This document discusses recent changes to US hazardous waste regulations. It summarizes that saccharin waste is no longer considered hazardous, and carbamate waste standards have been removed. Regulations for academic laboratories and e-manifesting were also revised. The solvent wipe exclusion conditionally excludes solvent-contaminated wipes from hazardous waste regulations if they meet certain requirements like a 180 day accumulation time limit and disposal as non-hazardous waste. The document provides details on the solvent wipe rule requirements and options.

1. Brian Martin, CHMM, PMP Consulting Environmental Scientist, Ameren Services
REGFORM Hazardous Waste Conference
November 5, 2015

2. Saccharin
• Removal of saccharin and saccharin salts
from hazardous waste list.
• Sweet relief for some food and beverage
producers.
• It is no longer necessary to manage
saccharin-containing waste as hazardous
waste.

3. Carbamate Waste
• Carbamate waste is subject to Land
Disposal Restrictions
• No chemical standards available to
calibrate lab instruments. Without
standards, Many carbamate compounds
“unanalyzable.”
• Remove carbamates from table of
Universal Treatment Standards.
• Allow BDAT, combustion, chemical
oxidation, biodegradation, carbon
treatment.

4. Academic Laboratories
• Revisions to Academic Laboratories Rule
• Provides miscellaneous corrections and
clarifications to the original rule.

5. e-Manifest Rule
• Establishes framework to allow e-Manifests
to replace paper multi-part manifests.
• Users may opt out of the system and
continue to use paper.
• It will still be necessary to carry a printed
copy of the electronic manifest with
shipments of hazardous wastes that are also
DOT hazardous materials.
• e-Manifests not available yet.

6. Miscellaneous
Corrections/Clarifications
• Technical corrections and clarifications to
hazardous waste regulations

7. Solvent Wipe Exclusion
• Conditional exclusion
from hazardous waste
rules
• Final rule 31July 2013
 40 CFR 261.4
 (a)(26) reused wipes
 (b)(18) disposable
• Not effective in
authorized states until
adopted

8. Solvent Wipes that Qualify
• “Shop towel, rag,
pad, or swab”
contaminated with:
 F001-F005 or
corresponding P- or U-
listed solvents
 TCLP solvents
 Unlisted but ignitable
(only) solvents
Wipes cannot be
contaminated with:
corrosives
reactives
 non-solvent TCLP
materials such as
○ Cr, Cd, Pb, Hg, Ag
 Will disqualify wipes
used on some wet
coatings, inks &
sealants

9. Accumulation Requirements
Time limit:
May accumulate “up to 180 days from start date of
accumulation for each container prior to being
sent” for disposal/cleaning
No separate storage area timeframes
No free liquids in container (paint filter test)
 “…at the point of being transported for disposal or
cleaning”
Non-leaking closed container, marked
“Excluded Solvent-Contaminated Wipes”

10. Closed Containers
Hazardous Waste Rules Solvent Wipe Rule
40 CFR 265.173(a)
Container must be “closed”
– EPA Closed Container
Guidance:
• For solvent-contaminated wipes
without free liquids:
“…complete contact between
the lid and the rim all the way
around the top” pg. 11
40 CFR 261.4(a)(26)(i)
 “…container is considered closed
when there is complete contact
between the fitted lid and the rim…
 …when wipes are no longer being
accumulated or when the container
is being transported, the container
must be sealed with all lids properly
and securely affixed to the
container and all openings tightly
bound or closed sufficiently to
prevent leaks and emissions”

11. Disposal/Laundry Requirements
Disposable Wipes (cannot
contain trichloroethylene)
Reusable Wipes
• Regulated municipal
(MSW) or hazardous
waste landfill or
• Regulated municipal,
hazardous waste, or BIF
combustor
• Laundry or dry cleaning
facility
– Any wastewater discharge
must be CWA-regulated
– State guidance documents
generally already required
CWA regulated discharges

12. Other Disposal Options
Under this rule, generators are allowed to:
 Continue managing qualifying wipes on-site and
off-site as fully regulated hazardous waste, or
 Manage wipes on-site under conditionally
excluded waste rules, but send them to a RCRA
TSD facility. A viable option if:
○ Company-specific disposal policy or practice dictates
TSDF disposal, or
○ Sanitary landfill or BIF operator does not accept
conditionally exempt solvent wipes
- Kansas Tech. Guidance Doc. HW-1995-G2 lists 18 KS
municipal landfills that can accept disposable wipes

13. Paperwork
No hazardous waste manifest required
DOT compliance
Virgin pre-moistened wipes are generally
shipped as ORM-D Consumer Commodity.
Do used solvent wipes need shipping papers?
 Some used wipes may be “solids containing
flammable liquids, n.o.s.”
 Depends on solvent
 See 49 CFR 172.102, Special Provision 47

14. Paperwork
Recordkeeping for conditional exemption:
Name and address of receiving facility
Description of process used to ensure no free
liquids at the point of being transported
Documentation of compliance with 180 day
time limit
Can take many forms, such as: service contract or
invoices that describe frequency of pickup, log of
container start dates, or accumulation start date
labels on each container. EPA preamble pg. 46459.

15. State Adoption
Authorized states can choose whether to
adopt this federal exclusion
 In effect in Illinois, Indiana, Ohio
 Indiana allows labeling as “Excluded Solvent-
Contaminated Wipes” or “other words indicating the
contents of the container.”

16. Environmental Protection
EPA risk assessment work for MSW landfill
and combustor disposal was extensive
○ First proposed 2003
○ More detailed risk assessment and Notice of Data
Availability released in 2009
 Comments were extensive, due to battle between industrial
laundries and disposable wipe manufacturers over market
share
○ Risk assessment updated in 2012. TCE risk re-
evaluated.
 Result: lined sanitary landfills and MSW combustors prevent
migration/releases of solvent in used wipes (other than TCE)

17. Solvent Wipe Take-Aways
Consider whether the conditional
exclusion is worth the effort
 Not all wipes qualify
 For low volume shops, 180 day time limit may be less than your
present satellite area accumulation time
 Risk of employee confusion if an additional type of waste
management is in the same work area as ordinary hazardous
waste
 Disposal cost may not be reduced.
EPA estimated national cost saving: $21.7
to $27.8 million/year