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).

1. 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.
2. Rags, sorbents, pads, used to clean up spills of hazardous waste are considered “residues” and require handling as hazardous waste.
3. Use drip pans when removing fluids to keep the generation of sorbents (rags, pads, speedy dry, etc.) to a minimum.
4. 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.
5. 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

1. For more information, contact the ME DEP, Office of Remediation and Waste Management at 207-287-2651.

2. 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.

3. To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Maine Shop Towel Guidance

2. Maine's Handbook for Hazardous Waste Generators

3. Maine's Motor Vehicle Recycling Website

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