same as to left
Saturation of Wipes	Must ensure that the solvent-contaminated wipes are "dry", meaning they contain no more than five grams of solvent or they have been treated by solvent extraction.	Must ensure that solvent contaminated wipes do not contain free liquids or have been treated by solvent extraction
Solvents not eligible for the exemption	Must ensure that the wipes do not contain any of the following 11 listed spent solvents which the US EPA has determined may pose adverse effects to human health or the environment went sent to a landfill. These solvents are: 2-nitropropane, methyl ethyl ketone (MEK), pyridine, cresols (o,m,p), chlorobenzene, trichloroethylene, nitrobenzene, methylene chloride, benzene, carbon tetrachloride, and tetrachloroethylene (PCE).	Not applicable
Transport Requirements	Must transport the solvent-contaminated wipes off site in containers designed, constructed, and managed to minimize solvent loss to the environment and labeled "Excluded Solvent Contaminated Wipes."	Same as to left

Table B: Conditions Applicable to Reusable Solvent-Contaminated Wipes
Activity/Issue	Sending to Laundry or Dry Cleaning Facility
Material Accumulation and Management	Must accumulate, store and manage the solvent-contaminated wipes in a non-leaking covered container.
Saturation of Wipes	Must contain no free liquids or must have been treated by solvent extraction.
Transport Requirements	Must transport the solvent-contaminated wipes off site in containers designed, constructed, and managed to minimize solvent loss to the environment.
Free Liquids	If the laundry finds free liquids, they are to either remove the free liquids and manage them as hazardous waste or return the wipes containing free liquids to the generator.

If you require assistance in understanding the impacts of this rule to your operations, please contact Emily Rynders or Dave Strayer at the Payne Firm at (513) 489-2255 or via e-mail at ear@paynefirm.com or dcs@paynefirm.com.

Updated 11/26/03