ECAR Fact Sheet for New York
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.

This fact sheet will help you recognize some of the most common materials that can turn shop towels into hazardous wastes.

Regulations

Dirty shop towels are exempt from 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).

The following conditions must be met:

• Any soiled rags or soiled clothing containing free liquids are subject to full regulation. There is no exemption for rags or soiled clothing contaminated beyond saturation.
• Rags and soiled clothing must be managed in accordance with New York State regulations (see link below) until the materials are sent for laundering and must be counted as wastes generated and accumulated for the purpose of determining generator category.

All rags and soiled clothing that contain flammable materials must be stored and transported in fire proof containers.

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. If the towels are hazardous, then you must manage them in accordance with hazardous waste regulations.

Links to the Regulations. Use the following links to view the regulations pertaining to shop towel management and storage.

New York Conservation Rules and Regulations on Hazardous Waste Management (NYCRR 372)

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. Shop towels are exempt from regulation only 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). Verify that dirty shop towels are managed correctly and picked up for laundering by an industrial laundry service that is connected to a publicly owned treatment works facility (POTW). You must manage your shop towels in accordance with the hazardous waste requirements until they leave your operations.
2. 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 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

1. For general questions, contact DEC Solid and Hazardous Materials Program at 518-402-8651.
2. New York State Spill Hotline: 1-800-457-7362.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Automobile Recycling home page
2. New Requirements for Vehicle Dismantlers
3. A Quick Look at Your Automobile Recycling Facility
4. Forms for Auto Recyclers
5. Summary of Laws, Rules and Regs Relating to Auto Recyclers
6. Resource Guide for Auto Recyclers

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