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Navigating Local/State Chemical Requirements (Part 1)

Role of wastewater; handling/usage information

CHICAGO — Chemicals are necessary when it comes to the laundry process, and with the potential for personal and environmental harm, numerous regulations have to be followed regarding usage, storage and safety.

Federal requirements are often top-of-mind with chemicals, so operators might overlook local and state regulations.

There can be wide variations in chemical storage and use regulations, but most general requirements are based on national or international building and fire codes, says Eli Cryderman, director-technical services for laundry chemical provider Gurtler Industries Inc.

These regulations will specify the amounts of hazardous chemicals that can be stored on-site; the type of building, containment and fire protection required; and any other storage and use considerations. 

“Every state is different and it would require that an operator research what standards their local state agencies follow and who those state agencies are,” says Vaughn Minissian, director of operations for chemical solutions and water technologies company Norchem Corp.

“Local/state/federal requirements are varied, and operators should always employ a bottom-up strategy, focusing on local requirements first,” adds Ryan Cotroneo, chief technology officer for chemical manufacturer UNX Industries Inc.

“These requirements will likely involve the most audits (wastewater) and are specific to the community and the infrastructure (human/mechanical) they have in place.”

WASTEWATER

Local/state environmental regulations that govern a chemical laundry application have to do with wastewater discharge, say Kasey Wahl, director of sales and marketing, and John Koduru, director of safety, regulatory and quality, for Washing Systems, a provider of products and services to the commercial laundry processing industry.

Cryderman says, “These restrictions are typically driven by the site’s local geography, the municipality’s wastewater processing capabilities and degree of environmental awareness. The authority most often cited is the Federal Clean Water Act and the National Pollutant Discharge Elimination System (NPDES) to restrict or eliminate certain chemicals in waste streams. 

“A laundry situated on a large watershed, governed by a small municipality whose main source of income is derived from tourism and outdoor activities will likely face more restrictive storage, use and wastewater discharge limits than a laundry located in a large city, with a well-developed water treatment system and many large and varied industrial operators.” 

When building or moving into a new facility, attention needs to be given to the chemistry being employed in the wash process and its effect on plant water discharge, shares Peter Berrio, director of business development for Pariser Industries, a manufacturer of specialty cleaning chemicals, and heavier soil plants will necessarily have more effluent, chemical and soil by-products to contend with.

“States and municipalities have various and specific approaches to supervision of wastewater along with allowable limits of potential contaminants in the waste stream,” he says.

Berrio adds that chemical suppliers are typically conversant with local rules and should be relied upon to review their safety data and formularies with the operators to anticipate future regulatory involvement as it relates to the following:

  • Phosphate limits statewide.
  • Local POTW (publicly or privately owned treatment works) pH and BOD (biological oxygen demand) limits.
  • The potential need for composite sampling and/or routine effluent analysis reporting requirements.
  • Product flammability vs. existing lease verbiage and building insurance provisions.

HANDLING/USAGE

“Most regulatory requirements for handling and use in the laundry industry are based on OSHA guidelines for the handling of corrosive or toxic chemicals,” shares Steven Tinker, senior vice president of research & development, marketing, for Gurtler Industries Inc.

“Accordingly, local and state regulatory agencies defer to the federal standards. The critical information on chemical handling requirements is included on the Safety Data Sheet (SDS).”

The storage of chemicals onsite comes with the responsibility to complying with the local, state and federal emergency response regulations, shares Wahl and Koduru. These require the business owners to prepare an annual inventory of all chemicals, which meet the threshold planning quantity (TPQ) set forth by the regulators.

At the federal level, the TPQ is 10,000 pounds per year of hazardous material or 500 pounds of an extremely hazardous material.

“However, in certain states such as California, the CUPA (Certified Unified Program Agencies) program’s TPQ is 500 pounds per year of any hazardous material and 500 pounds per year of extremely hazardous material,” they share.

When it comes to processing textiles in a laundry, chemical use is not generally regulated, Tinker points out.

Nick Wagner, principal technical account specialist at Ecolab’s Research, Development and Engineering Center, says that there have been recent industry discussions about how to determine if a product can kill and/or be effective against SARS-CoV-2, the virus that causes COVID-19, in the laundry process.

According to the EPA, “Cleaning products that claim to kill and/or be effective against viruses are pesticides and must be accepted and registered with the U.S. Environmental Protection Agency (EPA or the agency) prior to distribution or sale. These products may not be sold or distributed unless they have been properly tested and are registered by the EPA.”

“To verify the products used in your wash process that claim to be effective against viruses like SARS-CoV-2, the virus that causes COVID-19, it is critical that you ask your chemical vendor to provide you with the EPA registration number and EPA approved documentation stating that the product is effective against the virus,” Wagner says.

“If they cannot provide EPA documentation, it is likely that those claims have not been reviewed or accepted by EPA and, therefore, may present a risk to consumers, and healthcare providers in particular.” 

Furthermore, he points out that even if a product is registered through the EPA, the product must specifically have a registered claim, or emerging viral pathogen claim, for the target organism—in this case, the SARS-CoV-2 virus. Wagner suggests referring to the EPA’s list N for products that are known to, and have been approved by, the EPA to be effective against SARS-CoV-2, the virus that causes COVID-19.

“After all, it’s all about brand protection, providing the right product with the right registration and kill claims, so that you have peace of mind that the product you are using kills COVID-19,” he says.

“Most states have some regulations on the processing of healthcare-related textiles,” Tinker says. “These regulations can vary from state to state. Some states defer to  Centers for Medicare & Medicaid Service (CMS) and/or CDC (Centers for Disease Control and Prevention) recommendations.

“Some of the regulations on healthcare textile processing require a minimum processing temperature and time. Some require the use of chlorine bleach for sanitation. But with the increased use of lower temperature laundering and alternatives to chlorine bleach, many of these regulations are being reformed.”

Check back next Tuesday for Part 2 on safety data sheets.