Laundered Shop Towels: 15 - Why I spend the effort

Caveat emptor: "Let the buyer beware."

I could leave it at that and make this a very short post.

Here is what drives me to spend my free time researching and writing about the misuse of science by those scientists and professionals to which we have an implied trust that their conclusions and findings are unbiased and sound.

Kimberly-Clark wants to sell more disposable wipes.  They used a PE, two public health PhDs (one an ex-EPA director), and "an environmental and risk science consulting firm renowned for their expertise in Toxicology, epidemiology, Risk Assessment, Product Safety, Contaminant Fate and Transport, and Environmental/Forensic Chemistry." to imply a risk when using a competitor's product to increase sales. (1)

Dr. Andrew Wakefield "a medial researcher who published his work in the Lancet stood to gain financially from his purported findings because of his involvement in a lawsuit against manufacturers of the MMR vaccine." (2)

Chiropractors, who hold doctorate degrees, bill our insurance providers for services using "cold laser" and "applied kinesiology."

Alisa Rich, who holds a Masters in Public Health and is now a PhD that has been hired to teach risk as an Adjunct Professor at UNT, insists that her air sampling "confirmed the presence in high concentrations of carcinogenic and neurotoxin compounds in ambient air near and/or on residential properties" in the town of Dish, Texas. (3)

Caveat emptor?

No, I choose to write about their findings and methods in an attempt to educate and explain why their premise is false.  It's easy to call someone wrong and leave it at that. I choose to support it, because at the end of the day these professionals - who by their education, association, and credentials - infer our trust, make money and further an agenda at someone else's expense.

And what is that expenses?  Not just money lost due to fear, but the added stress that results from that fear.  How many children remain un-vaccination for preventable childhood diseases because of fear of Autism?

How many Dish residents worry about neurological problems and cancer?  How many folks living in the town of Dish Texas are fearful of the gas wells in their city?  They are fearful based on what a group of highly credentialed and learned scientists have put out in front of them as their potential risk?

"And what does these posts on shop towels have to do with hazardous waste?" one might be wondering?  Well in a roundabout way, understanding how we assign a health risk to an item or activity all works towards protecting public health and the environment.

It is a difficult enough job balancing the need to make a profit with the EHS goal of protecting employee and public health as well as the environment.  A worker believing that his employer may be harming him by forcing him to use a contaminated laundered shop towel, now sets in motion the need to prove there is no harm.  I am pretty sure that's exactly what Kimberly-Clark was aiming for based on their brochure.  How does the EHS department prove there is no risk when this Gradient report - written by a former EPA administrator and PhD - claims there is?

So, fine...take the easy way out and stop using laundered shop towels.  Problem solved.  Except Kimberly-Clark forgets to tell its customers that when you use a disposable shop towel, that towel will be discarded making it a solid waste which will then require a hazardous waste determination to be made.  That's not an issue when you use a laundered shop towel.

Here is what the EPA has to say about laundered shop towels:

Reusable wipes are part of a more systematic handling system. In general, a laundry owns reusable industrial wipes, rents them to generators, and collects them for laundering on a regular basis. Generators receive deliveries of wipes from the laundries, use them, and accumulate used wipes. Drivers, most often employed by the laundries, pick up the contaminated industrial wipes, replacing them with clean wipes at the same time, and then return the soiled wipes to the laundry. Once at the laundry, the wipes are then counted to assure the laundry is getting back from the generator the same number sent out and, finally, are cleaned before entering the cycle again.

This lead the EPA...

In the early 1990s, EPA developed a policy that deferred determinations and interpretations regarding regulation of solvent-contaminated industrial wipes to states authorized to implement the federal hazardous waste program or to the EPA region in the cases where a state is not authorized.

...and because of this policy a bit of confusion:

This policy led to the application of different regulatory schemes for both types of industrial wipes in EPA regions and states. Although the states differ in the details of their policies, in general, they regulate disposable industrial wipes as a hazardous waste when they are contaminated with a solvent that is listed or exhibits a hazardous waste characteristic. On the other hand, many, but not all, states provide regulatory relief for reusable contaminated wipes sent to an industrial laundry or other facility for cleaning and reuse. In about half the cases, this regulatory relief is in the form of an exclusion from the definition of hazardous waste, whereas other states provide an exclusion from the definition of solid waste.

