From: GaryJGATF (email@example.com)
Date: Wed Jan 21 1998 - 10:52:04 CST
Your question regarding disposal of laundry rags is a timely one. EPA is
currently examining this situation, but does not have any regulations or
guidance. Therefore, the appropriate source of guidance on this issue is the
state regualtions. You do not mention what state you are in. I have a copies
of almost all of the state policies on the regulatory status of shop towels. I
will fax you a copy of the state you are interested in.
Generally, the state policies are very simular. They do not regulate the type
of solvent used on the towels. They only address the management standards that
need to be followed. If these are followed, then the towels are not considered
a hazardous waste if they are sent off-site for laundering. If the towels are
disposed as solid waste and are contaminated with a solvent that would be
classified as hazardous, then they would have to be managed as a hazardous
waste which includes a manifest.
For Pennsylvania, the following is a summary of the required management
standards for reusable shop towels:
The towels need to be collected in closed containers which is required under
40 CFR 265.173 and 29 CFR 1910.106(e)(9)(iii). In order to allow the reusable
shop to avoid being classified as a hazardous waste, the PADEP policy on used
towels needs to be followed. According to the PADEP policy the shop towels
need to be:
1) Not saturated and pass the paint filter test (EPA SW846, Method 9095).
2) Be reused and not disposed.
3) Stored away from sources of ignition and in a manner to prevent worker
exposure to vapors from volatile solvents.
4) Either laundered on-site or sent to a commercial off-site laundry facility.
contractual agreement with the off-site laundry must available to the DEP
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