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ECAR
Fact Sheet for
Wisconsin
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 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.
The
Wisconsin Department of Natural Resources (WDNR) has prepared a
guidance document to help auto recyclers manage shop towels. You
can access the link to WDNR's Shop Towels guidance document under
Other Relevant Resources.
Regulations
Dirty
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 reused rather than disposed of, the state of Wisconsin
will give auto recyclers somewhat of a break by excluding them from
the hazardous waste regulations.
If
you are able to reuse your solvent-contaminated rags or wipes, the
WDNR does not require that you manage them as solid or hazardous
waste if you meet the following requirements:
- Store solvent contaminated rags or wipes in a covered container away from ignition
sources.
- Label containers “Dirty Solvent Rags Only.”
- Do not place different types of solvent contaminated material in the same container.
- Do not put other waste in a container of solvent contaminated rages or wipes.
- Handle solvent contaminated rages or wipes using an approved management practice such as laundering. You should have a contractual agreement for this
service.
Disposal
of Rags/Wipes No Longer Usable. Solvent contaminated rags or wipes
that are no longer reusable may be centrifuged and managed as solid
waste, as long as they are burned for energy recovery in a solid
waste to energy combustion unit. You must used a licensed solid
waste transporter, and a bill of lading to track bales to their
fuel blending locations. If the rags or wipes are hazardous waste,
you must use a hazardous waste transporter.
It
is not recommended that you dispose of contaminated rags
or wipes in solid waste landfills due to liability concerns.
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 reusing or disposing of them. If they
are hazardous, they must be managed in accordance with hazardous
waste regulations. See the ECAR Hazardous
Waste Fact Sheet.
Transportation.
If the rags or wipes will be laundered
and reused, and environmentally safe management practices are used
before and during transport, a transportation license is not required.
A
solid waste and sometimes, a hazardous waste transportation license
is required when rags are transported to facilities where they will
not be reclaimed.
Links
to the Regulations. Use
the following links to view the regulations pertaining to shop towel
management and storage.
Wisconsin Hazardous
Waste Regulations (NR 590.01-690.81)
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.
- Determine
if your solvent contaminated rages or wipes are hazardous waste
and manage them accordingly.
- If
they are not considered hazardous waste, make sure you comply
with applicable storage, labeling and transportation requirements.
- When
rags or wipes are no longer usable, make sure they are centrifuged
and managed as solid waste, having them burned for energy recovery
in a solid waste to energy combustion unit.
- Do
not dispose of the solvent contaminated rags or wipes in a solid
waste landfill.
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 “Dirty Solvent Rags Only.”
- 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 Wisconsin's DNR Auto Salvage Sector
Resource Specialist at 715-831-3263, or contact the WDNR
Regional Office in your area. For northern Wisconsin, call
715-635-2101 or 715-365-8900; West Central Wisconsin,
call 715-839-3700; Northeast Wisconsin, call 920-492-5800; Southeast
Wisconsin, call 414-263-8500; and, for South Central Wisconsin,
call 608-275-3266.
-
All
spills should be immediately reported using Wisconsin's 24-hour
toll free hotline at 800-943-0003. If you discover a discharge
through analysis of soil or water, use the Hazardous
Substance Release Fax Notification Form.
Related
ECAR Fact Sheets
- Hazardous Waste
Other
Relevant Resources
- Wisconsin -
Solvent Contaminated Shop Towels Guidance Document
- Wisconsin's Auto and Scrap Recycling
Website
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