ECAR Fact Sheet for Hawaii
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 flammable material in a towel, you haven't made it any less flammable. Depending on what they have been used for, shop towels may need to be managed as hazardous wastes. But you may be exempt from the full burden of hazardous waste management rules if you send your shop towels that are hazardous solely because the towels have absorbed a flammable/ignitable hazardous waste, which is not a F001-listed hazardous waste 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. (Note: Please contact the Hawaii Department of Health at 808-586-4226 for a specific description of F001-listed hazardous wastes)

Regulations

In the state of Hawaii, dirty rags/shop towels are subject to the federal Resource Conservation and Recovery Act (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 hazardous rags, which are hazardous solely because they are contaminated with a flammable/ignitable hazardous waste, except any F001-listed hazardous waste, are to be commercially laundered and reused rather than disposed of, the State of Hawaii will give auto recyclers somewhat of a break by excluding them from the hazardous waste regulations. These rags/towels need to be managed as hazardous waste only until they are picked up by a commercial laundering service.

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.

Hawaii's Hazardous Waste Management Requirements (unofficial online version)

Hawaii's Solid Waste Management Requirements (unofficial online version)

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.

1. Hazardous shop towels, hazardous solely because they are contaminated by an ignitable/flammable hazardous waste, except an F001 waste, 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.
2. 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.

• 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.
• Spray minimum amount of solvent onto rags instead of soaking rags.
• Use non-hazardous solvents whenever possible.
• 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," or "Hazardous Waste."
• 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

1. For more information, contact the Hawaii Department of Health (DOH), Solid and Hazardous Waste Branch, Hazardous Waste Section at (808) 586-4226.
2. To report a spill or leak, or to report an environmental incident or complaint, call the Hawaii Department of Health Office of Hazard Evaluation and Emergency Response 24-hour hotline at 808-247-2191, or 808-586-4249 during regular office hours.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Directory of Environmental Businesses in Hawaii, 2000
2. Hawaii Recycling Industry Guide

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