New EPA Requirements on Disposal and Recycling of Solvents

New EPA Requirements on Disposal and Recycling of Solvents

By Stephen Barlas, Contributing Writer

The new Environmental Protection Agency (EPA) rule on recycling of hazardous waste will affect many manufacturing sectors, including metalworking. The rule goes into effect in July. It is likely to add some regulatory hoops to jump through for companies that have been storing spent solvents on-site maybe with the thought of recycling, landfilling, or incinerating them.

However, the new rule does not affect the recycling of scrap metal. That has been subject to an exclusion from the Resource Conservation and Recovery Act, meaning it has never been considered a “hazardous secondary material” and can therefore be sent off for recycling with very few restrictions.

Going forward, the same will not be true for solvents, spent oil, and other substances that are considered hazardous secondary materials. Companies that want to continue to accumulate hazardous materials on-site will need to get state or federal permits. Those that send the materials off-site will have to comply with new recordkeeping and reporting requirements.

The EPA has been concerned for a decade about solvents and other hazardous materials being land-filled, perhaps creating a Superfund site down the road. The agency started the rule making process to address this subject all the way back in 2003, but the effort was sidetracked by lawsuits, additional studies, and various rule makings that went nowhere.

In 2011 the EPA proposed ending its transfer exclusion, which had been in place to shield many
hazardous secondary materials from being defined as solid waste. Many industrial sectors erupted in

For metal manufacturers that do want to continue to accumulate waste on-site, the final rule offers
a new option called the Certified Recycling Facility, which comes with considerable record keeping, storage requirements, spill prevention, financial assurance, worker training, and notification requirements. Under the new Definition of Solid Waste (DSW) rule, manufacturers can register as a Certified Recycling Facility with either the EPA or the state Solid Waste Agency. Facilities that successfully certify under the new rule can stockpile hazardous secondary materials such as solvents and oil. While this may be attractive to some, most facilities may choose to avoid the regulatory commitments that come with being registered as Certified Recycling Facility and opt for the generator option under the new rule, according to Phillip Retallick, senior vice president, compliance and regulatory affairs, Clean Harbors Environmental Services Inc. Retallick worked for the EPA for 10 years, then as director of the Delaware Solid and Hazardous Waste Program before joining the private sector.

The EPA has been concerned for a decade about solvents and other hazardous materials being land filled.

Retallick said, “The final rule allows fabricators the option to register as a generator with the authorized state environmental program or the EPA, if a state opts not to promulgate the new rule. This option allows the company to collect and store hazardous wastes designated for recycling as long as the yard meets some requirements, such as notifying either the state or the EPA that the yard is a generator subject to the rule … maintaining records of the amount of secondary hazardous waste collected and stored on-site, keeping documentation showing the amount and description of the secondary hazardous materials sent off-site for recycling, and notifying local emergency response officials where the accumulated secondary hazardous wastes are being stored on-site at the salvage yard.

Solvent Recycling Systems

Why Be Concerned about Hexavalent Chromium?

OSHA Compliance Requirements for Hexavalent Chromium (Hexavalent chrome, Chromium 6, Chromium VI) Effective May 31, 2010

Why be concerned about Chromium VI? Hexavalent chromium (Cr VI) is an IARC-1 human carcinogen. According to the EPA, “The best estimate of the excess risk of lung cancer from exposure to hexavalent chromium…is 8 cases of cancer in every 100 workers exposed.” -Environmental Protection Agency, Chromium VI (CASRN 18540-29-9). Other adverse health effects associated with Hexavalent chromium overexposure include irritation of the nose, throat, and lungs. Repeated or prolonged overexposure can damage the mucous membranes of the nasal passages and cause ulcers to form. In some cases the damage is so severe that the septum (the wall separating the nasal passages) develops a hole. Skin exposure to hexavalent chromium over prolonged periods can cause ulcers to form. Some workers develop an allergic sensitization to chromium. In sensitized workers, contact with even very tiny amounts can cause a serious skin rash. Exposure to Chrome 6 can also cause permanent eye damage in some cases.

Employees performing welding or thermal cutting tasks on chromium – containing metals are likely to be over-exposed to Hexavalent Chrome unless engineering controls and / or respiratory protection are used.

Only proven engineering controls (such as source capture air filtration from Gulftech Enterprises, Inc) can eliminate the need for the regulated areas. Filtration (rather than simple exhaust to the outside) allows re circulation of expensive conditioned air and reduces the size of the regulated area and reduces the number of affected employees.

There are generally three ways to maintain air quality:

– Dilution Ventilation (increased airflow in the welding area)

– Ambient air collection using dilution air and a dust or fume extraction device (ambient air cleaners can be mounted above the weld area to capture the weld fume).

– Source capture using a dust or fume extraction device (weld fume arms connected to either a portable fume extraction system or ducted to a dust collector).



Fume Back: Suction Off ; Suction On


New OSHA Standard 29 CFR 1910.1026