Goodman wiper and paper is a major recycler.

If you still have questions after reading this, please call or e-mail us for more information.

Trying to understand the technical and legal terms of state and federal environmental regulations can be like trying to understand a foreign language. However, understanding the truth about paper, cloth, or other textile "wipers" can help you avoid unnecessary legal concerns and problems in the future.

Some have interpreted the laws to say that users of laundered or rental wipers somehow are relieved of the legal liability associated with the oil, ink, solvent, or other chemicals often used with the wipers. This is not true!

There is also confusion about what is and is not hazardous waste.
This information will help you sort through some of the confusion, and get to the facts about regulations regarding wipers and legal liabilities. It will help you avoid the risks associated with noncompliance of environmental regulations.

What do the regulations really say?

Laws relating to the disposal of hazardous waste contained in wipers had their origins in the Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act of 1976 or "RCRA." Because of the enormous scale of differing regional environmental concerns, RCRA rules most commonly are interpreted and enforced by the individual state's environmental agencies. (This is true for all states except Wyoming, Iowa, Alaska, and Hawaii.)

Under EPA's existing hazardous waste "Mixture Rule," when a wiper contaminated with hazardous waste is thrown away, it should be treated as a hazardous waste. If that same wiper is laundered, then the water used to clean the wiper may be declared hazardous, and waste water regulations apply. The generator is not relieved of this liability when wipers are cleaned.

In fact, the contamination in question could possibly spread the generator's liability even further through the waterways.

The EPA does not distinguish between launderers (rentals) and cloth or paper disposable wipers. The waste generator (you) has legal responsibility and liability for the waste "from cradle to grave," regardless of whether the wiper is laundered or disposed.

Having the wiper laundered by a third party does not relieve the waste generator of the legal liability of improper disposal of those wastes by the third party.

The Uniform & Textiles services Association (formerly the Institute of Industrial Launderers) does not support any claim that customers can escape liability for improper disposal of waste from wipers by a laundry, rental, or uniform company.

What exactly is hazardous waste?

The EPA guidelines include two categories of hazardous wastes:

1. "Listed hazardous wastes" include those wastes that are hazardous because of what they are. (The EPA has an actual list on which these wastes appear.)

2. "Characteristic hazardous wastes" are wastes that exhibit at least one of the following characteristics: toxic, corrosive, ignitable, or reactive as determined by laboratory testing.
Most solvents--as well as inks, paints, oils, cleaners, or other common industrial chemicals used by industry today--have a "Material Safety Data Sheet" (MSDS) which accompanies their purchase. This is where the materials and status indicating the level of toxicity are listed.

What are the common types of products used with wipers?

What we know about oil:
The EPA has stated that incidental, or very small amounts of oil do not constitute a hazardous waste. Incidental is defined by a simple test, often called the "One-Drop Test." This is performed either mechanically or by hand wringing the wiper. If no oil drips from the wiper, then the wiper is considered to be nonhazardous. (Any oil collected from this test must be combined with other waste oil from the facility.) The wiper then may be disposed of as a solid waste. Please check with your state's department of environmental services to be certain.

What we know about solvents:
Due to the fact most solvents typically have a very high evaporation rate, there are only small amounts of solvent remaining on a wiper at the time of its disposal. EPA regional offices and state regulators frequently have offered conflicting interpretations on the regulations concerning this issue. There are some states that allow the One-Drop Test while others do not. The good news at this time is the EPA is considering a rule change to exempt wipers from the category of "hazardous" when the contaminant is a solvent.

What we know about inks, paints, and stains:
Because of the increasing pressure on paint manufacturers to produce "environmentally safe" products, these industries are leading the way in the research and production of high quality, water-based, nontoxic alternatives to the traditional stains, paints, and inks. There are numerous nonhazardous alternatives on the market today. In the unlikely event an application calls for a material that is hazardous, refer to the label or the MSDS for proper disposal.

What we know about industrial chemicals:
Because of the thousands of chemicals used by industry today, it would be impossible to attempt a description of each. And because a relatively small number are used in conjunction with wipers regularly, it is advisable to refer to the MSDS to select the best disposal option.
In all of the above cases, please check with your state’s department of environmental services to be certain of the proper disposal methods.

Are there environmental benefits of disposable wipers?

Failing to understand these regulations have led many companies to mistakenly believe wipers from a rental, uniform, or laundry service are some how safer and easier to use than disposables. It is a fact that using wipers that are laundered and returned does not relieve your company of liability. It even could increase your exposure; since once the wipers are transported out of your facility, you no longer have control over the wiper, yet you still have the liability should it be handled incorrectly. When disposed of through a legitimate solid waste firm, you are assured the wipers are managed in accordance with sound solid waste management practices.