You are here: Home/Blog / Compliance1 / How to Dispose of Used Rags and Oil Absorbents [2020 Compliance Guide]2
The Ultimate Guide: How to Dispose of Used Rags and Oil Absorbents
Wondering what the proper method is to dispose of your oil-soaked rags and absorbents?
In this guide, we will review disposal options (and alternatives – such as incineration and reuse), compliance requirements, environmental impact, and cost implications.
Chapter 1: Disposal options and alternatives
Chapter 2: Compliance basics and vocabulary
Chapter 3: Federal compliance decision guide (infographic)
Chapter 4: State compliance
Chapter 5: Cost implications
Chapter 6: Conclusion
Disposal Options and Alternatives
Before you determine how to properly dispose of your shop rags or absorbents, you should be aware of all your options – including alternatives, such as reuse.
First, when speaking strictly in terms of disposal, you have several options, including the following:
- Waste to Energy – This is the process of generating energy in the form of electricity and/or heat from the primary treatment of waste.Cons: This disposal method may emit fine particulate, heavy metals, trace dioxin and acid gas into the air. It also requires proper management of residues like toxic fly ash and incinerator bottom ash, and therefore must be treated as a waste.
- Incineration – Incineration is waste destruction in a furnace by controlled burning at high temperatures.Cons: Incinerators generate smoke. The smoke from the chimneys includes nitrogen oxide, particulates, heavy metals, acid gasses, and the carcinogen dioxin.
- Special Waste (non-hazardous) – This refers to garbage that requires special handling and assessment, processing, transportation, packaging, and/or additional disposal techniques. This includes petroleum-contaminated soil, stabilized grit and bar screenings, absorbent booms and pads, pit sludge, and sandblast mediaCons: Despite special treatment, the waste is still a landfill liability
- Landfill – This is regular garbage disposal. Non-hazardous waste is spread in layers, compacted and covered with earth at the end of each day.
Beyond disposal, you also have environmentally-preferred alternatives for managing your dirty shop towels and absorbents.
Bottom Line: You can skip the hassle of disposal by exploring reuse solutions such as a towel service or oil absorbent service.
EPA’s non-hazardous materials and waste management hierarchy ranks management strategies from most to least environmentally preferred. The hierarchy places emphasis on reducing, reusing, and recycling as important elements of sustainable materials management.
In the event that you have exhausted all options to reduce the number of absorbents and shop rags used at your facility through source reduction, reuse is the most preferred method on the EPA waste reduction hierarchy.
Reusable shop towel and reusable absorbent programs are typically offered by an industrial laundry service company and include a service program where the towels and absorbents are picked up, delivered, and laundered on a regular schedule.
[Compare disposable shop rags vs. a towel service]
The benefit of a reuse program is that you do not have to make a waste determination on your shop towels or absorbents (as long as there is no free-standing liquid) because they are not considered waste according to federal regulation.
Use SorbIts®, the world’s #1 Reusable Absorbent Solution
SorbIts® are the environmentally-preferred alternative to disposable oil absorbents. These launderable, reusable oil absorbents are trusted by the world’s top manufacturers to handle large industrial spills and everyday leaks, drips, and spills.
Compliance basics and vocabulary
Waste disposal is highly regulated by the Environmental Protection Agency (EPA), state agencies, and other stakeholders such at the Department of Transportation or even your local municipality. For example, the EPA and state agencies require many types of record keeping, labeling, and the use of proper containers. Municipalities may impose additional storage requirements.
In our research on the proper disposal and waste management methods for used absorbents and rags, the requirements were not always clearly defined. Some terms are subject to interpretation. So in your quest to determine how to manage your soiled absorbents and rags, keep in mind there may not be a finite answer and, as always, regulations are subject to change.
Here is the vocabulary you should be familiar with:
- Hazardous waste – What is considered a hazardous waste? In a discussion with Jodi Drew, Environmental Engineer at ITU AbsorbTech, the answer is not a simple one. For example, what the EPA considers a hazardous waste may not be the same as how your state environmental protection agency defines it. In addition, how the material is handled (for example, whether is it discarded, recycled, or properly wrung out from a rag) can also determine if it is a hazardous waste or even a waste at all.
