ECAR Fact Sheet for North Carolina
Shop Towels

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

BACK to VIRTUAL TOUR

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

Wipe/Towel Laundering. Dirty shop towels are exempt from the RCRA 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). An industrial wastewater point source discharge that is subject to Section 402 of the Clean Water Act (NPDES permit) also qualifies for this exemption.

The exemption from RCRA regulation does not apply where laundering waste discharge is not regulated under the Clean Water Act. Some examples include discharge into a septic system/leach field or an unpermitted direct discharge.

The operator must accumulate wipes appropriately and safely (e.g., in a closed container as opposed to placement in a waste pile or other land disposal unit) to prevent the release of contaminants to the environment. Even though wipes that are to be laundered are not regulated as a hazardous waste, any release or contamination due to the mismanagement of contaminated wipes is a violation of North Carolina law.

You may not mix hazardous waste with wipes to be sent to laundering facilities.

You cannot dispose of hazardous waste at a commercial laundry simply because it is contained in an absorbent that is to be laundered. Absorbents specifically designed to contain releases and absorb significant amounts of contaminants (e.g., pig or booms), and wipes used to contain spills or releases, do not qualify for the laundering exemption. They are considered "solid wastes" and must be managed subject to RCRA regulation.

Disposal. 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. The North Carolina Department of the Environment and Natural Resources (NCDENR) provides guidance to businesses to help them determine if the wipes are hazardous, and if so, what type of hazardous waste. If the towels are hazardous, then you must manage them in accordance with hazardous waste regulations. Click here for more information.

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

North Carolina Hazardous Waste Management Regulations

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.

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 additional information, please contact the North Carolina Hazardous Waste Section at
   919-508-8400.
2. To report a spill or leak, call 1-800-662-7956.
3. To report an environmental incident or complaint, contact the nearest DENR Regional Office.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. NCDENR Guidance Document on Contaminated Wipes
   

BACK to VIRTUAL TOUR