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ECAR
Fact Sheet for
Vermont
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.
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.
- 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.
- 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
- For
more information, contact the Vermont Department of Environmental
Conservation, Waste Management Division
at 802-241-3888.
- 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.
- To
report an environmental incident or complaint, call 802-241-3820,
or contact the nearest regional enforcement
officer.
Related
ECAR Fact Sheets
- Hazardous Waste
Other
Relevant Resources
- Vermont
- Shop Rags Guidance Document
- Vermont -
Shop Rags and Oily Waste Guidance
- Vermont EAD
- Auto Salvage Yard Environmental Resource Center
- Vermont
- List of Permitted Hazardous Waste Transporters
- Vermont
- List of all Permitted Transporters
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