Used wipes – Employers must determine if used shop wipes meet the characteristics of hazardous waste since they assume the characteristics of whatever they are used to clean up. If it is determined that the shop wipes are hazardous, requirements for hazardous waste generators with regard to handling and disposal of the waste found at 40 CFR 260 to 280 must be followed.
If wipes are not hazardous, they can be laundered or disposed of in the regular trash, depending on local landfill requirements.
OSHA requires that “combustible waste material and residues in a building or unit operating area shall be kept to a minimum, stored in covered metal receptacles and disposed of daily.” Rags which are soiled with oil, grease and other organic flammable or combustible materials are considered to be combustible waste.
If the wipes are to be laundered, they should be collected daily and gathered at a central point pending pickup by a recycler or launderer. Keep the wipes in an airtight metal container that is regularly emptied, and which is located away from buildings.
In a shop environment, technicians need to be ready for spills of any size or substance. Quite often, though, they’ll face small spills that can be safely handled by someone with HazCom training. For example, a small amount of a substance considered low in toxicity and released during a vehicle maintenance operation may be considered an incidental release, not an emergency.
Under OSHA regulations, no formal emergency response training would be necessary if these “incidental spills” meet the following criteria:
- They can be absorbed, neutralized or controlled at the time of the spill by employees in the immediate area or by maintenance personnel.
- They do not pose a significant safety or health hazard to nearby employees or to the employee cleaning up the substance.
- They do not have the potential to become an emergency in a short time.
However, if the shop has the potential for spills that are considered “more than incidental,” and employees are expected to handle them, there’s a good chance that your shop is required to provide extensive emergency response training, special equipment and a written response plan. The training requirements are found in OSHA’s HazWoper regulation 29 CFR 1910.120.
Spills that call for this level of response might include bulk storage tank leaks that seep or spray outside of secondary containment areas. Cargo tanks can also leak hazardous materials and pose emergencies.
EPA, too, requires spill response measures under several regulations that may apply to your maintenance shop. Oil spill response is covered under 40 CFR 112.7, “General Requirements for Spill Prevention, Control and Countermeasure (SPCC) Plans;” 40 CFR 279 Subpart C, “Standards for Used Oil Generators;” and 40 CFR 280 Subpart F, “Release Response and Corrective Action for Underground Storage Tank Systems Containing Petroleum.”
Hazardous waste emergencies are regulated under 40 CFR 262.34 and 265 Subpart D.
In addition, the agency requires immediate notification to appropriate agencies, such as the National Response Center, when a “reportable quantity” of oil or other hazardous substance is released.
There is also the challenge of waste disposal. The use of materials will produce waste, but how this waste will be handled will depend on its characteristics.
If the waste is ignitable, corrosive, reactive, toxic or listed as a hazardous waste in the regulations, then EPA recognizes it as “hazardous waste” and the regulations at 40 CFR 260 to 280 apply.
If the waste is non-hazardous, it may be recycled or disposed of in accordance with local landfill rules.
Used oil – The EPA does not regulate used oil that is being recycled or certain types of used oil filters as hazardous waste, unless the used oil contains a substance that causes it to meet the definition of hazardous waste. Instead, employers are expected to follow standards found at 40 CFR 279 for recycling used oil.
Some states may have more stringent regulations, so checking with your local environmental agency and waste hauler is a best practice.
Aerosol cans – Since many hazardous substances can be packaged in aerosol cans, the method of disposal may be confusing. The EPA is clear that steel aerosol cans do not contain a “significant amount” of liquid meet the definition of scrap metal and are exempt from hazardous waste regulation if recycled. So, a punctured and drained aerosol would not be considered hazardous waste.