solvent wipes

Q&A: How do I classify solvent wipes for transportation?

Q&A: How do I classify solvent wipes for transportation?

A question (01.04.18):

I’m looking for ability to confirm the DOT rating for particular product we have currently started to make. Is this something you’re able to help provide assistance/training?

I’m here to help, so my reply (01.05.18):

Yes. I can assist you with that.

If you are able to provide a safety data sheet (SDS) or some other technical information I will be happy to provide you with a “snap” classification at no charge.

If you decide to proceed a more formal classification can be provided under my consulting services for a fee.

He was OK with free advice:

I’ve attached two SDS for 70% IPA canister products. The only different to the two products would be the number of wipes in each canister. I believe the classification should be UN3175 – class 4a which one states but the other states UN1987 class 3. The IPA is fully absorbed into the fabric in each product which is why I’d think the classification should be a haz solid. Thank you in advance for any assistance.

Thanks
(SDS’s for two different wipes, both saturated with Isopropanol were attached)

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My final answer (01.05.18):

Thank you for contacting me. I will try to answer your questions below.

  • I assume this classification is for the transportation by ground or rail within the U.S. International transport and transport by other modes will require a separate classification. However, I am confident the classification will remain the same.
  • Isopropyl alcohol is a Class 3 flammable liquid.
  • The wipes are best classified as: UN3175, Solids containing flammable liquids, n.o.s. (Isopropyl alcohlo) 4.1, PG II
  • However special provision 47 in column 7 of the Hazardous Materials Table for this entry reads in part (last sentence):

Small inner packagings consisting of sealed packets and articles containing less than 10 mL of a Class 3 liquid in Packing Group II or III absorbed onto a solid material are not subject to this subchapter provided there is no free liquid in the packet or article.

Therefore, as long as both products meet the requirements of special provision 47 (small sealed packets with no free liquids), they are not subject to the USDOT Hazardous Materials Regulations and are not a hazardous material when offered for transportation.

I hope this helps.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Conclusion:

I never heard back so I can only assume all went well.  Here we have a perfect example of someone offering for transport a product as a hazardous material (subject to increased shipping and handling costs) when a perfectly good exception from regulation exists.  If applicable (and in this case I believe it is) the exception has the potential to save this business a lot of money.  Of course, USDOT/PHMSA HazMat Employee training is still required but that is a small price to pay for compliance and the knowledge that comes with it.

The Solvent Contaminated Wipes Rule in Michigan

On January 31st of 2014, the USEPA’s Solvent Wipe Rule became effective at the Federal level and in those states lacking authorization under RCRA to operate their own hazardous waste program.  As a state with an authorized hazardous waste program, Michigan has the option to adopt the new Federal Rule in its entirety, adopt it in part, or reject it outright and manage solvent-contaminated wipes by its own state rules.  The purpose of this article is to explain the regulatory requirements for the management of solvent-contaminated wipes by a hazardous waste generator in Michigan.

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EPA Reduces Regulatory Burden for Industrial Facilities Using Solvent Wipes

This is big news!  The regulated industry has been waiting for this Final Rule for some time.  This will affect the Federal RCRA regulations that most states with authorized hazardous waste programs “adopt by reference” into their state regulations.  Prior to this Final Rule most states already had some form of this exclusion, but it was not codified in the regulations.  Below is the news release from the USEPA, I’ll write an article on this soon providing a summary and what you need to know.

Common-sense exclusion will save industry up to $27.8 million per year

Release Date: 07/23/2013
Contact Information: Enesta Jones, jones.enesta@epa.gov, 202-564-7873, 202-564-4355

WASHINGTON – Today the U.S. Environmental Protection Agency (EPA) modified the hazardous waste management regulations under the Resource Conservation and Recovery Act (RCRA) to conditionally exclude solvent-contaminated wipes from hazardous waste regulations provided that businesses clean or dispose of them properly. The rule is based on EPA’s final risk analysis, which was peer reviewed in 2008 and published for public comment in 2009, that concluded wipes contaminated with certain hazardous solvents do not pose significant risk to human health and the environment when managed properly. EPA estimates that the final rule will result in a net savings of between $21.7 million and $27.8 million per year.

Wipes are used in conjunction with solvents for cleaning and other purposes by tens of thousands of facilities in numerous industrial sectors, such as printers, automobile repair shops and manufacturers of automobiles, electronics, furniture and chemicals.

“Today’s rule uses the latest science to provide a regulatory framework for managing solvent-contaminated wipes that is appropriate to the level of risk posed by these materials,” said Mathy Stanislaus, assistant administrator for EPA’s Office of Solid Waste and Emergency Response. “I’ve heard directly from stakeholders about the benefits of this rule and the need to finalize it. The rule reduces costs for thousands of businesses, many of which are small businesses, while maintaining protection of human health and the environment.”

Today’s final rule excludes wipes that are contaminated with solvents listed as hazardous wastes under RCRA that are cleaned or disposed of properly. To be excluded, solvent-contaminated wipes must be managed in closed, labeled containers and cannot contain free liquids when sent for cleaning or disposal. Additionally, facilities that generate solvent-contaminated wipes must comply with certain recordkeeping requirements and may not accumulate wipes for longer than 180 days.

EPA estimates that the final rule will result in a net savings of $18 million per year in avoided regulatory costs and between $3.7 million and $9.9 million per year in other expected benefits, including pollution prevention, waste minimization and fire prevention benefits.

Today’s rule is consistent with President Obama’s Executive Order 13563, Improving Regulation and Regulatory Review, which charges federal agencies to monitor regulatory effectiveness and to help make agency regulatory programs more effective or less burdensome in achieving the regulatory objectives.

EPA first proposed modified regulations for solvent-contaminated wipes on November 20, 2003, and published a revised risk assessment for public comment on October 27, 2009. The docket for this rulemaking is EPA-HQ-RCRA-2003-0004 and can be accessed at http://www.regulations.gov once the final rule is published.

More information about this rulemaking:http://www.epa.gov/epawaste/hazard/wastetypes/wasteid/solvents/wipes.htm