Excluded-Solvent Contaminated Wipes - Environment, Health and Safety

Federal regulations were recently updated regarding the storage, recycling, and disposal of solvent contaminated wipes/rags. Clear direction for compliance with regulatory obligations for generators of excluded solvent-contaminated wipes is outlined below in the EPA guide for managing Excluded Solvent-Contaminated Wipes here at UNC.

It is recommended that each shop minimize solvent use whenever possible. If solvent use cannot be minimized and Excluded Solvent-Contaminated Wipes are generated, it is preferable to utilize laundering services in compliance with the EPA management obligations outlined below in order to recycle wipes whenever possible. If disposal solvent wipes are used, they must be managed in accordance with the requirements of the EPA below for disposal Excluded Solvent-Contaminated Wipes.

For help with establishing and managing your Excluded Solvent-Contaminated Wipes Program, please contact EHS at 919.962.5723.

Solvent-Contaminated Wipes Final Rule Summary Chart

This chart summarizes the federal regulations in regards to managing solvent-contaminated wipes under 40 CFR 261.4(a)(26), which conditionally excludes from the definition of solid waste solvent-contaminated wipes that are cleaned and reused (“reusable wipes”), and under 40 CFR 261.4(b)(18), which conditionally excludes from the definition of hazardous waste solvent-contaminated wipes that are disposed (“disposable wipes”). This summary chart is a guidance document provided by the U.S. Environmental Protection Agency (EPA). This is not a regulation and, therefore, does not add, eliminate, or change any existing regulatory requirements. The statements in this document are intended solely as guidance. Additionally, state regulations may be different from the federal program.

Summary Chart
Description	Solvent-Contaminated Reusable Wipes	Solvent-Contaminated Disposable Wipes
Regulation Citation	40 CFR 261.4(a)(26) (Solid Waste Exclusion)	40 CFR 261.4(b)(18) (Hazardous Waste Exclusion)
Description	Solvent-contaminated wipes that are sent for cleaning and reuse are not solid wastes, provided the conditions of the exclusion are met.	Solvent-contaminated wipes that are sent for disposal are not hazardous wastes, provided the conditions of the exclusion are met.
Includes	Wipes containing one or more F001-F005 listed solvents listed in § 261.31 or the corresponding P- or U- listed solvents found in § 261.33, including: Acetone Benzene n-Butanol Chlorobenzene Creosols Cyclohexanone 1,2-Dichlorobenzene Ethyl acetate Ethyl benzene 2-Ethoxyethanol Isobutyl alcohol Methanol Methyl ethyl ketone Methyl isobutyl ketone Methylene chloride Tetrachloroethylene Toluene 1,1,2- Trichloroethane Trichloroethylene (*For reusable wipes only.) Xylenes Wipes that exhibit a hazardous characteristic resulting from a solvent listed in part 261. Wipes that exhibit only the hazardous characteristic of ignitability when containing one or more non-listed solvents.
Does not include	Wipes that contain listed hazardous waste other than solvents. Wipes that exhibit the characteristic of toxicity, corrosivity, or reactivity due to non-listed solvents or contaminants other than solvents.	Wipes that contain listed hazardous waste other than solvents. Wipes that exhibit the characteristic of toxicity, corrosivity, or reactivity due to non-listed solvents or contaminants other than solvents. Wipes that are hazardous waste due to the presence of trichloroethylene.
Storage Requirements	Wipes must be accumulated, stored, and transported in non-leaking, closed containers that can contain free liquids, should they occur.
Labeling	Containers must be labeled “Excluded Solvent-Contaminated Wipes.”
Accumulation Time Limits	Generators may accumulate wipes up to 180 days from the start date of accumulation prior to being sent for cleaning or disposal.
Recordkeeping	Generators must maintain documentation that includes: name and address of the laundry, dry cleaner, landfill, or combustor documentation that the 180-day accumulation time limit is being met description of the process the generator is using to meet the “no free liquids” condition.
Condition of Wipes Prior to Transport	Wipes must contain no free liquids prior to being sent for cleaning or disposal and there may not be free liquid in the container holding the wipes. “No free liquids” condition is defined in 40 CFR 260.10 and is based on the EPA Methods Test 9095B (Paint Filter Liquids Test) or other authorized state standard.
Management of Free Liquids	Free liquids removed from the wipes or from the wipes container must be managed according to applicable hazardous waste regulations in 40 CFR parts 260 through 273.
Eligible Handling Facilities	Must go to a laundry or dry cleaner whose discharge, if any, is regulated under sections 301 and 402 or section 307 of the Clean Water Act.	Must go to a combustor regulated under section 129 of the Clean Air Act or to a hazardous waste combustor, boiler, or industrial furnace regulated under 40 CFR parts 264, 265, or 266 subpart H. Must go to a municipal solid waste landfill regulated under 40 CFR part 258 (including § 258.40) or to a hazardous waste landfill regulated under 40 CFR parts 264 or 265.
Storage at Handling Facilities	Must store wipes in non-leaking, closed containers that are labeled “Excluded Solvent-Contaminated Wipes.” Containers must be able to contain free liquids should they occur.
Management of Free Liquids by Handling Facilities	Free liquids removed from the wipes or from the container holding the wipes must be managed according to applicable hazardous waste regulations in 40 CFR parts 260 through 273.