ECAR Fact Sheet for New Hampshire
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 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.

Regulations

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:

• Any industrial wastewater discharge from a commercial laundry must be in compliance with applicable state and federal permits (i.e., local pretreatment permit or National Pollutant Discharge Elimination System NPDES permit).
• You must have a contractual agreement in place with the commercial laundry that documents that the contaminated wipers are being laundered. Copies of the contractual agreements and related receipts must be retained by you and remain available for inspection by Department personnel

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

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. Are you in compliance with the requirements for laundering your contaminated wipers? If laundering contaminated wipers off-site, any industrial wastewater discharge from a commercial laundry must comply with applicable state and federal permits, and you must have a contractual agreement with the commercial laundry. If laundering on-site, the industrial wastewater must be discharged in compliance with applicable state and federal permits.
2. Are you storing and labeling your contaminated wipers properly? 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, and must be stored away from sources of ignition. The container must be labeled "Contaminated Wipers for Laundering."

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 "Contaminated Wipers for Laundering."
• 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.

Contacts

1. For more information, contact the New Hampshire DES Waste Management Division at
   603-271-2900.
2. To report a spill or leak during business hours, call the DES at 603-271-3899. If after hours or the weekend, call the New Hampshire State Police Hazardous Material Response at 800-346-4009 (in-state), or 603-271-3636 (out-of-state).
3. To report an environmental incident or complaint, contact the nearest regional office or link to the DES Public Information Center.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. New Hampshire - Contaminated Cloth Wipes for Laundering

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