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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. The New Hampshire Department of Environmental Services (DES) has prepared a guidance document to help auto recyclers manage contaminated wipers/shop towels. Much of the information is included in the fact sheet below. You can access the DES's “Contaminated Cloth Wipes for Laundering,” document under Other Relevant Resources. The New Hampshire Department of Environmental Services (DES) has created specific guidance for wipers contaminated with minor amounts of hazardous waste constituents that are to be laundered. The DES defines "contaminated wipers" as rags, shop towels, and wipers which have been used, contaminated with minor amounts of hazardous waste constituents such as solvents or oils, and are intended to be laundered before reuse. Contaminated wipers must be managed in a manner that will not pose a threat to human health or the environment. Other wastes, including spill absorbent materials and debris, do not meet the definition of contaminated wipers and therefore are not to be laundered or mixed with contaminated wipers destined for laundering. The DES has created the following management requirements for contaminated wipers. If you do not manage your contaminated wipers in an environmentally sound manner as described below, you can and shall be subject to full regulation under the state's hazardous waste and other applicable rules. No Free Liquids. The contaminated wipers shall contain no free liquids as identified by the paint filter test (PFLT,EPA SW 846 method 9095) or the liquids release test (LRT, EPA SW 846 method 9096). Any contaminated wiper that fails one of the tests may release free liquid hazardous waste constituents. Storage Requirements. Contaminated wipers must be placed in containers such as lidded drums or sealed laundry bags. The containers are to be closed and sealed at all times except when it is necessary to add or remove the contaminated wipers. The containers must also be stored away from sources of ignition. Labeling Requirements. The container must be labeled "Contaminated Wipers for Laundering" in order to prevent incompatible materials and wastes from being placed in the container. Transport Requirements. The contaminated wipers are to be managed and transported in accordance with the United States Department of Transportation standards. Off-Site Laundering Requirements. If laundering contaminated wipers off-site, the following requirements must be met:
On-Site Laundering Requirements. On-site laundering of the contaminated wipers can be done, provided that industrial wastewater is discharged in compliance with applicable state and federal permits (i.e., local pretreatment permit or NPDES permit ). Links to the Regulations. Use the following links to view the regulations pertaining to shop towel management and storage. New Hampshire Hazardous Waste Management Requirements 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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