Shop towels and rags

Scope

Various types of wastes may be managed according to special provisions in the regulations. Many special wastes are regulated at the state level. These wastes include shop towels and rags, cathode ray tubes (CRTs) and electronic wastes, industrial liquid wastes, radioactive mixed waste, and medical wastes.

Exemptions for solvent-contaminated wipes: Under an EPA rule that went into effect in January 2014, most solvent-contaminated wipes are no longer considered hazardous wastes. In order to qualify for the exemption, the wipes may only be contaminated with certain solvents. The wipes cannot be contaminated with a hazardous waste other than a solvent, or with a substance that exhibits another characteristic such as toxicity, corrosivity, or reactivity due to contaminants other than solvents; these wipes must be managed as hazardous wastes.

The exclusions apply to wipes containing one or more F001-F005 solvents listed in 261.31 or the corresponding P- or U-listed solvents found in 261.33, including:

Hazardous waste exclusion: Solvent-contaminated wipes that are disposed of are not hazardous wastes, provided they meet the conditions listed below. These wipes may be sent to combustors that are regulated under the Clean Air Act, municipal solid waste landfills, or hazardous waste landfills. (261.4(b)(18))

Regulatory citations

• 40 CFR Part 261 Subpart D — Lists of Hazardous Wastes

Key definitions

• Shop rags: Industrial wipes used to clean up parts, equipment, or small spills.
• Solvent contaminated industrial wipes: Wipes that are contaminated with certain solvents and managed according to the exclusions in 40 CFR 261.4.

Summary of requirements

Management conditions: In order to be eligible for the exemption (noted above under Scope), wipes must be managed as follows:

• Store used wipes in closed, non-leaking containers. Closed and labeled containers serve to minimize emissions, prevent spills, and reduce the risk of fires.
• Label the containers with the words “Excluded Solvent-Contaminated Wipes.”
• Remove any free liquids. Wipes may not contain free liquids when sent for cleaning or disposal. Free liquid solvent removed from the wipes must then be managed as a hazardous waste, as appropriate, and may be recycled.
• Send wipes off-site within 180 days. The time limit ensures that free liquids are removed from the solvent-contaminated wipes and the container and not stored indefinitely on-site.
• Comply with recordkeeping requirements. Generators must maintain certain documentation on-site so that states and EPA can ensure they are complying with the conditions of the exclusion. This documentation must include:
  • The name and address of the laundry, dry cleaner, landfill, or combustor;
  • Documentation that the 180-day accumulation limit is being met; and
  • Description of the process the generator is using to meet the “no free liquids” condition.

State adoption: Note that EPA is not requiring states to adopt the exclusions for industrial wipes. Your state may require you to treat solvent-contaminated wipes as hazardous wastes, even if they would be eligible for the federal exclusions. Your state may also have regulations that are stricter than the federal requirements. Be sure to check with your state environmental regulating agency to be sure you are in compliance with all the regulations that apply to you.

Non-hazardous solvents: Generators using industrial wipes with non-hazardous solvents are not affected by the exclusions. These wipes are not currently regulated as hazardous waste. Because of the reduced risk, EPA strongly recommends that all facilities consider using non-hazardous solvents.