Laundered and Non-Laundered Wiping Products: Disputed Facts
Over the long history of this rulemaking process, the two trade associations that represent industrial launderers (Textile Rental Services Association and Uniform and Textile Service Association) have repeatedly made claims that are disputed by Association of the Nonwoven Fabrics Industry/Secondary Materials and Recycled Textiles Association. Specific examples include:
UTSA/TRSA Claim: This rulemaking is intended to establish national standards regarding the processing and disposal of used industrial wiping products.
INDA/SMART Response: The primary purpose of this rule is to better regulate spent industrial solvents contained on used wiping products. EPA has repeatedly specified that the purpose of this rule is to reduce the amount of solvent discharged to the environment, and to encourage recycling of used solvent,
UTSA/TRSA Claim: This rulemaking should promote greater use of laundered shop towels because they are more environmentally preferable than non-laundered alternatives.
INDA/SMART Response: There is no evidence that shop towels offer any environmental benefit when compared with disposable alternatives.
- Contrary to TRSA/UTSA claims, nonwovens and wipers/rags can be wrung out and reused several times. These products are not typically used once then thrown away.
- EPA-commissioned data indicates that 13 million pounds of hazardous contaminants are discharged to POTWs annually, and that 80% of these pollutants come from laundered shop towel waste water.
- Contaminants found in laundry waste water contain lead, toluene, xylene, zinc, and other heavy metals.
- Disposable wipers contribute an insignificant one-tenth of one percent of the nations land-filled waste each year.
UTSA/TRSA Claim: Laundered shop towels are not a solid waste since they are reused so it is appropriate to conditionally exempt shop towels from the RCRA definition of solid waste while exempting disposables from RCRA definition of hazardous waste.
INDA/SMART Response: EPA-commissioned data shows that rental shop towels actually contribute 30% more waste, per thousand towels, to landfills than nonwoven wipers and about the same amount as rags. This is due to the fact that sludge generated during the laundering process is disposed of in landfills and the shop towels themselves can typically be used only a few times before they must be disposed of due to the strenuous nature of industrial laundering.
UTSA/TRSA Claim: Implementing various elements of EPA's NPRM will result in economic hardship for industrial launderers and could result in the closure of small businesses throughout the country.
INDA/SMART Response: In the first place, laundering of industrial shop towels represents a small fraction of the total revenue derived by industrial launderers. Many industrial laundries do not even accept shop towels, or only do so to secure more lucrative business such as the laundering of coveralls, uniforms, and floor mats. In addition, there has been tremendous consolidation in the industrial laundering industry over the past ten years or so such that the primary players in this industry - including Cintas, Coyne, and other multi-million dollar operations - dominate rather than the small mom and pop businesses that used to.
INDA/SMART also note that laundering is a service and, as such, does not typically generate municipal revenues (other than income taxes paid by the generally lower-wage employees who work in laundry facilities). Wipers and rags, on the other hand, are products offered for sale. As such disposables generate municipal revenue in the form of sales tax each time they are purchased. Disposable wiping products are also typically manufactured in the United States whereas most laundered shop towels are imported from overseas.
UTSA/TRSA Claim: Industrial laundries have made great strides in reducing the amount of power and water used in their facilities, as well as the amount of pollution released in their wastewater through the voluntary industry program, LaundryESP.
INDA/SMART Response: LaundryESP was first announced in the 1990s when EPA's Office of Water was considering the implementation of national pretreatment standards for industrial laundries. An original goal of the program was nearly unanimous participation by industrial laundries. The LaundryESP program calls for systematic reductions in the use of power and water by industrial laundries (as compared to base line figures), but the program became less visible from 1999-2004. LaundryESP was resurrected shortly after EPA issued its proposed rule in industrial wipers, with industry participation of far less than the 90+% originally envisioned.
Reductions in the use of energy and water translate directly into cost savings for industrial laundries. It seems somewhat cynical to INDA/SMART, therefore, that a trade group would seek commendation for these efforts. Moreover, pollution reductions claimed in the relatively small amount of LaundryESP data that have been released to EPA relate to reductions in laundry chemicals and cleansing agents - not the RCRA-hazardous wastes that are the subject of EPA's rulemaking.