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ECAR
Fact Sheet for
Connecticut
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.
Regulations
In Connecticut, how you manage used
rags depends on what they are contaminated with. If the used rag
is:
- Dripping with used oil, manage
as used oil (see ECAR Used Oil Fact Sheet).
- Contaminated with used oil, but not dripping,
test for hazardous waste then properly manage.
- Contaminated with paints or
solvents, or other hazardous materials, manage as hazardous wastes.
- Contaminated with non-hazardous materials such
as waxes, polishing compounds, etc., manage as solid waste if
only a small number are generated (1 or 2 per dumpster). If significant
numbers of these rags are generated, however, they must be segregated
and managed as Connecticut-regulated waste.
- Contaminated with other material (or only with
mild cleaners or soaps), dispose of in regular trash.
If
you lease rags and have them laundered, and they are contaminated
with hazardous waste, you must manage them as
hazardous wastes until they are picked
up for laundering. However, they do not require a hazardous waste
manifest.
All
laundries that handle industrial rags must have a wastewater discharge
permit from the Connecticut Department of Environmental Protection
(CT-DEP). To obtain a list of facilities that have valid discharge
permits and their compliance status with the permit conditions,
contact the CT-DEP (listed under the “Contacts” section below).
If
contaminated rags/used shop towels are not sent to a laundering
service, then auto recyclers must determine if the dirty shop towels
are hazardous or not before disposing of them. Most likely they
are indeed hazardous. Therefore, they must be managed in accordance
with hazardous waste regulations. See the ECAR
Hazardous Waste Fact Sheet.
Links
to the Regulations. Use
the following links to view the regulations pertaining to shop towel
management and storage.
Connecticut Hazardous Waste Regulations
Connecticut Used Oil Regulations
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 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). Contract
with a permitted industrial laundry service that delivers clean
cloth rags and will pick up the soiled rags on a regular basis.
The laundry service may require you to limit the solvent and other
chemical content of the soiled rags because of the limits on their
permit to discharge wastewater into the sanitary sewer. Have your
laundry service certify that they hold the appropriate permits
and they are in compliance with the permit conditions.
- Are you sending shop towels to be laundered?
If so, ensure that the used
towels are managed as hazardous waste until they are picked up
by the laundering facility.
- Do your shop towels contain
free liquids? If so, there
is no hazardous waste exemption for rags or soiled clothing contaminated
beyond saturation.
- Are you properly storing your shop towels? Store ignitable shop towels in NFPA approved, labeled
containers until they are picked up for laundering or disposal.
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.
- Keep oily rags separate from other rags that
have been contaminated with hazardous materials such as solvents.
- Remove excess solvent from rags by wringing or
pressing excess into a coverable container, or store rags in a
double-bottomed drum that allows the solvent to drip where it
can be collected and recycled or managed appropriately.
- Avoid using disposable towels. Use cloth towels
from an industrial laundry service that is discharging its wastewater
into a public sewer system.
- Do not dispose of solvents by pouring them onto
rags or into containers of used shop towels.
- Do not saturate your towels. If you do, wring
them out and reuse the liquid.
- Do not throw dirty wipes, paper towels or rags
into the dumpster if they have come into contact with hazardous
solvents or waste.
- Do not dispose of dirty shop towels in vehicles
to be crushed or shredded.
- Keep waste shop towels in a closed, fireproof
metal container labeled "Used Shop Towels."
- To reduce the risk of spontaneous combustion
when storing shop towels in metal cans, keep the towels moist
with water.
- 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
- For more information, or to obtain a list of facilities that have valid discharge permits
and their compliance status with the permit conditions, contact
the CT-DEP at 860/424-3018 and ask for the “engineer of the day”.
- To report a spill or leak, immediately call
the Connecticut Department of Environmental Protection,
Oil and Chemical Response Division at 860-424-3338, 24 hours/day.
Should this number become unavailable for any reason, call 860-424-3333.
Within 24 hours of the spill you are required to complete a written Report of Petroleum
or Chemical Product Discharge.
- To report an environmental incident or complaint,
contact the nearest regional
office.
Related
ECAR Fact Sheets
- Hazardous Waste
- Used Oil Fact Sheet
Other
Relevant Resources
- Connecticut Auto Recycling
Guide
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