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What to do with your used absorbents and rags.
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
Source: https://www.epa.gov/smm/sustainable-materials-management-non-hazardous-materials-and-waste-management-hierarchy
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:
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.
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.
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:
Who regulates used oil absorbents and shop rags?
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.
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.
Illinois
Indiana
Michigan
New York
Ohio
Pennsylvania
South Carolina
Texas
Wisconsin
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.
Links:
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:
The preferred method for handling used absorbents is that they are recycled or reused. Some companies will clean absorbents after they have been used.
Illinois EPA
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.
Links:
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.
Links:
From the PDEP site:
Absorbents:
Rags
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.
Links:
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.
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.
Links:
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.
Links:
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.
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.
Links:
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.
Links:
From the DEC site:
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.
Links:
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:
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
On top of all the time spent understanding and maintaining your knowledge of disposal requirements, here are some costs to consider:
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.