Checklists: Check Rags: Rags Information Shop Tour Stop #1 (Final Stop)
|The following questions and guidance are taken from the
Consolidated Screening Checklist For Automotive Repair Facilities.
A ‘√’ next to a response in the guide indicates that is the preferred response in terms of environmental compliance. If you select a response without a ‘√’, you may still be in compliance; however, you should verify that you are in compliance by contacting the appropriate federal or state regulatory agency and discussing your activity with them.
USED SHOP RAGS/TOWELS
A facility must manage used shop rags and towels as hazardous waste if they are contaminated with a hazardous waste or display a hazardous characteristic due to the presence of gasoline or metal-contaminated antifreeze. EPA allows facilities to manage these used rags and towels by having them washed through a laundry service, or disposing of them at an approved or ‘permitted’ disposal facility.A facility can recycle used shop rags and towels contaminated with used oil by burning them for energy recovery under the Used Oil Management Standards existing for burning used oil. According to the used oil regulations, facilities should handle oil-contaminated rags and towels as used oil until the oil is removed from them. EPA considers used oil satisfactorily removed when no visible sign of free flowing oil remains in the rags/towels. Note: After used oil has been removed, one may still need to handle the material as a hazardous waste if it contains a hazardous waste or exhibits any property of hazardous waste. Many shops avoid the hazardous waste determination process by sending rags to a laundering facility for washing, rather than disposal.
Shop Rag/Towel Laundering: Many states do not consider shop rags going to a laundry service to be hazardous waste (although a hazardous waste could be generated by the launderer). Even if shop rags are contaminated with hazardous waste, they are not being discarded. Therefore, the hazardous waste requirements do not apply. Check with your state hazardous waste agency on requirements for managing shop rags/towels.
How does the facility manage/dispose of used shop rags and towels?
How does the facility store used shop rags and towels stored on-site?
|Source: U.S. EPA Office of Enforcement and Compliance Assurance, EPA 305-B-03-004, October 2003.
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