From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
Subject: Re: [DCHAS-L] solvent contaminated wipes final rule
Date: Tue, 24 May 2016 16:58:12 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 154e48f8833-15db-dc87**At_Symbol_Here**webprd-m13.mail.aol.com
In-Reply-To <34cb763b72634c3595e460ab1839a3b7**At_Symbol_Here**bl-cci-exch02.ads.iu.edu>


One thing in your favor is that acetone is not a VOC under the EPA Clean Air Act.  



Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062
actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org

 


-----Original Message-----
From: Derheimer, Dan G <dderheim**At_Symbol_Here**IU.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Tue, May 24, 2016 2:55 pm
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
 
IU Principles of Ethical Conduct:
 
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.

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