ECAR Fact Sheet for Indiana
Shop Towels

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

BACK to VIRTUAL TOUR

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

1. For more information, contact the Indiana Department of Environmental Management (IDEM) at 800-451-6027 or 317-232-8603.

2. Report spills and environmental emergencies immediately to IDEM by telephone at 1-888-233-7745.

3. Submit a pollution complaint online through the IDEM Pollution Complaints Clearinghouse.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Indiana Auto Salvage Program Website
2. Indiana Auto Salvage Compliance Manual

BACK to VIRTUAL TOUR