ECAR
Fact Sheet for New Mexico
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.
The
New Mexico Environment Department (NMED) has prepared a guidance
document to help auto recyclers manage shop towels. You can access
the guidance for shop towels under “Other Relevant Resources.”
Regulations
In
the state of New Mexico, dirty rags/shop towels are subject to the
federal RCRA hazardous waste regulations, meaning that they need
to be collected in a proper container which is kept closed, labeled,
dated and inspected weekly, be managed under accumulation requirements,
and sent to a proper RCRA facility for disposal. However, if the
contaminated rags are to be commercially laundered and reused rather
than disposed of, the state of New Mexico will give auto recyclers
somewhat of a break by excluding them from the hazardous waste regulations.
The rags/towels need to be managed as hazardous waste only until
they are picked up by a commercial laundering service.
However,
to qualify for this exemption, there must be NO free liquids
present in the accumulated rags. Any free liquids must be managed
as hazardous waste and the entire rag/solvent mixture may be considered
a hazardous waste subject to regulation.
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.
The
below guidance is provided by the NMED Hazardous Waste Bureau (HWB):
- If
a spent rag or wiper contains a listed hazardous waste or exhibits
a hazardous waste characteristic (ignitable, corrosive, reactive,
or toxic), then the wiper will be regulated as a hazardous waste.
HWB has not made in the past, and does not make at the present
time, a distinction as to when a wiper becomes hazardous waste.
Once the wiper is no longer being used, it must be handled as
a hazardous waste if it meets the definition of hazardous waste.
Therefore, unless the generator is a Conditionally Exempt Small
Quantity Generator (CESQG) (generating less than 220 pounds
of hazardous waste per month), wipers meeting the definition
of hazardous waste would have to be manifested to a facility
having an EPA identification number.
- CESQG
facilities are only required to dispose of the hazardous waste
correctly. This means that wipers and rags that do not have
free flowing liquids can go to the local landfill if the landfill
will accept them. Contact the Solid Waste Bureau or the local
landfill for this determination.
- Laundering
of wipers is considered a form of reclamation since the spent
material, i.e. the wiper containing the contaminants, has been
used and as a result of contamination can no longer serve as
a cleaning agent without first being laundered to remove the
contaminants. Therefore, wipers that are stored on-site prior
to shipment off-site or reclaiming on-site must be stored in
compliance with state regulations. This regulation requires
that the wipers be stored in a closed container. The Occupational
Safety and Health regulations require this container to be metal
due to the possibility that spontaneous combustion might occur.
- If
the facility is a Small Quantity Generator (SQG) (generating
between 220 pounds and 2,200 pounds of hazardous waste per month)
or a Large Quantity Generator (LQG) (generating over 2,200 pounds
of hazardous waste per month) the requirements regarding storage
are much more complex with such conditions as an emergency communication
device, container labeling, weekly inspection of storage area,
portable fire extinguishers, and training for personnel, as
well as much more.
- In
the case of contaminated wipers being shipped to a laundry for
cleaning and reuse, other regulations such as the Clean Water
Act, may apply to the wash water. Many municipalities have their
own regulations regarding what can go down the drain, contact
the local wastewater treatment officials. The hazardous waste
regulations apply to the wipers only until they are actually
placed into the laundry process. An off-site laundry accepting
regulated wipers would have to obtain a hazardous waste storage
permit unless it washes the wipers within 24 hours.
Links
to the Regulations. Use
the following links to view the regulations pertaining to shop towel
management and storage.
New Mexico’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 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 New Mexico Environment
Department, Hazardous Waste Bureau at 505-428-2500.
- To
report a spill or leak, call the New Mexico 24-hour emergency
hotline at 505-827-9329. For non-emergencies, call 866-428-6535.
- To report an environmental incident or complaint, contact
the nearest regional office.
Related
ECAR Fact Sheets
- Hazardous Waste
Other
Relevant Resources
- New
Mexico – Contaminated Rags and Wipers Fact Sheet
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