ECAR
Fact Sheet for
Indiana
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
Wipes
(industrial shop towels, rags, paper towels, gloves, cotton swabs,
etc.) are not hazardous unless they come into contact with hazardous
materials or hazardous wastes. As wipes are used to clean up spills
and remove oils, they become contaminated with automotive fluids
and cleaning solvents.
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.
The
Indiana Department of Environmental Management (IDEM) has prepared
a guidance document to help auto recyclers manage shop towels. Much
of that information is included in the fact sheet below. You can
access the link to IDEM's Compliance Manual for Auto Salvage Facilities
under Other Relevant Resources.
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, the state of Indiana 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.
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.
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.
The state of Indiana regulates disposable
wipes. If the products used at your facility contain any of the
following constituents, then the disposable wipes, when contaminated,
could exhibit hazardous characteristics and may be regulated as
a hazardous waste:
- heavy metals such as arsenic, barium, cadmium,
chromium, lead, mercury, selenium and silver;
- chlorinated solvents such as monochlorobenzene;
1,4- dichlorobenzene; 1,2-dichloroethane; 1,1-dichloroethylene;
pentachlorophenol; methylene chloride; trichloroethane; trichloroethylene;
tetrachloroethylene and any chlorinated fl uorocarbons; or
- toxic solvents such as benzene, toluene, xylene,
pyridine, 2-ethoxyethanol, methyl ethyl ketone, and 2-nitropropane.
If the products used at your facility
are a listed waste when discarded (i.e., contain a chemical or chemicals
found on one of the hazardous waste “lists”), the contaminated wipes
will automatically be a hazardous waste when disposed.
Contaminated
wipes that are laundered are not regulated as a hazardous waste
unless they are used to clean up spills of hazardous waste or a
hazardous waste is added to the container of wipes. However, they
are still regulated by Indiana's Office of Air Quality. Contact
IDEM for a list of laundry facilities.
Links
to the Regulations. Use
the following links to view the regulations pertaining to shop towel
management and storage.
Indiana Hazardous Waste
Regulations (Article 3)
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. You
can manage used wipes in a couple of different ways, depending upon
the type of wipes that are used and the contaminant(s) that have
been absorbed.
Laundered Wipes. If you are sending reusable
wipes that exhibit hazardous waste characteristics to a laundry,
you must:
- Store contaminated wipes in closed containers
to prevent the evaporation of any contaminants into the air; and
ensure that storage containers are not accumulating free liquids
in the bottom of the container.
- If the container has free liquids, transfer the
free liquid into another container and manage by its hazardous
classification. Laundries will not accept wipes containing free
liquids.
Disposable Wipes.
- Make a
hazardous waste determination on used wipes. If the wipes are
a hazardous waste, they
must be managed accordingly.
- Wipes must
not be air dried as a means of removing ignitable or toxic characteristics
prior to disposal.
- Store contaminated
wipes in closed containers to prevent the evaporation of any
contaminants into the air
- 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 Indiana Department of Environmental Management
(IDEM) at 800-451-6027 or 317-232-8603.
- Report spills and environmental emergencies immediately
to IDEM by telephone at 1-888-233-7745.
- Submit
a pollution complaint online through the IDEM Pollution Complaints Clearinghouse.
Related
ECAR Fact Sheets
- Hazardous
Waste
Other
Relevant Resources
- Indiana Auto Salvage
Program Website
- Indiana Auto Salvage Compliance Manual
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