Managing Textile Materials Soiled with Hazardous Waste

What are “reusable soiled textile materials?”

“Reusable soiled textile materials” means textile items, including, but not limited to, shop towels, uniforms, gloves, and linens and towels which have become soiled with hazardous waste (e.g., an F- listed solvent) during commercial or industrial use, and are made reusable by laundering or comparable methods of cleaning.

What requirements apply to generators of “reusable soiled textile materials”?

Generators of reusable soiled textile materials which are soiled with a listed hazardous waste, or which are identified as a characteristic hazardous waste, are subject to Chapter 12 requirements [Standards Applicable to Hazardous Waste Generators (except for the manifest requirement found in Article 2 –See below)] including accumulation time limits, labeling and use of appropriate accumulation units.

However, generators that send such materials for commercial laundering are exempt from the generator fee requirements under section 25205.5 of Health and Safety Code (HSC), the use of a manifest (to transport the textile materials), and hazardous waste transporter requirements under HSC, Article 6 and Article 6.5, if they meet the conditions in HSC 25144.6 including ensuring:

1. The materials were not used to clean up or control spills;
2. No hazardous waste has been added after their original use;
3. No free liquids are released during the transportation or storage; and
4. The facility laundering or cleaning the materials has a contingency plan and maintains records of the types and quantities of the materials collected and laundered.

Please note: California did not adopt the Federal exclusions for solvent-contaminated wipes.

Can paper products (e.g., paper wipes) qualify for the above exemption as a “reusable soiled textile material”?

No. Reusable soiled textile materials do not include paper products such as paper towels or wipes, because these are not made reusable by laundering or a comparable method of cleaning. Thus, paper products cannot qualify for the exemptions in section 25144.6 of Health and Safety Code.

Any paper product soiled with a listed hazardous waste or which has been identified as a characteristic hazardous waste is subject to Chapter 12 [Standards Applicable to Hazardous Waste Generators] and upon shipment must be transported by a registered hazardous waste transporter using a Uniform Hazardous Waste Manifest.

Are “reusable soiled textile materials” (e.g., rags) soiled with used oil hazardous waste?

It depends. Materials contaminated with used oil are considered used oil if they contain free flowing used oil. A material that meets the definition of used oil must be managed as a hazardous waste. Thus, rags that contain free flowing used oil are hazardous waste, but may be managed under the exemption for “reusable soiled textile materials” under section 25144.6 of Health and Safety Code.

However, if the rags do not contain free flowing used oil they do not meet the definition of used oil and thus may not be hazardous waste if the generator has determined the rags do not exhibit a characteristic of a hazardous waste. In this instance, the rags are nonhazardous and thus not subject to Hazardous Waste Control Laws, including the exemption in section 25144.6 of Health and Safety Code.

Are “reusable soiled textile materials” (e.g., rags), or paper wipes soiled with isopropyl alcohol, hazardous waste?

It depends. Isopropyl alcohol (IPA) is not a RCRA listed hazardous waste solvent; however, it may exhibit the hazardous waste characteristic of ignitability. This particular characteristic applies to the IPA as a liquid. Therefore, if the solvent contaminated rags or paper wipes do not contain free liquids (using the paint filter test) the rags or paper wipes are not hazardous for exhibiting the characteristic of ignitability.