- Used Oil – Please refer to this EPA Reference Table for a complete list of what use oil is, and is not, according to the EPA. Some exmaples include used synthetic oil, used engine oil, used transmission fluid, and industrial hydraulic fluid. Keep in mind that your state agency may define it differently. Remember that you cannot mix used oil with other wastes or it will all be waste.
- Solvent – For the purpose of this article, we will not be addressing solvent or solvent-contaminated wipes. Please refer to our EPA Wiper Guide for more information on this topic.
- Absorbents – Socks, pads, rags, mats, pillows, sawdust, paper towels, cardboard. Note, some states define absorbents separately from rags.
Who regulates used oil absorbents and shop rags?
- U.S. EPA, Resource Conservation and Recovery Act (RCRA)
- Occupational Health and Safety Association (OSHA) – Primarily for safe storage requirements
- State Environmental Protection Agencies
- Local ordinances
- Local fire marshals (they may require solvents and soiled absorbents to be stored in a certain manner)
- Department of Transportation (DOT)
- Insurance Companies
Bottom Line: Waste disposal is highly regulated, particularly if it’s a hazardous waste, and can vary by location. Check all EPA, OSHA, state agency, and municipality regulations.
Storage of Used Rags and Absorbents
How you store used oil absorbents or rags again takes into account whether there is free-standing liquid. All used cleanup materials, from rags to sorbent booms, that contain free-flowing used oil also must be handled according to the used oil management standards.
Make sure containers are in good condition and don’t allow for rust, leaks or deterioration. Inspect them regularly for drip marks, discoloration, cracks, leaks, and pooling.
If there is no free-standing liquid, and the rags or absorbents do not contain fluid other than used oil
(EPA Reference Table), the EPA does not have any further storage requirements. Some states or municipalities, however, may have additional requirements. In Ohio, for example, drums should be labeled ‘used oil.’
Bottom Line: Inspect storage containers regularly for drip marks, discoloration, cracks, leaks, and pooling. Determine if your state agency or municipality requires special labeling on the containers.
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The EPA has a helpful page that links to all state environmental protection agencies, and their respective hazardous waste programs.
To save you some time, we took a look at some of the top states we service and compiled the compliance language and resources that reference used absorbent and rags. Please note, some states group absorbents and rags together, while others treat them separately. Please contact or refer to these sites for detailed information.
Click on your state below.
Don’t see your state? Locate your state environmental protection agency.
Department of Natural Resources (DNR)
In partnership with individuals and organizations, the DNR manages fish, wildlife, forests, parks, air and water resources while promoting a healthy, sustainable environment and a full range of outdoor opportunities.
From the DNR site:
Used oil absorbents are materials used to absorb petroleum-derived or synthetic oil that has been used or spilled. Examples include granular kitty litter-type absorbents; oil-dry cloths; rags; wipes; paper toweling; and absorbent pillows, pads and socks.
Oil absorbents can be disposed of in a landfill if:
- Waste oil has been drained so that no visible signs of free-flowing oil remain in or on the oil absorbent materials, and
- The oil absorbent materials are not hazardous waste, as defined in 289.01(12), Wis. Stats
The preferred method for handling used absorbents is that they are recycled or reused. Some companies will clean absorbents after they have been used.
The mission of the Illinois EPA is to safeguard environmental quality, consistent with the social and economic needs of the State, so as to protect health, welfare, property and the quality of life.
From the Illinois EPA site:
You should choose absorbents that can be recycled or have the potential for beneficial reuse whenever possible.
In general, the easiest and most effective way to manage used rags is to launder them. Used rags that are laundered are not considered a solid waste and therefore are not a hazardous waste. Therefore, testing of the rags and other hazardous waste requirements are not necessary. In addition, using a laundry service can save you money by reducing rag purchase and disposal costs.
Absorbents contaminated with used oil from which the used oil has been properly drained or removed are not considered used oil unless the absorbent contaminated with used oil is burned for energy recovery.
Used absorbents contaminated with hazardous substances other than used oil, especially solvents, paints, and inks, should be evaluated as potential hazardous waste and managed accordingly.
Department of Environmental Protection (PDEP)
The Department of Environmental Protection’s mission is to protect Pennsylvania’s air, land, and water from pollution and to provide for the health and safety of its citizens through a cleaner environment.
