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Regulations BACK to VIRTUAL TOUR 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. 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. 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 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.
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.
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