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ECAR
Fact Sheet for
California
Shop Towels
 
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The
following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.
What You Need to Know
When you absorb toxic or flammable
material in a towel, you haven't made it any less toxic or flammable.
Depending on what they have been used for, shop towels may need
to be managed as hazardous
wastes. But you
may be able to be exempt from the full burden of hazardous waste
management rules if you send your towels to a qualified industrial
laundry service. (The service has to discharge its wastewater
into an approved wastewater treatment facility -- it can't discharge
directly to a river or stream, for example.) If you do not
send your towels out for cleaning (for example, if you use disposable
towels), then the burden is on you to prove that they are not hazardous
before you dispose of them. Reusable towels and a qualified
laundry service are by far the best bet.
This fact sheet will help you recognize
some of the most common materials that can turn shop towels into
hazardous wastes.
Regulations
Dirty shop towels are exempt from
regulation if they are managed correctly and picked up for laundering
by an industrial laundry service that is connected to a publicly
owned treatment works facility (POTW). If a shop towel service is
not used, then you must determine if your dirty shop towels are
hazardous or not before disposing of them. If the towels are hazardous,
then you must manage them in accordance with hazardous waste regulations.
Links to the Regulations. Use
the following links to view the regulations pertaining to hazardous
waste determinations and management.
California
Health and Safety Code
Federal
EPA Standards Applicable to Generators of Hazardous Waste
Self-Audit
Checklist
When an inspector comes to your facility,
there are certain things he or she checks to see if you are in compliance
with environmental regulations. It makes good sense for you to perform
a "self-audit" and catch and correct problems before they result
in penalties. Also, there are some compliance incentives associated
with self-audits (see Audit
Policy Page).
Use the following list to audit your
handling of used shop towels.
- Shop towels are exempt from
regulation only if they are managed correctly and picked up for
laundering by an industrial laundry service that is connected
to a publicly owned treatment works facility (POTW). Verify
that dirty shop towels are managed correctly and picked up for
laundering by an industrial laundry service that is connected
to a publicly owned treatment works facility (POTW).
- If dirty shop towels are not
laundered by an industrial laundry service that is connected to
a publicly owned treatment works facility (POTW), then you must
make a hazardous waste determination for the dirty shop towels
and if the shop towels are hazardous, manage them as hazardous
waste. Verify that a hazardous
waste determination has been made for shop towels that are not
laundered by and that laundry service that is connected to a publicly
owned treatment works facility (POTW) and that if the towels are
hazardous, that they are managed as hazardous waste.
Best
Management Practices (BMPs)
Most regulations tell you what you
have to do to be in compliance, but they don’t explain how to do
it. That’s where "best management practices" come into play.
BMPs are proven methods that help you to get into compliance and
stay there. The following BMPs are recommended for handling used
shop towels.
- Avoid using disposable towels.
Use cloth towels from an industrial laundry service that is discharging
its wastewater into a public sewer system.
- When possible use non-chlorinated
or low VOC cleaning compounds. Using chlorinated solvents will
cause the rags to be a hazardous waste.
- Do not dispose of solvents by
pouring them onto rags or into containers of used shop towels.
- Do not throw dirty wipes, paper
towels or rags into the dumpster if they have come into contact
with hazardous solvents or waste.
- Liquid petroleum wastes should
not be draining from towels placed into the trash.
- Do not dispose of dirty shop towels
in vehicles to be crushed or shredded.
- Keep waste shop towels in a closed,
fireproof container labeled "Used Shop Towels."
- Examine your equipment cleaning
practices to identify opportunities to reduce their frequency,
thereby reducing the number of towels, wipes, or rags that are
used for this purpose.
- Maintain records of analytical
waste determinations and disposal receipts for at least 3 years.
Contacts
- California Department of Toxic
Substances Control: 916-323-2678.
- Public and Business Liaison Hotline:
800-728-6942.
Related
ECAR Fact Sheets
- Hazardous
Waste
Other
Relevant Resources
- Partners in
the Solution Guidance Manual (Developed by the State of California
Auto Demantlers Assn)
- Shop
Towel Pollution Prevention Fact Sheet
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