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ECAR
Fact Sheet for
Virginia
Shop Towels
 
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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.
Regulations
Used rags/shop towels are subject
to the 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 Virginia 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.
Auto recyclers 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,
auto recyclers 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.
Links to the Regulations. Use
the following links to view the regulations pertaining to shop towel
management and storage.
Virginia
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 only if they are managed correctly and picked up for
laundering by an industrial 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. Follow
proper procedures for recovering excess liquids and be sure to
handle those liquids according the requirements.
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 "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 Virginia Department of Environmental Quality Division of Waste
Management at 804-698-4000.
- To report a spill or leak, call
1-800-468-8892.
- To report an environmental incident
or complaint, contact the nearest DEQ
Regional Office.
Related
ECAR Fact Sheets
- Hazardous
Waste
Other
Relevant Resources
None.
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