Industrial Shop Towels: Pollutant Or Solid Waste
Not so, according to findings released by the U.S. EPA as part of an in-depth 'life-cycle analysis' report. Research data compiled by Lockheed/Martin Energy & Environmental Systems through an EPA contract was summarized in a lengthy report: "Life Cycle Assessment of Industrial Wipers." It concluded that rented/laundered shop towels may have a greater negative environmental impact than disposable towels and rags.
Commissioned as part of the data-gathering phase of EPA Office of Water rulemaking activity, waste management program administrators at both the state and federal level were surprised to learn:
- that the total volume of industrial wipers and rags that enter the solid waste stream is so small that it is not even calculated, as are other industrial wastes, and;
- that when commercial laundries wash shop towels the oils, greases, toxic heavy metals, and hazardous solvents are either transferred to the local sewer treatment plant in wastewaters or are concentrated in the washer sludge that, typically, also get landfilled.
The EPA Office of Water has identified 23 pollutants of concern (POC). These 23 hazardous substances - primarily organic chemicals and heavy metals including toluene, o & p-xylene, tetrachloroethene, napthalene, ethylbenzene, and bis (2-ethylhexyl) phthalate - are mostly unregulated in wastewater discharges from the commercial laundry industry. Usually, some of these hazardous pollutants cannot be treated by the local wastewater treatment plant - or 'pass through' - and are transferred directly to surface waters.
According to trade associations representing industrial laundries that rent and clean shop towels, 87 percent do not have sophisticated wastewater pretreatment equipment to rid their sewer discharge of these POCs that may pass through the system directly to surface waters. While most commercial shop towel rental laundries do employ some form of wastewater pretreatment, few can actually remove the POCs that EPA has suggested cause the greatest ultimate surface water contamination. Similarly, POTWs which are primarily designed to treat household sanitary wastes, have difficulty treating these POCs entering the wastewater stream from both commercial laundries and industry. The EPA report estimates that of the 13 million pounds of pollutants discharged into sewers by laundries every year, more than 5 million pounds of this toxic stew ends up in surface waters every year, a result of untreated pollutant 'pass-through.'
Rulemaking activityThe end result of this fact-finding effort is a recently proposed rule that could impact all commercial laundries cleaning more than 255,000 pounds of shop towels per year per facility (some laundries clean 255,000 pounds of towels every week): The "Categorical Pretreatment Standard for Commercial Laundries," becomes law in June of 1999 with a phased-in compliance schedule over the following three years.
The standard is likely to be challenged in court by the commercial laundry trade associations and may see further implementation delays. Enactment will require laundries that clean shop towels to install expensive effluent pretreatment equipment and increase the frequency of discharge monitoring and analysis to meet tightened pollutant limits.
According to the U.S. EPA Office of Water, if this law is passed as is, it will have a direct cost impact on the commercial shop towel laundry industry of $83 million per year. These costs combine the expense of purchasing, installing, and maintaining pretreatment equipment as well as the cost of the required periodic wastewater effluent sampling, analysis and reporting. The commercial laundry trade associations are convinced that the real cost impact on their membership will force a few laundries out of business. POTWs will be required to regulate, monitor and enforce these rules.
Stakeholders respondDuring the public comment period in late 1997 and early 1998, individual laundry operators, suppliers of disposable wipers, laundry trade associations, and the disposable wiper trade associations submitted exhaustive comments on the proposed regulation with their own perspectives. Many POTWs submitted written comments based on laundry wastewater treatment experiences within their own systems. Some POTWs are in favor of additional categorical standards while others would rather see fewer.
The Uniform & Textile Services Association (UTSA), representing most commercial shop towel rental laundries, encouraged its members to mail form letters to the EPA Office of Water, professing undue hardship if the proposed standard were adopted unchanged. Claiming considerable regulation by local industrial wastewater authorities, the laundry association's position is that sufficient regulation exists locally and no federal categorical standard is necessary. Its position seems contrary to the fact that Boston's Metropolitan Water Resources Authority limits simple oil and grease discharges (or total petroleum hydrocarbons - TPH) at 10 mg/l while Detroit regulates TPH at 2000 mg/l. The majority of the POCs that EPA has included in the standard are completely unregulated by local POTWs. Clearly, local regulation by POTWs is inconsistent encouraging commercial laundries to locate in areas of the country where wastewater discharge regulations are less stringent.
