Enviro Watch



If you have any questions in regards to the above, please do not hesitate to contact our offices so that we may explain the amendments to the provisions of the Code in more detail. Our address is:


Fiddler González & Rodríguez, P.S.C., P.O. Box 363507, San Juan, PR 00936-3507. Our fax (787) 759-3108.


We welcome your questions and comments.

Juan Carlos Gómez Escarce
(787) 759-3166


María L. González Hernández
(787) 759-3173



Eduardo Negrón Navas

(787) 759-3106


Pedro J. Reyes Bibiloni

(787) 759-3208





On July 31, 2013, the Environmental Protection Agency (EPA) revised the solid waste definition to conditionally exclude solvent-contaminated wipes that are sent for cleaning and reuse (also referred to as “reusable wipes”). The agency also revised the hazardous waste definition to conditionally exclude solvent- contaminated wipes that are disposed (also referred to as “disposable wipes”).


Wipe is defined as a woven or non-woven shop towel, rag, pad, or swab made of wood pulp, fabric, cotton, polyester blends, or other material. Solvent-contaminated wipes include wipes that after use or cleaning up after a spill are contaminated with solvents, and that would otherwise be regulated as hazardous waste. Solvent contaminated wipes include wipes that: (a) contain one or more of the F001 through F005 solvents (40 C.F.R. 261.31), or the P-or U- listed solvents (40 C.F.R. 261.33); (b) exhibit a hazardous characteristic (40 C.F.R. 261, subpart C) when that characteristic results from a solvent listed in 40 C.F.R. 261; and/or (c) exhibit only the hazardous waste characteristic of ignitability (40 C.F.R 261.21) due to the presence of one or more solvents that are not listed in 40 C.F.R. 261. The exclusion applies to the solvent-contaminated wipe, not to the free liquid spent solvent removed from the wipe or from the container holding the wipes, which remain a hazardous waste. The conditional exclusion is not applicable to wipes that: contain hazardous waste other than solvent, exhibit the characteristics of toxicity, corrosovity or reactivity due to contaminants other than solvent, or wipes that are hazardous waste due to the presence of trichloroethylene.


In order to qualify for the exclusion, the solvent-contaminated wipes, when accumulated, stored and transported must, among others, be contained in non-leaking, closed containers labeled “Excluded Solvent Contaminated Wipes”. Solvent-contaminated wipes may be accumulated for up to 180 days. Generators must document that they are managing excluded solvent-contaminated wipes and keep such information at their site.


This final rule, published in 78 FR 46448, will become effective on January 31, 2014.


If you have any questions regarding this matter or would like to know more of our Firm’s experience in this area please call us. If you know anyone that would like to read the FGR Environmental Watch, please feel free to forward this article. Stay tuned for further updates of FGR ENVIRONMENTAL WATCH.

©2014 FIDDLER GONZÁLEZ & RODRÍGUEZ, P.S.C. Permission is granted to view, store, print, copy or distribute the content of this article for noncommercial or personal use, provided you do not alter it and you give us proper credit.

The content of this article is for informational purposes only. It is not legal advice or advertising. In addition, the above discussion has been provided in general terms and, therefore, should not be relied upon as legal advice applicable to a specific set of facts and circumstances. Before taking legal action, consult a lawyer you trust. Although we will try to be accurate, you cannot rely on its applicability to your specific problem without consulting your lawyer. Fiddler González & Rodríguez, P.S.C. and the members of the Environmental Practice Group assume no responsibility to inform you of additional changes in law or any other legal issues related to matters addressed in this email of which we may become aware after the date hereof.

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