ECAR Fact Sheet for Michigan
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. 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.

This fact sheet will help you recognize some of the most common materials that can turn shop towels into hazardous wastes.

Regulations

Dirty shop towels are exempt from hazardous waste regulation 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). All shop towels/solvent wipers are eligible for this exclusion if the wipers contain no free liquids and are sent to a commercial laundry that is subject to regulation under the Clean Water Act or a dry cleaner. Let the cleaning company know what type of chemicals you are using with the towels so they can determine the best way to clean them and the affect on their own waste stream.

All rags and soiled clothing that contain flammable materials must be stored and transported in fireproof containers.

If shop towels are not reused, then you must determine if your dirty shop towels are hazardous or not before disposing of them. Towels that are spontaneously combustible are a D001 hazardous waste. Towels may be a listed waste depending on what and how solvents are used. If the towels are hazardous, which they most likely are, then you must manage them in accordance with hazardous waste regulations.

Links to the Regulations. Use the following links to view the regulations pertaining to shop towel management and storage.

Michigan's Natural Resources and Environmental Protection (Act 451), Part 111 regarding Hazardous Waste Management and administrative rules

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.

1. 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.
2. Do your shop towels contain free liquids? If so, there is no hazardous waste exemption for rags or soiled clothing contaminated beyond saturation.
3. Keep waste shop towels in a closed, fireproof metal container labeled "Used Shop Towels." If being handled as hazardous waste, then label the containers with the date waste first put in container, the waste code, and the words "Hazardous 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 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 MDEQ's Environmental Assistance Center at 1-800-662-9278.
2. For reporting spills/releases and pollution emergencies, contact: 1-800-292-4706.

Related ECAR Fact Sheets

1. Hazardous Waste.

Other Relevant Resources

1. DEQ Guide for Salvage Yard Owners
   

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