ECAR Fact Sheet for Wisconsin
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 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.

1. Determine if your solvent contaminated rages or wipes are hazardous waste and manage them accordingly.
2. If they are not considered hazardous waste, make sure you comply with applicable storage, labeling and transportation requirements.
3. 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.
4. 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.

1. Avoid using disposable towels. Use cloth towels from an industrial laundry service that is discharging its wastewater into a public sewer system.
2. Do not dispose of solvents by pouring them onto rags or into containers of used shop towels.
3. Do not saturate your towels. If you do, wring them out and reuse the liquid.
4. Do not throw dirty wipes, paper towels or rags into the dumpster if they have come into contact with hazardous solvents or waste.
5. Do not dispose of dirty shop towels in vehicles to be crushed or shredded.
6. Keep waste shop towels in a closed, fireproof metal container labeled “Dirty Solvent Rags Only.”
7. To reduce the risk of spontaneous combustion when storing shop towels in metal cans, keep the towels moist with water.
8. 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.
9. Maintain records of analytical waste determinations and disposal receipts for at least 3 years.

Contacts

1. 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.

2. 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

1. Hazardous Waste

Other Relevant Resources

1. Wisconsin - Solvent Contaminated Shop Towels Guidance Document
2. Wisconsin's Auto and Scrap Recycling Website

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