Waste Frequently Asked Questions

Are wipes that are contaminated with a solvent that is not a listed hazardous waste under RCRA (i.e., not a listed solvent) eligible for the exclusions?

Yes, wipes that are contaminated with a solvent that is not listed under F001 through F005 in 40 CFR section 261.33 are eligible for the Wipes Rule exclusions provided the wipes do not exhibit the characteristic of reactivity, corrosivity, or toxicity in 40 CFR part 261.

Stated another way, wipes contaminated with a solvent that is not listed under F001 through F005 and that only exhibit the characteristic of ignitability in 40 CFR part 261 are eligible for the exclusions.

If a generator disposes of waste down a sewer to a Publicly Owned Treatment Works (POTW), does the generator need to obtain a generator ID number?

Section 262.12(a) states that a generator must not treat, store, dispose, transport, or offer for transport hazardous waste without having received an EPA ID number. If the generator is not doing any of these activities, he does not need an ID number. If the generator is accumulating waste, accumulation is a form of storage, and an ID number would be required.

Do I count the weight of the container?

The weight of a container is not counted when determining generator status or for biennial reporting. It is customary to show the total weight (i.e., waste plus container) on the manifest.

Visit Waste to learn more about the RCRA's waste requirements.