June 1, 2005

EPA needs more equitable solutions

Laundered shop rags have enjoyed a large market share due to inequitable regulation for disposal set by the EPA.
Encouraged by the phenomenal success of disposable nonwoven wipes, manufacturers are now turning their attention to industrial markets.

High-end segments with critical manufacturing environments, including aerospace, electronics, pharmaceutical, printing and automobile finishing are boosting demand for cleanroom, surface preparation and other specialty industrial wipes.

The result is a situation where manufacturers are vying for share in a market traditionally dominated by reusable, laundered shop towels.

Currently, some estimates show laundered shop towels hold nearly 90% of the industrial wipers segment, but nonwoven wiper manufacturers are projecting gains in the 6% range during the next several years.

This currently lopsided market is partly a result of environmental measures intended to regulate the disposal of industrial wipers and the solvents that are applied to them.

Laundered shop rags have enjoyed relative immunity from these regulations due to a misconception that laundering for re-use makes them more environmentally friendly than their disposable counterparts.

A classification difference between laundered and disposable wipes has exempted laundered rags from the definition of hazardous waste, and the nonwovens industry is bearing the brunt of this misclassification. The classification of nonwovens wipers as hazardous waste and the costs and efforts involved in safe disposal of these products give them an unfair disadvantage against laundered towels.

The U.S. Environmental Protection Agency, Washington D.C., has jurisdiction over waste disposal in the U.S., and the Federal law governing the storage, handling and disposal of hazardous waste is known as RCRA, the Resource Conservation Recovery Act. For the past 18 years, the nonwovens industry, spearheaded by INDA, the Association of the Nonwovens Fabric Industry, has pressed EPA to classify all industrial wipers by the solvents applied to them, not by the substrates themselves. These efforts have yielded minimal results until recently, when EPA proposed a modification to its hazardous waste management regulations under RCRA for certain solvent-contaminated materials including laundered shop towels and disposable wipes.

The proposal
On November 23, EPA sought to clarify Federal standards regarding the handling, transportation and disposal of wiping products that are treated with industrial solvents.

For the first time, regulations would include laundered shop towels into the RCRA program. Since Congress passed RCRA in the 1970s, the EPA has exempted laundered shop towels from RCRA waste disposal standards as long as the state governments regulated the laundering of shop towels.

Shop towels have historically fallen under jurisdiction of EPA’s Office of Water Management because their solvents are removed in the laundering process and returned to public water supplies for processing. This exempts them from the definition of solid waste and by extension hazardous waste. Unlike laundered wipes, since day one, disposable wipes have been regulated under the Office of Solid Waste and could earn the hazardous waste definition if certain criteria are met.

While EPA feels this proposal would resolve long-standing issues associated with the management of industrial wipers, representatives of the nonwovens industry believe otherwise and recommend that more be done to protect the environment and level the playing field for wipes—a product some studies show to be superior.

“There is definite growth in the industrial wipes market, with projections in the 4-6% range annually through 2008,” said Paul Farren, vice president, and general manager nonwovens, Georgia-Pacific, who predicted that such an action could propel industrial wipe growth to nearly 10%. “There have been problems in the manufacturing segment due to the EPA regulations. Although no overnight changes are expected, if the rules are modified, any change would present an enormous opportunity.”

The Conditions
Generally speaking, laundered shop towels remain exempted from solid waste classification, and thus may never be classified hazardous waste. Generators must store and transport them in covered containers after use, and ensure they are not dripping with solvents, a condition that would allow launderers to refuse a shipment. Once a laundry accepts the shipment, the generator’s responsibility is finished.

Disposable wipes, if certain conditions are met, can be exempt from the definition of hazardous waste but have always been classified as solid waste.

They too must be stored after use by the generator in a covered container but, when transported to a disposal facility, the container must clearly identify the cargo as contaminated with solvents. If disposal is to occur at a municipal solid waste incinerator, the non-laundered wipers must contain no free liquids. Disposal at a municipal solid waste landfill requires the rags be dry and contain no more than five grams of solvents. Therefore, removing solvents is yet another responsibility placed on the generator.

