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Solvent Contaminated Wipes - RCRA Exclusion

The Environmental Protection Agency (EPA) has two exclusions under the Resource Conservation and Recovery Act (RCRA) for managing solvent-contaminated wipes under the solid waste and hazardous waste regulations that can save facilities millions of dollars a year. Solvent-contaminated wipes include wipes, shop towels, rags, pads, or swabs made of wood pulp, fabric, cotton, polyester blends, or other materials that after being used contain a solvent that would be considered hazardous waste because it is a listed chemical or because it exhibits ignitability. Wipes contaminated with hazardous wastes other than solvents or exhibit the other hazardous waste characteristics of toxicity, corrosivity, or reactivity are not included.

The first exclusion occurs due to the EPA’S Definition of Solid Waste (DSW). Solvent-contaminated wipes that are reusable and sent for cleaning on or off site are not considered solid wastes, if the following requirements are met:

  • Wipes are stored in non-leaking, closed containers that can contain any free liquids, and are sealed when transported and labeled “Excluded Solvent-Contaminated Wipes”;

  • The wipes held in the containers mentioned above are removed from the facility within 180 days; and

  • Wipes must not contain free liquids when offered for transport.

Note that a facility using this rule is not required to accept laundered or cleaned wipes back into the same location. The exclusion applies if the wipes are laundered and sent to any facility for reuse. Many facilities only accept new wipes due to quality standards and their laundered wipes are sent to other facilities with lower grade wipe uses for reuse.

The second exclusion applies to disposable wipes that are not reusable and that will be considered solid waste and not hazardous waste. The disposable wipes that can be sent out as excluded solid waste under RCRA must meet all of the above requirements that reusable wipes must meet and must only be sent to certain types of regulated landfills or combustion facilities which include: combustors that are regulated under section 129 of the Clean Air Act or under 40 CFR parts 264, 265, or 266 subpart H, or municipal solid waste landfills regulated under 40 CFR part 258 (including § 258.40), or hazardous waste landfills regulated under 40 CFR parts 264 or 265. 

For more information on how this can benefit your facility, please contact Baron Environmental at 908-508-9000.

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