FAQ Calendar
About What's New News ECar Fact Sheets Compliance Pollution Prevention Resource Files Ask ECar Links

 

ECAR Fact Sheet for Vermont
Shop Towels

 

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

BACK to VIRTUAL TOUR

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 VT DEC has prepared guidance documents to help auto recyclers manage shop towels. Much of the information is included in the fact sheet below or you can access the guidance for shop towels under “Other Relevant Resources.”


Regulations

Oily Wastes. Under Vermont's hazardous waste regulations, any wastes that are contaminated with greater than 5% by weight of petroleum distillates are considered to be hazardous wastes. Oily wastes are routinely generated during the servicing of vehicles and include oil soaked sorbents, shop towels, sludge and grit, and floor sweepings.

Any of these materials that contain 5% or more by weight of oil must be managed as a hazardous waste. If you are not sure of the amount of oil in these wastes, a one-time test of the material can be done to determine the level of oil present. Copies of the test results should be kept on file. Prevention is best way to reduce the amount of this material that requires disposal as a hazardous waste.

Shop Towel Exemption. In the state of Vermont, shop towels and other reusable absorbents contaminated with “listed” hazardous wastes, or that exhibit a hazardous waste “characteristic” are considered exempt from the provisions of the state's hazardous wastes regulations under the following conditions:

  • The shop towels or absorbents are picked up, cleaned and delivered back to the facility under a contractual agreement with a commercial laundering service that uses either a solvent-based dry cleaning or a water-based laundering process to clean the rags/absorbents;
  • The hazardous waste has not been disposed of onto the rags and free liquid hazardous waste is not present;
  • Any hazardous waste-contaminated reusable absorbents that are on-site are stored in closed bags or containers on an impervious surface in a roofed enclosure so they are protected from the elements;
  • The containers are labeled as “Used Rags or Absorbents Destined for Laundering”; and
  • The laundering facility properly manages all residuals and waste from the laundering process.

If all of the above management requirements are met, shop rags, towels and reusable absorbents that have been soiled with hazardous wastes do not have to be managed as hazardous waste.

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.

Vermont's Hazardous Waste Management Requirements

Vermont's Solid 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. Shop towels are exempt from hazardous waste regulations if they are managed correctly and picked up for laundering by a commercial laundry service. Make sure the shop towels are picked up, cleaned and delivered back to the facility under a contractual agreement with a commercial laundering service that uses either a solvent-based dry cleaning or a water-based laundering process to clean the rags/absorbents, and that the laundering facility properly manages all residuals and waste from the laundering process.
  2. Are your shop towels stored and labeled properly? Hazardous waste-contaminated reusable absorbents that are on-site should be stored in closed bags or containers on an impervious surface in a roofed enclosure so they are protected from the elements. Label the containers “Used Rags or Absorbents Destined 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.
  • 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 Rags or Absorbents Destined 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 for at least 3 years.

Contacts

  1. For more information, contact the Vermont Department of Environmental Conservation, Waste Management Division at 802-241-3888.
  2. To report a spill or leak, call the Vermont Division of Waste Management at 802-241-3888 (weekdays), the 24-hour spill reporting hotline at 800-641-5005, or the National Response Center at 800-424-8802.
  3. To report an environmental incident or complaint, call 802-241-3820, or contact the nearest regional enforcement officer.

Related ECAR Fact Sheets

  1. Hazardous Waste

Other Relevant Resources

  1. Vermont - Shop Rags Guidance Document
  2. Vermont - Shop Rags and Oily Waste Guidance
  3. Vermont EAD - Auto Salvage Yard Environmental Resource Center
  4. Vermont - List of Permitted Hazardous Waste Transporters
  5. Vermont - List of all Permitted Transporters


BACK to VIRTUAL TOUR


About | What's New | News | ECar Fact Sheets | Compliance | Pollution Prevention | Resource Files | Ask ECar | Calendar

©2010 ECAR "The Driving Force for Environmental Compliance"