Spearheaded by David Dunlap, UTSA's Director of Environmental Affairs, UTSA believes that no further regulation of the shop towel rental laundry industry should be imposed. Understandably, the association would like to protect the interests of its member laundries, although actual shop towel rental and cleaning services represent only 10% of commercial laundry business activities, while creating 90% of their wastewater effluent problems. UTSA has amassed a considerable war chest devoted to launching legal challenges over this issue. David Trimble at TRSA, the Textile Rental Services Association, has joined forces with UTSA in this battle, sharing similar positions.
Meanwhile, both INDA - The Association of the Nonwoven Fabrics Industry - representing nonwoven wiper manufacturers, and SMART - the Secondary Materials And Recycled Textiles association - representing textile wiper (rag) manufacturers, share the conviction that under State and Federal RCRA (Resource Conservation & Recovery Act) hazardous waste management laws their industry has been heavily regulated since 1976 as to how their products are intended to be disposed of, while commercial laundries are at liberty to accept, transport, clean, and return shop towels that are laden with RCRA-regulated hazardous substances with virtually no oversight.
Peter Mayberry, director of government affairs at INDA agrees with Bernie Brill, executive vp at SMART who commented, "No level playing field exists for suppliers of laundered reusable wipers and single-cycle disposable varieties. This in spite of the fact that EPA's own research suggests that laundered wipers present a negative cumulative multimedia environmental impact while disposables tend to retain and minimize landfill mobility of wiper contaminants." Disposable wiper varieties, now commonly referred to as 'single-cycle wipers,' are either manufactured from recycled pulp and paper, virgin polypropylene and similar plastics or converted from used clothing and other textiles, enjoying the benefit of recycled origins.
Related regulatory actionIronically, the EPA's Office of Solid Waste is developing its own rule regarding management of solvent-containing disposable wipers. EPA's James O'Leary has devoted considerable time and energy to this project for several years and recently released an interim report characterizing the historical management practices employed by users of disposable wipers. Findings revealed in the report suggest that most solvent-laden disposable wipers pass the 'Liquid Release Test' (One-Drop Test) prior to disposal and represent a minimal negative environmental impact on landfills, the most common post-use management technology employed. The interim report indicates that some form of mechanical fluid removal prior to disposal may be included in their final rulemaking effort, for either disposable or reusable shop towels. RCRA regulation flexibility may be incorporated into their final rule, in contrast to the typical strict interpretations imposed since 1976 for those wipers contaminated with regulated substances. Wiper users tend to agree that only a small percentage of industrial wipers, whether disposable or reusable, are contaminated with regulated substances, most finding applications with essentially unregulated oils and greases. All of the regulatory activity may be of little consequence to most wiper users except printers and other solvent-intensive applications.
Impact on industrial wiper usersIn all likelihood, industry may be less resistant to using disposable wipers as an environmentally-preferred option in spite of the popular misconception that rented laundered wipers are more environmentally friendly. Similarly, many state and federal waste management regulators who have commonly recommended the use of rented, laundered wipers as a 'pollution prevention' activity may revise their posture in view of the facts about true environmental impact. Users of rented shop towels will no doubt see increased prices as the commercial shop towel rental laundries 'pass-through' these additional costs of compliance to their customers.
For additional information contact:Ms. Marta Jordan, U.S. EPA Office of Water, (202) 260-0817
James O 'Leary, U.S. EPA Office of Solid Waste, (703) 308-8827
David Dunlop, UTSA, (703) 247-260
David Trimble, TRSA, (202) 833-6395
Bernie Brill, SMART, (301) 656-1077
Peter Mayberry, INDA, (202) 828-2329