Replacing a main drape, a set of legs and borders, or a worn traveler is a capital project most institutions plan carefully. Disposing of the goods coming down is usually an afterthought: someone drags them to the loading dock and they leave with the next trash pickup. That habit creates avoidable exposure. Retired stage drapery is a large, heavy waste stream. Cotton goods carry chemical flame retardant treatments. Some states restrict textile disposal outright. The removal work itself happens on the rigging system, where the most serious incidents in a theater happen. This article gives a documented procedure for taking retired curtains out of service, preparing them for disposal, and telling your waste hauler what they need to know.

How to Read This Article

Each control in this article is labeled by its authority. Requirement means a regulation or adopted code imposes the obligation. Recommended practice means conservative venue policy or professional practice that goes beyond what a code literally requires. Adopt recommended practices as written policy so they are applied consistently.

OSHA standards are cited throughout. Federal OSHA does not cover state and local government employees, which includes most public school staff. In states with an OSHA-approved State Plan, public employees are covered by that plan (Occupational Safety and Health Administration [OSHA], n.d.). Where your institution is not covered, treat the cited OSHA provisions as the recognized benchmark for safe practice.

Scope and Assumptions

This procedure covers stage drapery: main curtains, valances, legs, borders, travelers, blackouts, and similar soft goods. It assumes two fabric families:

• Treated cotton (velour, duvetyne, muslin, and similar), flame retarded with a Rosco Laboratories Roscoflamex product or a Turning Star Flamexx or Flame Guardian product.
• Inherently flame retardant (IFR) fabric, typically polyester, in which flame resistance is a property of the fiber rather than an applied chemical. See IFR Velour Stage Curtain Fabric for background.

The following are outside the scope of this procedure. Stop the process for any of them until it is resolved:

• Proscenium fire safety curtains. These are life safety systems governed by the building code and ANSI E1.22, Fire Safety Curtain Systems. Older fire safety curtains were commonly manufactured from asbestos cloth (Theatrecrafts, n.d.). Do not cut, fold, sample, or remove any component of a fire safety curtain system. Refer it to your facilities office for evaluation by an accredited asbestos inspector. See Fire Curtain Safety and Asbestos Awareness in Theater Buildings.
• Painted scenic drops. Paint, primers, and coatings introduce constituents the treatment SDS does not address.
• Drapery with no treatment record. If you cannot identify the product applied, you cannot rely on the information below. Your hauler or environmental consultant may require a waste profile before acceptance.

Know What You Are Disposing Of

Treated cotton and IFR fabric look alike on a pipe but behave differently as waste.

Characteristic	Treated Cotton	IFR Fabric
Source of flame resistance	Water-based chemical treatment deposited in the fiber	Built into the fiber; no treatment required (Turning Star, n.d.-a)
Disclosed treatment chemistry	Roscoflamex NF: urea and ammonium sulfamate, 1 to 5 percent each (Rosco Laboratories, 2022). Flamexx CLS-6: ammonium sulfate 5 to 7 percent, diammonium phosphate 1 to 2 percent, proprietary blend 3 to 5 percent (Turning Star, 2024)	None, unless records show a topical treatment after a failed flame test
OSHA hazard classification of treatment product	Not classified as hazardous under 29 CFR 1910.1200 (Rosco Laboratories, 2022; Turning Star, 2024)	Not applicable
Sensitivity to water	Treatment is water soluble; both SDSs identify the products as harmful to aquatic life and direct users to keep them out of drains and waterways	Not water sensitive
Combustion products	Ammonia (Rosco Laboratories, 2022); nitrogen, sulfur, and phosphorus oxides (Turning Star, 2024)	Varies by fiber; consult the fabric manufacturer

Two practical consequences follow:

1. Treated cotton must stay dry from the day it comes down until the hauler takes it. Rain, hosing, or laundering moves the treatment out of the fabric and toward drains.
2. Neither fabric should ever be burned on site.

For background on the toxicology of these products, see Fire Retardants in Theatre: Are They Toxic?

If IFR goods were topically treated during their service life, which some venues do after a failed field flame test, manage them as treated goods and record the product used. For flame testing background, see Understanding Fire Safety Standards for Stage Curtains.