- https://www.dot.state.pa.us/ (Page 9)
From the PDEP site:
- Make a determination if the used absorbent is hazardous or not, and managed according to hazardous or non-hazardous determination.
- If determined to be hazardous (likely if absorbent was used to clean up hazardous material/waste spill), manage as hazardous waste.
- If material is non-hazardous (oily spills), store in leak-proof container. Make sure no free liquid is present. Dispose as a municipal waste.
- Separate oily rags from other used rags that may be potentially ignitable (contaminated with solvents, etc.).
- Air-dry before storing in designated containers. Used shop rags should not be “wet” or contain free liquids when stored.
- Do not dispose of in municipal trash. PennDOT’s policy is to recycle all shop rags through an approved laundry or vendor service.
Indiana Department of Environmental Management (IDEM)
IDEM has grown to a staff of 900+ and employs some of Indiana’s most qualified engineers, scientists and environmental project managers specializing in air, land, pollution prevention and water quality issues.
From the IDEM site:
Sorbents (absorbent material such as pigs, pillows and socks) are not hazardous unless they come into contact with hazardous materials or hazardous wastes.
- If a facility’s sorbents are contaminated only with used oil, the sorbents may be disposed by burning for energy recovery under the used oil rule. In order to comply with the used oil rule, a facility must properly manage its oil-contaminated sorbents (i.e., don’t mix other wastes with these sorbents), and it must either recycle sorbents or send them for disposal at a permitted facility that burns them for energy recovery.
- If a facility cannot manage its sorbents and spill waste under the used oil rule (e.g., because of contamination with a waste other than used oil), it must make a hazardous waste determination and manage them accordingly.
- If used sorbents are determined not to be a hazardous waste, and they do not drip or accumulate free liquids (such as in the bottom of their storage container), a facility may dispose of them with its regular trash.
Texas Commission on Environmental Quality (TCEQ)
The Texas Commission on Environmental Quality strives to protect the state’s public health and natural resources consistent with sustainable economic development. Their goal is clean air, clean water, and the safe management of waste.
From the TCEQ site:
Absorbent materials with signs of free-flowing oil are managed as used oil. If there are no visible signs of free-flowing oil, these materials are not regulated as used oil— unless they are burned for energy recovery. If they are to be disposed of in a landfill, absorbent materials are solid waste and subject to a hazardous waste determination. Before landfill disposal, the generator is required to: determine the amount of waste to be disposed of, explore reuse/recycling options, contact the landfill about its restrictions, and obtain prior approval from the TCEQ Municipal Solid Waste Permits Section on a case-by-case basis.
The best approach is to prevent spills and thereby minimize the need for used oil absorbents. However, once this waste is generated, there are several options for proper management. Recycling such absorbents by reuse or by burning for energy recovery is the next most desirable option, followed by bioremediation and incineration. TCEQ considers disposing of used oil absorbents in landfills the least environmentally responsible option.
Ohio Environmental Protection Agency (OEEF)
The Ohio Environmental Protection Agency is a state agency whose goal is to protect the environment and public health by ensuring compliance with environmental laws.
From the OEEF site:
Used oil is any oil, synthetic or refined that has been contained in various items and these items would be regulated as used oil until materials containing or otherwise contaminated with used oil from which the used oil has been properly drained or removed to the extent possible such that no visible signs of free-flowing oil remain in or on the material. Examples include: Oil Filters, Absorbent materials, Shocks or struts, Transmissions, Engines. Once the used oil is drained from these items, they are no longer regulated by the used oil rules.
- Label containers or tanks of used oil with the words “Used Oil.”
- Store used oil in container or tanks that are in good condition (not leaking, rusting).
- If there is a leak of used oil, stop the leak, contain it, clean it up properly, and properly manage the cleanup materials.
- Use a transporter with an EPA identification number when shipping used oil off site.
- Do not mix your used oil with other wastes unless you are sure that you are complying with the appropriate regulations.
Department of Health and Environmental Control (DHEC)
The mission of the DHEC is to improve the quality of life for all South Carolinians by protecting and promoting the health of the public and the environment.
