ECAR
Fact Sheet for Nebraska
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 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.
Regulations
The
state of Nebraska gives specific guidance on how to manage shop
towels, as follows:
- Wipers that have been contaminated with a listed hazardous
waste are regulated as a listed hazardous waste when disposed.
- Whether
the solvent is applied to an object and cleaned or applied to
the wiper prior to use results in the same waste. The department
does not make any distinctions on how the spent solvent got
onto the wiper. The wiper would be a listed waste either way.
- Wipers
that are a characteristic hazardous waste must be managed as
a hazardous waste.
- Wipers
contaminated with listed waste listed solely because it exhibits
one or more of the characteristics of hazardous waste present
a special circumstance. If these wastes no longer exhibit a
characteristic of hazardous waste, they are not considered hazardous
waste. However, non-wastewater mixtures are still subject to
land disposal restrictions even if they do not exhibit a characteristic
at the point of land disposal.
Laundering
Shop Towels. If the contaminated rags are to be commercially laundered
and reused rather than disposed of, the state of Nebraska will give
auto recyclers somewhat of a break by excluding them from the hazardous
waste regulations.
Solvent
wipers that will be cleaned or laundered and reused are considered
to be in continued use. As a result, these wipers have not been
discarded and are not a solid waste. This is contingent upon the
following:
- The container used to hold the soiled wipers and the wipers
contain no free liquid. If there were free liquids, there is
the assumption that hazardous waste could be being disposed
incident to the wiper laundering or cleaning.
- The
commercial cleaner or laundry receiving the soiled wipers must
be in compliance with applicable environmental regulations such
as the Clean Water Act for laundries.
- The
commercial cleaner or laundry receiving the soiled wipers is
not required to obtain a hazardous waste treatment, storage,
or disposal permit for the wiper cleaning because the wipers
are not considered to be a solid, and hence, a hazardous waste.
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.
Nebraska's 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).
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 a commercial laundry service. Verify that dirty shop towels are
managed correctly and picked up for laundering by a commercial
laundry service. 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 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
- For more information, contact the Nebraska Department
of Environmental Quality (NDEQ) Waste Management Program at 402-471-2186.
- To report a spill or leak, call the NDEQ spill hotline
at 402-471-2186, or 402-471-4545 (weeknights, weekends and holidays).
- To report an environmental incident or complaint, contact
the nearest NDEQ
Regional Office
Related
ECAR Fact Sheets
- Hazardous Waste
Other
Relevant Resources
- Nebraska Guidance: Solvent Contaminated Shop Towels, Rags, and Wipers
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