Does your facility generate shop towels? Shop towels are commonly used to collect paints, solvents, petroleum products, dyes or other residues associated with industrial machinery. Many facilities recycle their shop towels through an industrial laundry. If shop towels are discarded, the nature of the contamination associated with the towels determines whether the towels are considered a hazardous or otherwise regulated waste.
West Virginia has been authorized by the United States Environmental Protection Agency (USEPA) to administer the Resource Conservation and Recovery Act (RCRA). The West Virginia Department of Environmental Protection (WVDEP) determines how contaminated towels are regulated within the state. Contaminated shop towels are considered a solid waste. However, if the towels contain a listed hazardous waste or exhibit a characteristic of a hazardous waste, they become a hazardous waste and must be handled as such until they are cleaned.
The transportation of a hazardous waste generally requires the use of a “cradle-to-grave” manifest. However, facilities classified as either a Conditionally Exempt Small Quantity Generator (generating 100 kilograms or less per month of hazardous waste, or 1 kilogram or less per month of acutely hazardous waste) or a Small Quantity Generator (generating more than 100 kilograms, but less than 1,000 kilograms, of hazardous waste per month) do not need hazardous waste manifests to transport used shop towels for cleaning and re-use.
The USEPA has recently begun investigating air toxic emissions from industrial laundries in New England that treat shop towels contaminated with volatile organic compounds consisting of methyl ethyl ketone, toluene and xylene. The USEPA levied a $65,000 penalty against the G&K Services facility in Manchester, New Hampshire and the company has agreed to upgrade their pollution control equipment. Additionally, 17 industrial laundries in New England reportedly are under investigation by state and/or federal regulators regarding toxic emission controls at their facilities.
It is likely that additional scrutiny by the USEPA into industrial laundering facilities around the county will follow. This anticipated scrutiny may well extend to the individual businesses that generate and store industrial shop towels prior to shipment for cleaning.
This article was authored by William Chambers, Acacia Environmental Group LLC. For more information on the author see here.