ECAR
Fact Sheet for Minnesota
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
Mercury, a highly toxic metal, is
often found in hood or trunk light switches. Liquid mercury and
mercury vapor are hazardous to both humans and the environment.
Once released into the environment, mercury cannot be eliminated
— it will stay in the environment forever. Just one-half pound of
mercury, the amount found in approximately 450 trunk or hood lights,
has the potential to contaminate one-half million northern pike.
Already, 94 percent of Minnesota lakes have mercury contamination
at a level that limits human fish consumption. Removal of mercury
switches from vehicles before crushing is an important part of managing
your hazardous wastes.
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 regulations if they are managed correctly and picked up for
laundering by an industrial laundry service that is connected to
a local wastewater treatment facility. All shop towels/solvent wipers
are eligible for this exclusion if the wipers contain no free liquids
(completely wrung out) and are sent to a commercial laundry that
is subject to regulation under the Clean Water Act. However, specific
handling regulations depend on the type of substance contained in
the towel. See the Minnesota
Pollution Control Agency (MPCA) Fact Sheet on Managing Towels, Wipes
and Sorbents.
If sorbents are picked up weekly
or more often, keep a chart of pick-up dates and pounds picked up.
(In this case, an accumulation start date and weekly container inspection
is not necessary.)
All rags and soiled clothing that
contain flammable materials must be stored and transported in fireproof
containers, marked "Hazardous Waste — Solvent Sorbents [Towels/Wipes]."
If a shop towel service is not used,
then you must determine if your dirty shop towels are hazardous
or not before disposing of them. If the towels are hazardous, then
you must manage them in accordance with hazardous waste regulations.
Whether you are sending the towels
to be laundered or disposing of them as hazardous waste, you must
remove free liquid by wringing. Reuse extracted liquid or manage
it as hazardous waste.
Links to the Regulations. Use
the following links to view the regulations pertaining to shop towel
management and storage.
Minnesota
Hazardous Waste 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.
- 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 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
Minnesota Pollution Control Agency (MPCA) Regional Office closest
to you:
- Northeast Region (Duluth) 218-723-4660.
- North Central Region (Brainerd)
218-828-2492.
- Northwest Region (Detroit Lakes)
218-847-1519.
- Southwest Region (Marshall) 507-537-7146.
- Southeast Region (Rochester) 507-285-7343.
*Report petroleum and fuel spills
of five or more gallons, and any other chemical spill (including
lead-acid batteries) which may cause pollution, to the State Duty
Officer at 651-649-5451 or 1-800-422-0798.
Related
ECAR Fact Sheets
- Hazardous
Waste.
Other
Relevant Resources
- ASP Audit Checklist - Towels, Wipes, Sorbents
- Managing Towels, Wipes and Sorbents (4 pgs)
- Motor
Vehicle Salvage Facility Environmental Compliance Manual
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