You ask a very tricky question.

 

If the filter is saturated I would believe you would have to deal with them as hazardous (regulated). If they are air drying them to eliminate a hazard, this has been frowned upon in the past by several EPA inspectors that I have dealt with in Georgia. If part of the process is to air dry the sample to, let us say, examine the filter under a microscope you may be able to treat the filter as non-regulated at the end of the process. Again what is being caught in the filter may also cause the filter to be regulated.

 

As it comes to the regulation, it is clear it must be a wipe. I would think it would be difficult to defend it to a regulatory body that the definition covers filters.

 

I am no expert in how your inspector in PA would view this.

 

Jeff

 

Solvent-contaminated wipe means a wipe that, after use or after cleaning up a spill, either (1) contains one or more of the F001 through F005 solvents listed in 40 CFR 261.31 or the corresponding P- or U- listed solvents found in 40 CFR 261.33; (2) exhibits a hazardous characteristic found in 40 CFR part 261 subpart C when that characteristic results from a solvent listed in 40 CFR part 261; and/or (3) exhibits only the hazardous waste characteristic of ignitability found in 40 CFR 261.21 due to the presence of one or more solvents that are not listed in 40 CFR part 261. Solvent-contaminated wipes that contain listed hazardous waste other than solvents, or exhibit the characteristic of toxicity, corrosivity, or reactivity due to contaminants other than solvents, are not eligible for the exclusions at 40 CFR 261.4(a)(26) and 40 CFR 261.4(b)(18).

 

Wipe means a woven or non-woven shop towel, rag, pad, or swab made of wood pulp, fabric, cotton, polyester blends, or other material.

 

 

Hello,

The solvent contaminated wipes final rule (40 CFR 261.4(b)(18) which conditionally excludes IPA / methanol / acetone ect..disposable solvent cleaning wipes as hazardous waste allows us to put them in a sealable container / label as excluded solvent contaminated wipes and discard in the municipal trash. 

 

My question is what if I have a filter saturated in acetone (not used to clean) can I put it in the same excluded solvent contaminated wipes container or do I have to dispose of this filter as hazardous waste.  Right now scientists air dry in the hood and dispose of in the municipal trash which I’m working on changing.  I don’t want to break any regulations but I also don’t want to unnecessarily split hairs. 

 

Thanks,

 

Mary Biersack

Lab Safety and Chemical Hygiene Specialist

West Pharmaceutical Services, Inc.

P: +1 610-594-3278

530 Herman O. West Drive | Exton, PA 19341 | United States

 

 

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