Additionally, EPA has published a list of solvents, such as acetone, that under no conditions can be placed in a landfill.

The nonwovens camp finds the EPA’s inequitable disposal requirements between the wipes and towels questionable, since contaminants possessing the hazardous characteristics of ignitability, corrosivity, reactivity or toxicity must be disposed of according to guidelines set under RCRA, regardless of the wipe style.

“The industrial laundry rhetoric is that laundered shop towels are environmentally friendlier than non-laundered wipes, which simply isn’t supported by the facts,” said Robert Peterson, business manager, new business development, for DuPont Nonwovens, Wilmington, DE.

“The soil on the laundered wipes ends up in the landfills, via launderers sludge. If it isn’t captured in sludge it can be released into public rivers and streams. So really it’s a charade.”

Although the primary EPA goal is to establish a Federal framework for the handling and disposal of industrial wipers and the solvents applied to them, the conditions, as written, can be viewed as both advantageous and par for the course for laundered shop towels. A fringe benefit for the laundered towels, regardless of the proposed rule change, is end users with an eye on the bottom line will be reluctant to pay extra disposal fees for wipers deemed hazardous.

Hidden Costs for Laundered Shop Towels
Truth in economics
Exempt from the costs associated with hazardous waste, one would believe laundered shop rags are the most economic choice for their needs.

In reality, however, hidden fees charged by launderers can add up. Laundries assume the user will lose or damage up to 10% of the towels, and automatically tack on fees to cover costs associated with this estimate.

Waste and management costs passed on to the user are generally an additional 15%. Many launderers will charge users for an inventory level, not actual usage and factor cost by weight.

INDA concerns
In terms of inequities, INDA’s concerns lie in the fact that identical solvents require labeling for transport to landfills and incinerators but not for release into public drinking water sources. Eyebrows are raised because non-laundered products destined for landfills, must be dry; yet laundered towels containing the same solvents need only meet non-dripping standards. “RCRA is not about the towels; it’s about the waste they contain,” warned Ralph Solarski, of Kimberly-Clark, who serves as president of INDA’s Focused Interest Committee for Wipers. INDA believes all wiping products should be exempt, under certain conditions, from the designation of hazardous waste, but conditions regulating disposal should be equitable for both types of wiping products and related to the solvents they contain.

Peter Mayberry, INDA director of governmental affairs, Washington, D.C., said that INDA agrees with a standard of no dripping. To remove the maximum solvent, INDA feels generators should hand wring the wipes before placing them in disposal receptacles. “Hand wringing should be required because it would…facilitate recycling of used solvents and ensure minimum negative impact on human health and the environment,” added Mr. Mayberry.

Rental shop towels can come back unclean or otherwise impaired, causing concealed dangers.

Nonwovens Wipers Advantages
Despite regulations hampering a nonwovens’ bid for a greater market share, industry leaders cite education as an invaluable tool in expanding that segment.

Several reports laud productivity advantages of task-engineered wipers over laundered shop towels. Advances in fibers, production and dispensing technique make task customization simple. The right wiper can be used for the right job, ensuring consistency in performance.

Nonwovens wipers also benefit workplace safety with a consistently clean environment that is free from contamination, while rental shop towels can return from the laundry unclean or impaired, causing concealed dangers. These include metal shavings from lathing operations that can injure faces and hands and residual oils and chemicals to cause skin rashes. Furthermore old, worn, less-absorbent rental shop towels may allow chemicals to come into contact with hands.

A recent study conducted by environmental consulting firm Gradient Corporation, Cambridge, MA, evaluates potential exposure to metals in laundered shop towels. Samples of towels, which had been used and then laundered, were collected from 23 locations in 14 states. They were then submitted to an independent lab, which analyzed them for 27 metals, as well as for oil and grease.

