ECAR Fact Sheet for Oregon
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 commercial off-site laundry facility that meets the appropriate state and local requirements to handle such material, or if they are laundered on-site.

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 Oregon Department of Environmental Quality (DEQ) has prepared a guidance document to help auto recyclers manage shop towels. Much of the information is included in the fact sheet below. You can access the guidance for contaminated rags destined for laundering under "Other Relevant Resources."

Regulations

The Oregon DEQ encourages the use of laundered, reusable wipers whenever possible to reduce waste. If you meet the following conditions, you will not be required to manage your shop towels as a hazardous waste:

• The used wipers contain no free liquids as identified by the paint filter test (EPA SW-846, Method 9095);
• The used wipers are stored and transported in fire resistant DOT closed containers (lidded drums), away from sources of ignition;
• Containers holding used wipers are labeled to identify the contents (e.g., "Dirty Rags Destined For Laundering");
• No other wastes are mixed with the used wipers;
• The used wipers are either laundered on-site or sent to a commercial off-site laundry facility that meets the appropriate state and local requirements to handle such material. In most cases, this would mean that the laundry is regulated under a municipal sewer pretreatment permit; and,
• You have a contractual agreement with the laundry to clean the used wipers and return clean wipers back to your facility.

This exemption applies only to rags or wipers which are laundered for reuse and meet the above conditions.

If rags or wipers are disposed, treated prior to disposal, or do not meet any of the above conditions, they will be considered a solid waste and be subject to a waste determination and applicable hazardous waste regulations.

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

Oregon Hazardous Waste Regulations

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 are either laundered on-site or sent to a commercial off-site laundry facility that meets the appropriate state and local requirements to handle such material. Verify that dirty shop towels are managed correctly. If rags or wipers are disposed, treated prior to disposal, they will be considered a solid waste and be subject to a waste determination and applicable hazardous waste regulations
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.

• Make sure the used wipers contain no free liquids.
• Ensure the used wipers are stored and transported in fire resistant DOT closed containers
• Label containers holding used wipers properly;
• Do not mix other wastes with the used wipers;
• Launder on-site or send to a commercial off-site laundry facility that meets the appropriate state and local requirements; and,
• Ensure you have a contractual agreement with the laundry to clean the used wipers and return clean wipers back to your facility.

Contacts

1. For more information, contact the Oregon Department of Environmental Quality (DEQ) at 503-229-5696 or 800-452-4011 (toll-free in Oregon).
2. To report a spill or leak, contact the Oregon Emergency Response System (OERS) at 800-452-0311.
3. To report an environmental incident or complaint, contact the nearest DEQ Regional Office.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. OR Vehicle Dismantlers webpage

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