ECAR
Fact Sheet for Iowa
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
Dirty
rags/shop towels are subject to the 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, auto recyclers get 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.
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.
Auto
recyclers 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, auto recyclers 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.
Soiled
cloth rags sent to a laundry facility are not considered a waste
since they are being reused. Wastewater from washing the rags is
the responsibility of the laundry facility. Be aware that laundry
facilities will not accept rags with excessive amounts of oil or
solvent. Wring rags into the appropriate container (i.e used oil
into the used oil container) before sending them to the cleaner.
Store dirty rags in a container that will not absorb oil or leak.
Partially used rags can be stored separately and labeled for reuse
prior to laundering.
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. Disposable
rags contaminated with a listed hazardous waste are hazardous. Switching
to launderable cloth rags will minimize this waste stream and eliminate
the need for testing the rags. 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.
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). 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.
- 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, contact the Region 7 Environmental
Protection Agency at 913-551-7020, or the Iowa Department of Natural Resources at 515-281-8941.
- To
report a spill or leak, call the Iowa hotline at 515-281-8694
as soon as possible but not later than 6 hours after the onset
or discovery of the spill or leak. If the release involves EPA-regulated
material and the amount released is above EPA reportable quantities,
it must also be reported to the National Response Center at 800-424-8802
within 15 minutes.
- To report an environmental incident or complaint, contact
the Iowa DNR.
Related
ECAR Fact Sheets
- Hazardous Waste
Other
Relevant Resources
-
Automotive Products Disposal Directory
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