Regulatory Framework

Hazardous Waste Determination

Requirement. Anyone who generates a solid waste must make an accurate determination of whether it is a hazardous waste (Hazardous Waste Determination and Recordkeeping, 2026). The determination proceeds in order:

1. Is the waste excluded under 40 CFR 261.4?
2. Does it meet a listing description?
3. Does it exhibit a hazardous characteristic?

Knowledge of the waste, including manufacturer SDS information, may be used to make the determination. Small and large quantity generators must keep records supporting the determination.

For an institution, the generator is the institution, not the individual teacher. Route the determination through your facilities, risk management, or environmental health and safety office. Do not make it informally at the stage door.

Read the RCRA language in Section 13 of the treatment SDS carefully. The Rosco statement addresses the product “as supplied,” meaning unused liquid, not fabric treated with it (Rosco Laboratories, 2022). The retired curtain is a different waste and needs its own determination. None of the ingredients disclosed on the cited SDSs is a toxicity characteristic constituent under 40 CFR 261.24 (Toxicity Characteristic, 2026). Flamexx CLS-6 includes an undisclosed proprietary blend, so request a written statement from Turning Star addressing that blend before you finalize the determination.

Hazard Communication

The OSHA Hazard Communication Standard exempts articles, meaning manufactured items that do not release more than very small quantities of a hazardous chemical under normal use (Hazard Communication, 2026). A curtain is an article, so the curtain itself has no SDS. Haulers frequently ask for one anyway. Provide the SDS for the treatment product along with your written determination.

State and Local Disposal Restrictions

Requirement where adopted. Some jurisdictions prohibit disposal of textiles regardless of condition. Since November 1, 2022, Massachusetts has banned textiles from disposal or transfer for disposal, and its guidance names curtains and fabric specifically (Massachusetts Department of Environmental Protection [MassDEP], n.d.-a, n.d.-b). Certain contaminated textiles are exempt (MassDEP, n.d.-b). Before calling your hauler, check your state environmental agency and municipal solid waste ordinances for textile restrictions.

Asbestos

Requirement. Removal of asbestos-containing material is governed by the EPA asbestos NESHAP (National Emission Standard for Asbestos, 2026) and OSHA’s construction asbestos standard (Asbestos, 2026). For K-12 schools, AHERA requires public school districts and nonprofit private schools to inspect for asbestos-containing building material and maintain management plans (U.S. Environmental Protection Agency [EPA], n.d.).

Recommended practice. Before any drapery work, ask your district’s AHERA designated person whether the stage contains identified or assumed asbestos-containing material. Treat any fire safety curtain component of unknown composition as suspect until an accredited inspector’s sample result says otherwise. This is most commonly found in old fire curtains. 

Leftover Treatment Product

Partially used containers of Roscoflamex or Flamexx are a separate waste stream from the curtains. Both SDSs direct users to keep the product out of sewers and waterways (Rosco Laboratories, 2022; Turning Star, 2024). Never pour leftover product down a sink or floor drain. Include it in your institution’s chemical waste program and make a separate determination.

Controlling Hazards During Removal

The most serious hazards in this project come from removing the goods, not from the fabric chemistry. Apply the hierarchy of controls in order.

• Elimination. Bring goods to the deck rather than working at height wherever the rigging allows. Do not disturb any suspect asbestos material at all.
• Substitution. Use HEPA vacuuming instead of shaking, beating, or blowing dust out of the fabric with compressed air. Each of those methods puts accumulated dust into the breathing zone.
• Engineering controls. Use the rope lock, the loading gallery, and the counterweight system’s designed loading procedure to keep every line set under control. Move bundles on carts or dollies rather than carrying them.
• Administrative controls. Write the procedure down. Put a rigging-qualified person in charge of all line set work. Establish an exclusion zone beneath the loading gallery and the arbor path during any weight handling. Limit bundle weights, as described in Step 17.
• Personal protective equipment. Wear work gloves for chain, grommets, and hardware, and safety glasses during vacuuming and stripping. Anyone working beneath loading gallery operations wears a hard hat. If staff choose to wear filtering facepiece respirators (N95) for nuisance dust, the employer must provide them with the information in Appendix D of 29 CFR 1910.134 (Respiratory Protection, 2026).

