ECAR
Fact Sheet for
Delaware
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 commercial laundry service. 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
the state of Delaware, dirty rags/shop towels are subject to the
federal RCRA hazardous waste regulations, meaning that they need
to be collected in a proper container
which is kept closed, labeled, dated and inspected weekly, be managed
under accumulation requirements, and sent to a proper RCRA facility
for disposal.
However, if the contaminated rags are to be commercially laundered and reused
rather than disposed of, the state of Delaware will give auto recyclers
somewhat of a break by excluding them from the hazardous waste regulations.
The rags/towels need to be managed as hazardous waste only until
they are picked up by a commercial laundering service. See if the
laundry/recycling facility you use is meeting local sewer discharge
limits. Laundries/recyclers that discharge their waste water to
a drain field should be avoided.
However,
to qualify for this exemption, there must be NO free liquids
present in the accumulated rags. Any free liquids must be managed
as hazardous waste and the entire rag/solvent mixture may be considered
a hazardous waste subject to regulation.
You
should also bear in mind that allowing solvents to evaporate from
the rags in order to achieve a "no free liquids" state
is not permitted. Instead, you may wish to use some sort of solvent
extraction or wringing to recover excess solvent amounts if they
plan to have rags laundered. Any recovered liquids should be managed
in accordance with the regulations.
Finally,
contaminated rags or commercial wipes regulated as hazardous waste
MAY NOT be burned in a space heater, boiler, industrial
furnace, incinerator, or other combustion device operated by the
generator, or open burned.
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.
Delaware's
Solid Waste Management Requirements
Delaware's
Hazardous Waste Management Requirements
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 a commercial laundry service. Verify that dirty shop towels are
managed correctly and picked up for laundering by a commercial
laundry service. You must manage your shop towels
in accordance with the hazardous waste requirements until they
leave your operations.
- Do your
shop towels contain free liquids? If so, there
is no hazardous waste exemption for rags or soiled clothing
contaminated beyond saturation.
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.
- Use cloth towels which can be cleaned and reused.
- When possible, use less hazardous cleaning solvents (ones without chlorinated
compounds).
- See if the laundry/recycling facility you use is meeting local sewer discharge
limits. Laundries/recyclers that discharge their wastewater
to a drain field should be avoided.
- Keep waste shop towels in a closed container marked “Contaminated Shop Towels
Only".
- Don't throw
dirty towels into your dumpster.
- Don't saturate
towels. If you do, wring them out and reuse the liquid.
- Try not
to use disposable paper towels or rags.
- Don't dispose
of solvents by pouring them into containers of used shop towels.
Contacts
- For
more information, contact the Delaware Department of Natural Resources
and Environmental Control (DNREC), Division of Air and Waste Management,
Hazardous Waste Program at 302-739-3689.
- To report an emergency spill or leak, call the DNREC 24-hour Release
Reporting Hotline at 800-662-8802, or 302-739-5072 (business hours),
or the National Response Center at 800-424-8802. Releases by transporters
must be reported by calling the 24-hour hotline at 800-662-8802,
or the DNREC at 302-739-3689 or 302-739-4580.
- To
report an environmental incident or complaint, contact the nearest
regional office, or call the Toll-Free
24-Hour Environmental Complaint Line.
Related
ECAR Fact Sheets
- Hazardous Waste
Other
Relevant Resources
- Delaware
— Automotive and Repair Shop Guidance
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