- https://live-sc-dhec.pantheonsite.io/sites/default/files/media/document/R.61-107.279.pdf (Pages 4-5)
From the DHEC site:
With the exception of materials containing or otherwise contaminated with used oil that are burned for energy recovery, materials containing or otherwise contaminated with used oil waste from which the used oil has been properly drained or removed to the extent possible such that no visible signs of free-flowing oil remain in or on the solid waste are:
(a) Not used oil and thus not subject to this regulation; and
(b) Solid wastes, and if the materials are listed or identified as hazardous waste, are subject to the
hazardous waste regulations R.61-79.260 through 266, 268, 270, and 124.
Used oil drained or removed from materials containing or otherwise contaminated with used oil
is subject to regulation as used oil under this regulation
New York State Department of Environmental Conservation Pollution Prevention Unit
The mission of the DEC is to conserve, improve and protect New York’s natural resources and environment and to prevent, abate and control water, land and air pollution, in order to enhance the health, safety and welfare of the people of the state and their overall economic and social well-being.
From the DEC site:
- Store shop towels and absorbents in separate metal containers with tight-fitting lids.
- Label containers “Contaminated Shop Towels Only” and “Oily Waste Absorbents Only,” as appropriate.
- If shop towels contain no free-flowing liquids, send them to a industrial laundry.
- Treat shop towels and absorbents containing used oil as hazardous wastes until properly managed.
Department of Environmental Conservation
The Michigan Department of Environmental Quality promotes wise management of Michigan’s air, land, and water resources to support a sustainable environment, healthy communities, and vibrant economy.
From the DEC site:
Disposable oil-contaminated wastes, like commercial sorbent pigs, rags, shop towels, cat litter or oil dry, and soils, can be sent to a licensed sanitary landfill if the waste meets all these conditions:
- Does not contain any free liquids (the materials pass the paint filter test) and the materials are either of the following:
- Not a hazardous waste, including sorbents used for cleaning up most oil spills; or
- Are hazardous waste generated only by a conditionally exempt small quantity generator [R 299.9205(2)]; and
- The landfill operator will accept oil contaminated materials.
- No other used oil or other waste was intentionally added to the sorbent waste material for disposal in a landfill.
Generators must handle the sorbents as hazardous waste if the material was used to clean up oily waste that was listed hazardous waste as defined by Part 2 Identification and Listing of Hazardous Waste administrative rules to Part 111 of Act 451. Generators must also evaluate used sorbents to determine if they exhibit one or more hazardous waste characteristic (e.g. ignitable, toxic) and handle them appropriately
How much does it cost to dispose of absorbents and towels
On top of all the time spent understanding and maintaining your knowledge of disposal requirements, here are some costs to consider:
- For disposal methods, costs can vary greatly by geography. It can also vary by the type of container (roll off, compactor, or by the drum) and how often they are serviced. Roll off and compactors are much less expensive to haul away than drums. As an example, we have seen a by-the-drum incineration cost at $185 per drum and special non-hazardous waste compactor at $250/haul.
- Inquire about all costs – delivery fees, fuels and/or environmental fees, minimum tonnage fees, rental fees, etc.
- Consider your time – manifesting your waste, keeping up with compliance requirements, etc.
- In most cases, reuse is a lower cost alternative to disposal. Please check out our calculator tool to compare the cost of a disposable absorbent program vs. reuse
- Compare the cost of a towel service program to buying disposables and discarding them
Bottom Line: Explore the true cost of disposal by evaluating your time (manifesting, keeping up with compliance), all disposal fees, and the ultimate cost to the environment.
While this document is not a definitive guide, it can help you make a decision on how to handle your used absorbents and rags – reuse, incineration, or disposal. If you plan to dispose of the absorbents, it’s important to know, either through testing or documented knowledge (such as Safety Data Sheets), the source of contamination (in other words, what is contained in the absorbent or rag).
Beware of storage requirements, and know your definitions (hazardous waste, used oil, solvent, etc.) by state. Most state agencies can provide additional guidance with a phone call. You can also contact Jodi Drew, our Environmental Engineer, at 888-729-4884 with questions.
Please note that it is your responsibility to know and follow the appropriate compliance guidelines for your facility per the requirements of all applicable entities.
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