Hi Dan and Jeff,
Thank you for your thorough responses, I feel much more confident in my decision of what to do now. I agree that I might be able to defend disposing of the acetone saturated filters as non- hazardous, but since
they are technically not wipes I’ll discard as hazardous waste (I’m thinking I shouldn’t take advantage of an exemption allowing us to be practical about wipes).
Having a clear understanding of this regulation will help me when training the chemists why they can’t treat listed solvent waste via evaporation in the hoods.
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu]
On Behalf Of Derheimer, Dan G
Sent: Tuesday, May 24, 2016 1:25 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] solvent contaminated wipes final rule
Mary: The filters would be listed (F003) if spent acetone containing solvent contacted them. You might have an argument if the acetone is associated with the filter as a product(not a spent solvent) of some kind
during its life cycle as the regulation is silent on this situation. If not, they are not hazardous and would not be flammable if wet unless spontaneously combustible. Note that if a listed solvent and you are evaporating in a hood, that is considered treatment
without a permit so it’s safe to avoid grey areas with the regulations in these circumstances. I would advise that your state or EPA might have specific guidance on this that would trump my interpretation of the rule in IN.
Dan Derheimer
Director
Environmental Health & Safety
Indiana University Bloomington
1514 E. 3rd St.
Bloomington, IN 47405
dderheim**At_Symbol_Here**iu.edu
IU Principles of Ethical Conduct:
http://www.indiana.edu/~bfc/docs/circulars/13-14/B10-2014.pdf
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu]
On Behalf Of Biersack, Mary
Sent: Tuesday, May 24, 2016 11:22 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] solvent contaminated wipes final rule
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
Find West on
Twitter and
LinkedIn.
The contents of this message are confidential and may be privileged. If you have received this message in error, please permanently delete it, along with any files that may be attached to
this message, without reading, printing, copying, forwarding or otherwise distributing it. Please notify the sender of the error immediately so that we can prevent it from happening again.
Find West on
Twitter and
LinkedIn.
The contents of this message are confidential and may be privileged. If you have received this message in error, please permanently delete it, along with any files that may be attached to
this message, without reading, printing, copying, forwarding or otherwise distributing it. Please notify the sender of the error immediately so that we can prevent it from happening again.
Previous post | Top of Page | Next post