SMARTWIPES.org | Making the right choice when choosing wipers

EPA Rule at a Glance

Disposal industrial wipers were covered under EPA regulations prior to this new rule, while rental (laundered) towels were not. Instead, rental towels were governed by a wide variety of state and local laws. Impact: Bringing both rental towels and disposal wipers under one rule replaces a hodgepodge of regulations, making it easier for companies with multi-state locations to comply with regulations.
End-users (the operating facilities, not laundries or third-party haulers) are responsible for pollution discharges. Impact: Operating facilities need to closely monitor laundering or disposal of wipers and towels.
Companies that dispose of less than 250 pounds of hazardous waste per month are exempt from the following regulations. Companies that generate more than 250 pounds per month must adhere to these regulations. Impact: Plant operations should now include pre-treatment technology.
a. If waste is sent for disposal through a licensed combustion waste facility or to a nonlandfill facility, then the wipers must have no free liquids. In other words, although the wipers may have more than 5 grams of solvent on them, the wipers must be wrung to eliminate dripping liquids. Hand wringing is not permitted. Pre-treatment such as centrifuging, microwave extraction, or gravity draining are acceptable methods.

b. If waste is sent to a municipal or nonhazardous waste landfill, the wipers must be in dry condition, meaning that they contain less than 5 grams of solvent and are free of dripping liquids. Substances on the EPA list of 11 solvents of concern may not be sent to these landfills under any conditions.
The EPA 11 solvents of concern are: 2-nitropropane, nitrobenzene, MEK, methylene chloride, pyridine, benzene, cresols (o,m,p), carbon tetrachloride, chlorobenzene, tetrachloroethylene, and trichloroethylene. Nonhazardous substitutes are now available for some of these chemicals. Facility managers should contact their industry association for more information.
If a rental shop towel program is used, then free liquid must be removed before being sent to the laundry.
Wipers with solvents containing more than 5 grams of solvent must be stored in closed containers while at plant sites, rather than left in open bins where these pollutants can escape into the air. Impact: Indoor air quality at plants should improve.
Wipers with solvents must be transported in closed containers. Impact: To avoid environmental fines, managers must ensure that contractors comply.
Wipers and towels with grease and oil can be treated as regular solid waste if they meet the no drip rule. This literally means that if the item is wrung out, it does not drip. No special handling is needed before laundering or disposal. Impact: Treatment is simplified.
Recovery and recycling of spent solvents is encouraged, and most can be reused for industrial cleaning. Impact: Expect to save money on cleaning supplies.

Learn The Talking Points

SMART and INDA have worked together in proposing to the EPA's Office of Solid Waste several key objectives for this rule. These include:

Creation of a coherent, common sense national policy that companies of all size may comply.
Establish a uniform federal regulatory framework that all states can adopt for both laundered and non laundered wiping products.
Minimize the amount of potentially harmful hazardous solvent released into the environment and conserve and recover as many valuable solvent material resources as possible.

You may want to incorporate one or more of the following key points in your letter:

We strongly encourage EPA to finalize a Rule that will have ONE set of conditions for laundered and non-laundered wipes. This will appropriately reflect the fact that the potential risks to human health and the environment are the same and will make it much easier for the hundreds of thousands of generators - many of whom are small businesses - to understand and implement in their operations.
The laundering process does NOT recycle the solvent; it processes it as a waste. While the towel will be reused, the solvent is intended for disposal from the time the launderer picks up the wipe at the generators facility. Disposal of the solvent on a laundered wipe eventually ends up in the landfill just as a non-laundered wipe.
EPA's current proposal is unnecessarily complex and confusing - with differing conditions/requirements for wipers destined for the laundry, landfill or municipal incinerator.

The Rule shouldnt be complex - potential environmental and health risks are the same for all wiping materials.

One set of conditions/requirements makes perfect sense because the potential risks to human health and the environment are the same for laundered and non-laundered wipes. A single set of conditions will be much simpler for the generator community to implement.

Both non-laundered wipes and laundered wipes should be excluded from hazardous waste regulation
Both non-laundered wipes and laundered wipes should have the same container and labeling requirements
Both non-laundered wipes and laundered wipes should meet a performance standard of not dripping when hand wrung by the person managing the wipe to ensure that the maximum amount of solvent that can practically be removed is recovered and recycled.
Both non-laundered wipes and laundered wipes should be subject to a limited list of nasties - based upon EPA's Risk Assessment - that must always be handled as hazardous waste. All other solvents should be treated the same whether they are going to a landfill on a non-laundered wipe or to a landfill on a laundered wipe via the industrial laundering process. It is recommended that if the wipe meets the not dripping when hand wrung by the person managing the wipe performance standard, and it doesnt contain a solvent on the nasties list, then no further conditions should apply. However, if EPA decides that additional conditions should apply, then those conditions should apply equally to both laundered and non-laundered wipes.

These recommendations will result in a substantial increase in the amount of solvents recovered and recycled, simplify the Rule for easier understanding and implementation by the hundreds of thousands of generators who must implement the Rule and provide appropriate protection to human health and the environment.

EPA's research clearly shows that the potential risks to human health and the environment are the same for both laundered and non-laundered wipes. It is common sense the solvents on the laundered wipes dont magically disappear.
EPA's studies prove that they end up in landfills just like the solvents on non-laundered wipes in sludge whose liquid composition presents a greater potential threat than non-laundered wipes scattered throughout a landfill. And, rather than reducing the amount of solid waste going to landfills, laundered wipes actually increases the amount of solid waste going to landfills. The rhetoric that laundered wipes are more environmentally friendly is just that, rhetoric. The facts prove that laundered wipes and non-laundered wipes present EQUAL potential risks and as such should be regulated EQUALLY.

Finally, we encourage EPA to finalize this Rule as soon as possible. No further research or study is necessary. All vested parties have had an opportunity to provide their input. Please dont delay. 18 years is long enough. A simple, common sense approach that will accomplish EPA's objectives is on the table. Please implement it now.