Regulatory Affairs Manual Series 100 s2

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Appendix 6: Management of Solvent Contaminated Wipes and Rags

Effective Date: February 2003 Rev. # 1 Mandatory Discretionary 

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ENVIRONMENTAL REGULATION OVERVIEW

DISTRIBUTION: D. Blevins, R. Blum, M. Delgadillo, D. Engle, L. Elder, B. Fuhrer, M. Jasko, A. Kellogg, B. Knighton, J. Loris, A. Ozolins, J. Miner, B. Morris, D. Ruppert, J. Sedilo, G. Smith, R. Svoboda, J. Vaughan, E. Zalewski FROM: L. Williams LKW , T. Tisa TJT NUMBER: 03-004 DATE: February 28, 2003 SUBJECT: Management of Solvent Contaminated Wipes and Rags

OVERVIEW: Used paper or cloth wipes, rags or shop cloths (here after referred to as wipes) are a solid waste when they are thrown out or are recycled. Wipes that become contaminated with certain solvents have the potential to be classified as hazardous waste. A wipe meets the definition of hazardous waste when a) it contains a spent solvent that has served its intended purpose and is no longer useful as a solvent (e.g. acetone) , or b) it is mixed with a listed hazardous waste (e.g. F-listed solvents like 1,1,1 trichloroethane) or c) the rag and the solvent meet the characteristic of a hazardous waste (e.g., D001 ignitability through spontaneous combustion).

The management and disposal of these wipes can come under the same rules and regulations that govern the management of hazardous waste. The EPA does allow the individual states to administer their own programs and make decisions on the proper management of solvent contaminated wipes. Therefore interpretations regarding this waste are being made by taking into account regulations of the specific states in which Fisher Scientific generates these types of waste.

IMPACT TO FISHER SCIENTIFIC: Both manufacturing and logistic operations generate solvent contaminated wipes. The majority of wipes generated at a distribution center should be by contractors who come on-site to perform maintenance on forklift vehicles or conveyors. However, solvent contaminated wipes are generated from process as well as maintenance operations at manufacturing plants.

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Contractors should take all contaminated wipes with them and not be allowed to discard them into Fisher Scientific’s “trash” dumpsters. All maintenance shops need to collect their solvent rags and store them in properly labeled and closed containers. These containers should be labeled as to the contents. For example “ shop wipes” if the wipers are determined to be non hazardous waste or “hazardous waste “ if the wipes are determined to be hazardous waste.

ACTION PLAN: These are the waste management steps that must be followed for wipes: 1. CONDUCT A WASTE CLASSIFICATION OF THE WIPES a) separate wipes that have been used with any chemical or solvent, b) document the waste classification of the wipe based on the process generating the waste (e.g. degreasing or spill cleanup), the solvent used or the characteristic of the wipe, c) if the wipes are classified as hazardous waste or they contain free liquids: i. they must be disposed of through ONYX Environmental Services as hazardous waste or non hazardous waste, ii. if the waste is hazardous then the waste must be kept in a closed container with a label that reads “Hazardous Waste” and kept either at an satellite accumulation area or timed accumulation area with the date of accumulation marked on the drum; d) if the wipes have been documented as non federal or non state hazardous waste, and are not going for laundering: i. ensure that all other state requirements are met ( e.g. in Illinois these wipes must be handled as special waste, in Pennsylvania they must be handled as residual waste). 2. TO LAUNDER WIPES OFF-SITE a) ensure that the wipes have been documented as non federal or non state hazardous waste in Step 1, b) ensure that wipes contain no free liquid , c) send the wipes off-site to a uniform laundry using the information identified in Table 1 below. 3. TO LAUNDER WIPES ON-SITE a) ensure that the wipes have been documented as non federal or non state hazardous wastes in Step 1,

b) obtain approval, in writing, from the local Publicly Owned Treatment Works to receive the waste stream by providing them the nature of the chemical(s) on the rag, the volume of the laundry operation, and the type of detergent you plan to use, c) discharge the waste water to the POTW when the POTW gives you written permission.

If you have any questions or need assistance, please call Leslie Williams at (412) 490-8933 or Tom Tisa at (412) 490-8928 .

1 . 1 . 1 . 1 T A B L E 1

State Specific Requirements For Laundering of Wipes

State Requirements if wipes are to be laundered AR 1. use hazardous waste manifest 2. use hazardous waste transporter 3. ship to authorized hazardous waste facility

CA 1. does not apply to rags used to clean up spills 2. do not add other hazardous waste to the rags 3. ensure rags are not dripping with liquid 4. verify laundry keeps records with date, type, and quantity of materials received 5. verify laundry has contingency plan for emergencies

IL 1. No additional requirements except as described in the action plan above.

NJ 1. manage rags on-site as hazardous waste 2. ship rags within 90 days of generation 3. ensure rags are not dripping with liquid 4. ship rags in proper DOT containers/packaging and labeling 5. the wipes do not have to be shipped as hazardous waste

NY 1. manage rags on-site as hazardous waste 2. ensure rags are not dripping with liquid 3. store in fire proof containers 4. ship rags in proper DOT containers/packaging and labeling

WI 1. label containers "Dirty Solvent Rags Only" 2. separate containers for cloth and paper rags 3. ensure rags are not dripping with liquid 4. maintain contract with laundry service

cc: N. Brown, B. Chase, E. Carfagno, J. Farris, J. Felder , B. Hundley, A. Malus, K. Napier, C. Rohlmeier

Revision Date: September 2004 Page 5