Compliance Guide: Excluded Solvent-Contaminated Wipes

1. Compliance Overview

The Excluded Solvent-Contaminated Wipes Rule sets standards for how to store, manage and transport solvent-contaminated wipes. The purpose of the EPA Wiper Rule is to help keep solvent out of landfills.

Below we discuss key components of the standard:

A. Does the Solvent-Contaminated Wipes Rule Apply to My Facility?
B. Wipes Storage Containers
C. 180 Day Accumulation
D. Documentation
E. How to prove no free-standing liquid on containers

A. Does the rule apply to our towels or wipes?  

The Wiper Rule applies to any solvent-contaminated wipe or towel used or stored at your facility. It does not apply to wipes or towels that contain hazardous waste other than solvent or exhibit the characteristics of toxicity, corrosivity, or reactivity due to contaminants other than solvents, such as metals.

The type of towel does not matter in the determination of the rule applicability.  What matters is the solvent that is on the towels, or if the towels have the characteristic of ignitability after use.

If your towels do not come in contact with any “part 261” listed solvents (shown below) or have the characteristic of ignitability, they do not fall under the wiper rule.

(From EPA Wiper Rule Summary)

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
• Isobutyl alcohol
• Benzene
• Methanol
• n-Butanol
• Methyl ethyl ketone
• Chlorobenzene
• Methyl isobutyl ketone
• Creosols
• Methylene chloride
• Cyclohexanone
• Tetrachloroethylene
• 1,2-Dichlorobenzene
• Toluene
• Ethyl acetate
• 1,1,2- Trichloroethane
• Ethyl benzene
• Trichloroethylene (*For reusable wipes only.)
• 2-Ethoxyethanol
• 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.

B. Storage Containers

Wipes must be contained in non-leaking, closed containers. Containers must be labeled “Excluded Solvent-Contaminated Wipes.”

Solvent-Contaminated Wipes Label – Free Template

The containers must be able to contain free liquids, should free liquids occur. At the point of transport for cleaning or disposal, the solvent-contaminated wipes and their containers must contain NO free liquids.

You cannot use open tubs anywhere in your facility for solvent-contaminated towels, but may use them for red general purpose towels. The rule states that containers must be closed and labeled while wipes are accumulated. When the containers are full they must have no free liquids and be sealed.

You are not required to keep a cover on clean product.

Free liquids from the towels or wipes must be managed according to applicable hazardous waste regulations outlined by the EPA.

C. 180 Day Accumulation

Wipes may be accumulated for up to 180 days prior to being sent for cleaning or disposal. This 180-day clock begins the date the first solvent-contaminated wipe is placed in the container.

The rule is not prescriptive in how you document the 180 days or the method you use to comply with the no free liquids requirement.

A date on the label is not required – it is just a good way to track the 180 days. Accumulation date record keeping is the generators requirement. (see the documentation below for more).

D. Documentation

You must maintain documentation that you are managing excluded solvent-contaminated wipes and keep that documentation at your site.  

ITU AbsorbTech statements with delivery frequency can be used as documentation.

E. How to document there is no freestanding liquid in the solvent-contaminated wipes

You may use any method of removing solvents to the degree that there is no free liquid accumulating in the container (drum) to be used for transportation.

Our customers use a variety of methods to prove there is no free-standing liquid, including:

• Small containers at the point of use, transferred to larger accumulation and shipping containers
• Good material handling practices – hand wringing prior to putting towel in any post use container
• Good material handling practices – limiting the amount of liquid used (pumps or sprays vs. dip to apply solvents used in cleaning)
• Screen bottom drums, with or without drains
• Screen top drums
• Allowing towels to sit with no screening and then transferring to another container.
• Mechanical separation using a centrifuge, or rollers
• A few may even use the more aggressive method of mechanical wringing.

The important part is that you document the method used and how you know that it is effective.  The paint filter test is low tech and can be done by anyone.  Visual observations and documentation are also acceptable methods.  EPA has stated that they do not expect every towel to be tested, so some type of periodic tests or observations are acceptable for them.

As your partner, ITU AbsorbTech will communicate on a regular basis any concerns with compliance that we would observe while in your facility or once the towels arrive at ours.

For additional information, please review the final rule summary chart.