Solvent-Contaminated Shop Rags (Primer)

On July 30, 2013, EPA published the final rule on the proper disposal of solvent-contaminated shop rags and wipes. These final rules are effective January 31, 2014. We have noticed that many facilities are treating their solvent contaminated wipes as hazardous waste; resulting in unnecessary operating expenses.

Wipes contaminated with spent solvents, or if ignitable, can be managed as follows:

1. If the wipe is reusable (i.e., made of cloth) the facility can send it to an EPA approved laundry facility.

2. If the wipe is not reusable (i.e., made of paper), the facility can dispose it in a municipal landfill, a hazardous waste landfill, or an industrial incinerator.

There are some recordkeeping requirements that must be followed. The facility must document the following:

• There must not be any free liquids as determined by the Paint Filter Liquids Test (EPA Methods Test 9095B).

• The wipes must be kept in non-leaking closed containers.

• Wipes must not be stored for more than 180 days.

• Documentation must be kept demonstrating that these wipes are being managed as excluded solvent-contaminated wipes.

If the facility meets these requirements, the solvent-contaminated wipes are then excluded from the definition of hazardous wastes. In essence, the solvent contaminated wastes are treated as universal waste. There are certain exceptions. For example, trichloroethylene contaminated wipes are not part or the EPA rule exclusion.

Contact us to find out how to stay informed about rule development and proposed rules that may impact your facility operations. Contact Sam Joshi, P.E. at (215) 389-2811 if you have any questions.