Printreg Archive
Re: Shop Towel On Site Recycling


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From: GaryJGATF (gjonesprinting@aol.com)
Date: Fri May 08 1998 - 14:06:24 CDT


Dear Andrew:

The answer to you question lies in how the shop towels are classified with
respect to their status under the hazardous waste regulations. Many states do
not regulate the towels as hazardous if they are not saturated, which means
they pass the paint filter test or in Mass, the one-drop test. You should
check with the state or let me know which state and I will provide a copy of
the state policy to you.

If they are hazardous, then transportation can only occur with a licensed
transporter. However, if the facility is an exempt quantity generator (less
than 220 lbs/mo hazardous waste) or a small quanitity generator (220-2,200
lbs/mo), they may be able to self-transport without a license. However, some
states do not allow for the self-transportation of hazardous waste. You will
need to check with the state or states that this facility is located in. In
addition, you will have to follow any applicable DOT requirements as well. I
don't know all of the DOT regulations and would suggest you contact them at
202/366-4488.

If the towels are not classified as hazardous, then they could be self-
transported without a problem as far as EPA is concerend. You would, however,
still have to comply with DOT.

One final thought is that you would also have to be careful that the state
would not require a permit for the cleaning equipment. Some states would
consider cleaning towels treatment and would require a permit.

Gary Jones
Graphic Arts Techncial Foundation


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