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Generator Compliance Checklist

SB419 provides the following benefits to generators using reusable textile absorbents that follow the minimal provisions of the law:

  1. Reusable textile absorbents are exempt from hazardous waste generator fees connected with the waste absorbent materials.
  2. Reusable textile absorbents are exempt from hazardous waste manifesting and other hazardous waste transportation requirements.
  3. Reusable textile absorbents are exempt from requirements to use certified hazardous waste haulers.
  4. Reusable textile absorbents are exempt from requirements to use permitted hazardous waste TSD facilities.

To take advantage of these benefits, you need to follow the requirements in this checklist.

 
✔️ Generator Requirements – SB419 Reusable Soiled Textile Materials
The absorbent must be a reusable soiled textile material. A reusable soiled textile material means textile items, including, but not limited to, shop towels, uniforms, gloves, and linens and towels which may become soiled with hazardous waste during commercial or industrial use, and are made reusable by laundering or comparable methods of cleaning.
The materials or the management of the materials must not otherwise be regulated by the Environmental Protection Agency pursuant to the federal act. Health & Safety Code 25144.6 (b)(1)
The materials must not be used to clean up or control a spill or release that is required to be reported to any state or federal agency. Health & Safety Code 25144.6 (b)(2)
No hazardous waste can be added after the materials’ original use. Health & Safety Code 25144.6 (b)(3)
No free liquids as defined by Section 66260.10 of Title 22 of the California Code of Regulation (i.e. free liquids readily separate from solid portion of waste), can be released during transportation or storage of the materials. Health & Safety Code 25144.6 (b)(4)
The facility laundering or cleaning the materials must maintain records of the date, type, and quantities by piecework or weight of the materials collected and laundered. Health & Safety Code 25144.6 (b)(5)

Cleaning Facility Compliance Checklist

A facility laundering or using comparable methods of cleaning reusable soiled textile materials is not required to obtain a hazardous waste facilities permit or other grant of authorization if SB419 requirements are met. For your convenience, the requirements and the status of M. L. Winters compliance with these requirements are itemized below.

Cleaning Facility Requirements – SB419 Reusable Soiled Textile Materials

✔️ REQUIREMENTS M. L. WINTERS COMPLIANCE
✔️ The facility laundering or cleaning the materials must maintain records of the date, type, and quantities by piecework or weight of the materials collected and laundered. Health & Safety Code 25144.6 (b)(5) M. L. Winters keeps detailed records of incoming materials to be cleaned. We individually weigh each customer’s order. We can also weigh the order after cleaning to give you the weight of liquids removed from the absorbents.
✔️ The facility laundering or cleaning the materials must prepare a contingency plan which specifies procedures for handling both onsite and offsite emergencies involving the materials, and employees are trained in its execution. Health & Safety Code 25144.6 (b)(6) M. L. Winters has an emergency plan that covers the handling of materials and all employees are trained as part of new employee and annual training. A copy of the contingency plan is available upon request.
✔️ Management procedures must be in place to ensure that the reusable soiled textile materials are managed in accordance with all the requirements specified. Health & Safety Code 25144.6 (c)(1) Management procedures at M. L. Winters, such as developing this checklist and information package, ensure that the materials are managed in accordance with all requirements set forth.
✔️ The waste wash water conveyances and containers must be constructed of materials to ensure that they are impervious under the conditions of use, and be visually inspected at least twice a year to ensure that waste wash water is not leaking to the underlying soil. Health & Safety Code 25144.6 (c)(2) M. L. Winters uses a Stoddard solvent dry cleaning process. All solvent tanks and piping are above ground and properly constructed and contained. All items are periodically inspected to verify integrity.
✔️ The sludge collected from the washing process is to be managed in accordance with this chapter. Health & Safety Code 25144.6 (c)(3) M. L. Winters recycles the solvent on-site in a distillation system. Sludge from the distillation unit is properly managed as hazardous waste in accordance with State and Federal regulations.
✔️ The facility must have a training program in place that ensures that the facility personnel are able to safely and properly handle and clean the reusable soiled textile materials and to respond effectively to emergencies by familiarizing them with emergency procedures. Health & Safety Code 25144.6 (c)(4) M. L. Winters has a comprehensive training program for its employees that includes, but is not limited to, proper handling of materials and emergency response actions. The training is conducted in accordance with the company Injury and Illness Prevention Program in compliance with California OSHA regulations.
✔️ The waste being treated must be generated onsite. Health & Safety Code 25201.5 (d)(1) All solvents used in the dry cleaning process are recycled back into the system. Waste sludge from the solvent recycling distillation process is generated on-site and is managed as hazardous waste.
✔️ The treatment should not require a hazardous waste facilities permit pursuant to the federal act. Health & Safety Code 25201.5 (d)(2) M. L. Winters does not need a hazardous waste facilities permit for the cleaning of the reusable textile absorbents or the on-site recycling of dry cleaning solvent.
✔️ The facility must prepare and maintain written operation instructions and a record of the dates, amounts, and types of waste treated. Health & Safety Code 25201.5 (d)(3) M. L. Winters keeps detailed records of the cleaned materials, as well as operation instructions for the dry cleaning equipment and processes.
✔️ The facility must prepare and maintain a written inspection schedule and log of inspections conducted. Health & Safety Code 25201.5 (d)(4) M. L. Winters has a comprehensive inspection log that follows a set inspection schedule for all equipment related to the dry cleaning process.
✔️ Written records and logs must be maintained for a period of three years. Health & Safety Code 25201.5 (d)(5) All logs and inspection records are kept on file for a minimum period of three years as required by regulations.
✔️ The facility must maintain adequate records to demonstrate that it is in compliance with all applicable pretreatment standards and with all applicable industrial waste discharge requirements issued by the agency operating the publicly owned treatment works into which the wastes are discharged. Health & Safety Code 25201.5 (d)(6) The dry cleaning process does not discharge waste water to the publicly owned treatment works. The facility does have a permit from the Los Angeles County Sanitation District for industrial water discharges from wet laundry processes.