ECAR
Fact Sheet for
Florida
Shop Towels
 
Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
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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.
Part
261 - Identification and Listing of Hazardous Waste
Part
262 - Standards Applicable to Generators of Hazardous Waste
Self-Audit
Checklist
When
an inspector comes to your facility, there are certain things they
check 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 used oil storage areas and management
procedures.
- 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 used oil storage areas and management procedures.
- 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,
wipers, or rags that are used for this purpose.
- Maintain
records of analytical waste determinations and disposal receipts
for at least 3 years.
Contacts
- DEP
Hazardous Waste Compliance Assistance Program: 800-741-4337.
Related
ECAR Fact Sheets
- Hazardous
Waste
Other
Relevant Resources
- Shop
Towel Pollution Prevention Fact Sheet
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