The substantive difference between these two approaches is that materials excluded from the definition of solid waste are not considered a waste at all, and are not subject to Federal RCRA regulation, whereas materials excluded from the definition of hazardous waste are considered to be wastes that, when certain conditions are met, do not need to be managed as hazardous wastes.  

For reusable industrial wipes, the conditions for the various exclusions vary from state to state, but most require that the containers of wipes not contain free liquids, and require that the laundry discharge to a Publicly Owned Treatment Works (POTW) or be permitted under the Clean Water Act. Some states have established other requirements such as requiring generators to manage contaminated wipes according to the hazardous waste accumulation standards prior to laundering, and requiring generators to file a one-time notice under the land disposal restriction (LDR) program

Laundered shop towels are considered reusable.  Reusable shop towels that are laundered and the wash water sent to a POTW or discharged under a NPDES permit are NOT hazardous waste.  Using Kimberly-Clark disposable shop towels WILL be solid waste and MAY meet the defintion of a hazardous waste.

You can see the problem Kimberly-Clark faces here.  How do they counter the reality that each and every one of their disposable shop towels will require a hazardous waste determination where as none of that is required if you use a reusable shop towel, especially one that is laundered.

It's all about the words "reusable" and "disposable."  And Kimberly-Clark's plan to counter that?  Convince workers that laundered shop towels contain "Concentrations of metals in laundered shop wipes can result in exposures (as evaluated using the methodology presented in this report) which exceed toxicity criteria for certain metals." (4) and then ask them "Why take the risk?" (5)

So this brings up an interesting question for Kimberly-Clark.  If laundered shop towels exceed toxicity criteria, what would be the toxicity criteria for a disposable shop towel that has not been cleaned with soap and water and dried under heat?

Well?

Interesting question, especially when you read this little bit of information from that same EPA proposed rule found in the Federal Resister (Vol. 68, No. 224 / Thursday, November 20, 2003).

Specifically, in 1985, EPA received a petition, pursuant to 40 CFR.260.20, from the Kimberly-Clark Corporation, a manufacturer of disposable industrial wipes, that asked EPA to exclude disposable wipes from the definition of hazardous waste. The petition stated that these materials are over-regulated because the amount of solvent in the wipes is insignificant and because the disposable wipes do not pose a threat to human health and the environment even when disposed of in a municipal solid waste landfill. In 1987, EPA received a second rulemaking petition from the Scott Paper Company that reiterated many of Kimberly-Clark’s points and added that the hazardous waste regulations are not necessary because contaminated disposable wipes are handled responsibly, make up just 1% of a generator’s waste stream, and could be beneficial to the operation of incinerators because of their heat value.

Kimberly-Clark has been dealing with this issue of hazardous waste determination for their product for a long time.  Allowing laundered shop towels to be managed outside of RCRA presents a disadvantage to Kimberly-Clark.  Guess what?  I agree with Kimberly-Clark!  I think that the great majority of all shop towels if properly managed, laundered, reused, burned for energy, or disposed in a Solid Waste landfill -  do not pose a threat to human health and the environment.

The wheels of regulatory change, however, move much too slow to have this issued resolved correctly.  Since 1985, 2003, and then in 2010 it remains unresolved. Still, Kimberly-Clark, you cannot have it both ways.

Spent shop towels are either a risk to human health and the environment or they are not.  Don't even think about telling me there is a difference between putting it to the face and putting it in a landfill.  TCLP anyone!
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So I spend my time researching and writing this blog to help me understand the manipulated world around me.  I am not so foolish to believe my blog will change anything.  Misinformation is exactly what they want and use, and they have the power and structure to keep it up.  I mean, look how many people buy those silly latex "holographic" bracelets for balance? (see Power Balance)

Still, the internet does provide room for all different types of voices, even mine.  It's there for anyone to see and use.  It's the best I can do to counter bad science, even if it is read by so few and buried within the noise produced by search engine algorithms somewhere on page 9 or 10.

If it clears the air for one person and helps them make a sound decision to stop or move forward, then it's time well spent.

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