All of the laundered shop towels contained oil and grease, and many contained elevated levels of metals, such as lead. The study concluded that metals on these towels can get onto hands and then inadvertently get into the mouth and be swallowed. Based on using 2.5 towels per day, the study also showed that the amount of lead that someone might accidentally ingest from the laundered shop towels was essentially equivalent to California Environmental Protection Agency’s (CalEPA) Maximum Allowable Daily Level (MADL) for reproductive toxicity. More frequent daily use of the laundered towels was shown to have more dire results, including higher exposure to antimony and cadmium.

DuPont has enjoyed success in the industrial market with its Sontara EC engineered-cloth wipers. They are more versatile than cloth rags, stronger and more durable than paper and less expensive in use than both.
Nonwovens producers blame too many years of inequitable EPA regulations on the industry’s lag in developing newer, better wiping technologies for industrial applications. Those already in the market develop their product’s quality and delivery rather than invest in new technology.

G-P’s Mr. Farren said his company is further developing its airlace technology blending the benefits of airlaid pulp with spunlace technology to penetrate industrial markets. Airlace possesses the strength required for use in industrial fabrics, and G-P continues to experiment with various fibers to improve its balance of strength and price.

“The technology for applications in the industrial market is there, but a lot depends, of course, on the EPA regulations,” said Mr. Farren.

While DuPont has achieved significant success with its Sontara Industrial Wipers, the first nonwoven sterile wiping product to be designed specifically for use in the pharmaceutical, medical device and biotech industries, the company’s Mr. Peterson agreed that EPA regulations are hurting the segment.

Some wipes producers, such as Chicopee, a subsidiary of PGI Nonwovens, design their products for specific industrial applications and the proposed regulations should have relatively little impact.

With nonwoven material, industrial wipes producers can guarantee customers wiper size and quality control.
Elizabeth Offringen, Business Unit Manager, Industrial Wipes, PGI Nonwovens, said the company sees moderate growth in the market, particularly in applications requiring low linting and minimal particulate release performance. PGI, she said, is continuously being awarded new patents that combine hydroentangling and spunmelt technology for use in future applications.

In the European market, particularly Eastern Europe, Radoslaw Muziol, vice president, Novita SA, Poland, said the demand for industrial nonwovens wipes has not yet reached its potential. Citing education and time, Mr. Muziol believes that as more Eastern European countries join the European Union, the standard of hygiene will rise.

Larger companies that don’t rely specifically on the industrial wiper segment may weather the wipes issue, and focus on more lucrative markets until the climate is right for further research and development.

Smaller operations with stakes in the industrial market must keep a close eye on the issue while staving off lean times as U.S. industries continue to move jobs overseas.

In 1996, Jeffrey Slosman started his industrial wipers manufacturing company, National Wiper Alliance, Asheville, NC, and chose nonwovens materials for production because they allow him to guarantee his customers exact wiper size and quality control.

Mr. Slosman said he enjoyed early success from a robust customer base, but unfortunately, as the U.S. industrial market shrinks, so too, does the pool of nonwovens customers.

Asked what the future may hold for National Wiper Alliance, Mr. Slosman is cautiously optimistic. The rule proposal, he said, is only the beginning in an uphill battle for survival.

“Five years from now we will still be competing to secure the same market share, but a lot will depend on how any proposed regulation is interpreted by the EPA. No matter what’s written, most importantly is how it’s enforced.”

The Future
Based on public feedback about the proposed rule change, the EPA has three avenues to choose:

Approval, as published in November; make changes based on public input or simply decide not to issue a final ruling on this matter.

Regardless of the decision, every day hazardous materials are dumped into the environment through loopholes in the rules that govern them, and INDA will be on the front lines as long as it takes.

“We are encouraging EPA to address this issue and to go final with a rule that accomplishes increasing solvent recovery/recycling, protecting human health and the environment and providing clear, simple guidance to the hundreds of thousands of businesses that will be impacted,” said K-C’s Mr. Solarski.

The right thing to do is for EPA to take action and eliminate the confusion and complexity that has existed for years.”

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