Guidance on Handling Contaminated Wipes

GUIDELINES FOR CONTAMINATED WIPES


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Created June 2003

Laundered Wipes

The US EPA previously determined that contaminated wipes, generated as a result of normal operations, which are sent to commercial industrial laundries and subsequently reused are not “discarded.” Therefore, they are not considered a solid waste subject to RCRA regulation.

The North Carolina Hazardous Waste Section has adopted this policy based on two reasons. First, laundering has not historically been a waste management activity. Second, the amount of contaminants normally present would be adequately regulated through the Clean Water Act’s pretreatment requirements.

For this reason, the RCRA regulation exemption may extend to wipes laundered by generators (as opposed to a commercial facility), as long as certain conditions are met. The wipes must be reused, and the laundering waste discharged to a publicly owned wastewater treatment system subject to the Clean Water Act. An industrial wastewater point source discharge that is subject to Section 402 of the Clean Water Act (NPDES permit) also qualifies for this exemption. Any sludge produced from pretreatment prior to discharge may be regulated as a hazardous waste if it contains a listed hazardous waste or itself a characteristic hazardous waste.

The exemption from RCRA regulation does not apply where laundering waste discharge is not regulated under the Clean Water Act. Some examples include discharge into a septic system/leach field or an unpermitted direct discharge.

The operator must accumulate wipes appropriately and safely (e.g., in a closed container as opposed to placement in a waste pile or other land disposal unit) to prevent the release of contaminants to the environment. Even though wipes that are to be laundered are not regulated as a hazardous waste, any release or contamination due to the mismanagement of contaminated wipes is a violation of North Carolina law.

You may not mix hazardous waste with wipes to be sent to laundering facilities.

You cannot dispose of hazardous waste at a commercial laundry simply because it is contained in an absorbent that is to be laundered. Absorbents specifically designed to contain releases and absorb significant amounts of contaminants (e.g., pig or booms), and wipes used to contain spills or releases, do not qualify for the laundering exemption. They are considered “solid wastes” and must be managed subject to RCRA regulation.

Wipes Intended for Disposal

Wipes contaminated with a listed hazardous waste (i.e., a hazardous waste with an “F,” “K,” “P” or “U” waste code) must be managed as a listed hazardous waste when disposed, or when accumulated or treated before being disposed. This rule applies regardless of how the wipes became contaminated. However, wipes contaminated with a characteristic waste are hazardous only if the contaminated wipe itself exhibits hazardous waste characteristics.

If the spent wipe contains, or has been mixed with a listed hazardous waste, then the “mixture rule” found at 40 CFR 261.3(a)(2)(iii) and (iv) applies. This rule states that a solid waste mixed with a listed hazardous waste causes the entire amount of waste to be listed as that hazardous waste. The only exceptions are mixtures of solid waste and listed hazardous wastes that were listed solely because they exhibit a characteristic.

Characteristic wastes are ignitable, corrosive, reactive or toxic, as determined by the Toxicity Characteristic Leaching Procedure test. For example, F003 solvents are listed because of their ignitability. However, wipes contaminated with F003 xylene are not considered a hazardous waste if they no longer exhibit the characteristic of ignitability.

If the spent wipes are going to be incinerated, fuel blended or land disposed, they must be managed as a hazardous waste. Containers holding spent wipes cannot be left open to allow the solvent to evaporate.

Examples of Listed Wastes

In practice, listed solvents (F001-F005, including trichloroethylene, methylene chloride, toluene and methyl ethyl ketone) are often applied to work surfaces or equipment parts and then wiped off with a disposable wipe. Alternatively, listed solvents may be applied to a wipe that is then put in contact with a work surface.

In both cases, the constituent make-up of the wipe is essentially identical, poses the same hazards, and the resulting contaminated wipe must be managed as a listed hazardous waste when disposed. The only exception would be spent wipes contaminated with F003 listed solvents (please see discussion above).

Other examples of contaminated wipes include wipes used to clean print rollers, touch-up paint operations, degreasing parts, painting lines, process circuit boards, electrical parts, and numerous other operations. The same rationale applies to spent wipes contaminated with other listed wastes. For example, wipes used to clean a sludge press may be contaminated with F006 electroplating sludge. Another example would be gloves and paper towels (wipes) contaminated with K051, a separator sludge from the petroleum refining industry.

Examples of Characteristic Wastes

Some examples of characteristic contaminated wipes include rags contaminated with lead when used to wipe circuit boards and wipes contaminated with paint in other cases which then become characteristic for methyl ethyl ketone (MEK). Please note that paint waste which contains toluene, xylene or MEK is not listed. However, if wipes used to clean this waste are characteristic for ignitability, metals or other organic constituents, they should be treated as hazardous.

Wipes contaminated with “thinners” may or may not be considered hazardous waste, depending on the nature of the thinner. Many thinners, such as mineral spirits, turpentine and naptha, are characteristic only for ignitability. Other thinners are listed wastes, therefore wipes contaminated with listed solvent “thinners” are considered a listed hazardous waste and should be managed accordingly.

It should be noted that wipes contaminated with characteristic, ignitable, hazardous waste are generally not liquids; therefore, administering a flashpoint test to determine ignitability is not appropriate. The contaminated wipes would only be a characteristically, ignitable hazardous waste if they were subject to spontaneous combustion, ignition through friction or moisture absorption. Even though these wipes may not be considered a RCRA hazardous waste, adverse conditions may allow the wipes to ignite and create a hazard. Implement good management practices to handle these wipes so as to prevent exposure to an ignition source.

Some facilities have reported allowing contaminants to evaporate from wipes prior to disposal so that the wipes are considered non-hazardous. The evaporation of hazardous waste is improper treatment. Hazardous waste determinations are to be made when and where the waste is first generated.

General Comments

All land disposal restrictions contained in 40 CFR 268 apply to wipes disposed as a hazardous waste.

Because every site is unique, some factors or situations concerning spent wipe management may not be addressed in this guidance document. For additional information, please contact the North Carolina Hazardous Waste Section at 919-733-2178.

Source: This document is based on excerpts from the Indiana Department of Environmental Management’s Non-Rule Policy Document, “Management of Contaminated Wipes.” IDEM has given limited approval to use the material exclusively in this document.