ECAR
Fact Sheet for Maine
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. You may be able to be exempt from the full
burden of hazardous waste management rules if you send your towels
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.
The
Maine Department of Environmental Protection (ME DEP) Small Business Assistance Program has prepared a guidance
document to help auto recyclers manage shop towels. Much of the
information is included in the fact sheet below. You can access
the guidance for shop towels under “Other Relevant Resources.”
Regulations
Shop towels are used for general
maintenance and spill clean up. Rags may be used to wipe down parts,
etc. Sorbent boom and pads are used for collecting oil from spill
events. If you handle materials that become classified as hazardous
wastes with rags then this combination of things will also require
handling as a hazardous waste.
Prevent hazardous waste from accumulating
by minimizing the volume that is generated and by segregating your
wastes. Better still, don’t use unnecessary chemicals and processes
that create hazardous waste to begin with.
Shop towels should be laundered for reuse (don’t launder rags if the wastewater
goes to a septic system), or properly disposed of as a solid waste.
The shop towels must be essentially dry with no free flowing or
dripping liquids and have flashpoint less than 140 degrees F.
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.
Maine's Solid/Hazardous
Waste Management Requirements
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).
- Are rags (or wipes) that have been used for
cleaning laundered for reuse or properly disposed of as a solid
waste? (Note: These cleaning rags must be essentially dry with
no free flowing or dripping liquids and have flashpoint less than
140 degrees F.) don’t launder rags if the wastewater goes to a
septic system.
- Rags, sorbents, pads, used to clean up spills
of hazardous waste are considered “residues” and require handling
as hazardous waste.
- Use drip pans when removing fluids to keep the
generation of sorbents (rags, pads, speedy dry, etc.) to a minimum.
- Consider coating your floor surface for easy
clean up of fluids. Using squeegee or other similar implements
can easily capture any spilled materials with minimal spread of
liquids and use of sorbents.
- In the case of an oil spill, petroleum-contaminated
sorbents (rags, pads, speedy dry materials, etc.) require handling
as a 'special waste' and disposal at a properly licensed facility.
Contact the ME DEP to properly report the spill and receive guidance
on handling the volume and type of 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 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."
- 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 ME DEP, Office of Remediation and Waste Management at 207-287-2651.
- To report a spill or leak of
hazardous waste, call the ME DEP 24-hour hotline at 800-452-4664.
To report an oil spill, call the 24-hour hotline at 800-482-0777.
For more detailed spill response procedures, access the ME
DEP's Emergency and Spill Response website.
- To report an environmental incident or complaint, contact
the nearest
regional office.
Related
ECAR Fact Sheets
- Hazardous Waste
Other
Relevant Resources
- Maine Shop Towel Guidance
- Maine's
Handbook for Hazardous Waste Generators
- Maine's Motor
Vehicle Recycling Website
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