Step-by-Step Procedure

Phase 1: Assess and Document

1. Confirm the item is in scope. Verify that nothing slated for removal is part of a fire safety curtain system and that nothing is a painted drop. If either is uncertain, stop and refer to facilities.
2. Pull the records. Collect purchase records, fabric specifications, flame certificates, and treatment logs, including product name, application date, and applicator. Identify the fiber and the treatment product for every piece. If the treatment history is unknown, stop and consult facilities or EHS before proceeding.
3. Obtain the current SDS for each treatment product actually applied, directly from the manufacturer’s website.
4. Inventory each piece:
   • Type, fiber, and treatment product
   • Finished width, height, and fullness
   • Fabric weight, plus any lining
   • Hardware and hem weights
   • Estimated total weight

   Estimate weight as finished width × (1 + fullness) × height, converted to square yards, then multiplied by fabric weight in ounces per square yard and divided by 16. For example, a 40 ft × 20 ft main curtain at 50 percent fullness contains about 133 square yards of fabric. In 25 oz velour that is about 208 lb before lining, webbing, and hem chain. Confirm whether the fabric specification lists weight per square yard or per linear yard before calculating.

5. Inspect for contamination. Note paint, adhesive, mold, water damage, or animal droppings on any piece. Contaminated goods are reported to the hauler separately and may be handled differently under state disposal bans.
6. Make and record the waste determination through facilities or EHS, using the SDS, the manufacturer’s statement on any proprietary components, and the inspection results.

Phase 2: Plan and Notify

7. Route the project through your facilities or business office. Most institutions have an existing hauler contract, and the call should be made by, or with the authorization of, the account holder.
8. Check state and local textile restrictions. Identify any textile recovery or recycling outlets available in your area.
9. Call the hauler using the script below. Get the answers confirmed in writing.
10. Schedule the removal. Put a rigging-qualified person in charge of the work, and issue the written procedure to everyone involved.

Phase 3: Remove the Goods from the Rigging

11. Counterweight line sets: unload the arbor before unloading the batten. Removing drapery from a balanced batten makes the set arbor heavy. If the counterweight is not removed first, the batten can run out of control. Follow the manufacturer’s procedure for your system. A typical sequence (J.R. Clancy, n.d.):
    • Bring the batten to its loading position and set the rope lock.
    • Run the arbor to the loading gallery.
    • Unload the counterweight.
    • Unload the batten.

    Clear the area beneath the loading gallery and the arbor path before any weight is handled. Systems without a loading gallery require the manufacturer’s alternate procedure, which typically uses a capstan or temporary batten load.

12. Motorized line sets. Follow the manufacturer’s procedure for removing load. Removing heavy drapery may affect load-monitoring settings.
13. Dead-hung pipes. Work from a mobile elevating work platform operated by a trained operator, following the manufacturer’s manual. Never work from a ladder leaned against hanging goods or a pipe.
14. Support the fabric as ties are released. Assign a second person to carry the panel’s weight so that the last remaining ties are never loaded with the full panel.

Phase 4: Prepare for Disposal

15. HEPA vacuum on the deck. Never shake, beat, or blow out the fabric. Remember, old curtains collect a lot of dust and surface debris that will shake off the curtains when you take them down. We recommend wearing masks and PPE during this process.
16. Strip all metal:
    • Hem chain and weights, including lead drapery weights found in older goods (see The Use of Lead Tape to Weight Down Theatre Curtains)
    • Pipe from pipe pockets
    • Snaps, carriers, and S-hooks

    Send metal to a scrap metal recycler. Keep and label any lead weights separately.

17. Fold, roll, and bundle. Keep treated cotton dry, and never launder or rinse it. Pack goods in heavy-duty clear bags or tied bundles. Limit any single lift to 51 lb, the load constant of the NIOSH Revised Lifting Equation (Waters et al., 1994). The recommended limit is lower for lifts from the floor, lifts with twisting, and repetitive lifts. Use carts for anything heavier.
18. Label every bundle with fiber, treatment product, the statement “nonhazardous per generator determination dated ___,” and “metal removed.”

Phase 5: Stage Pending Pickup

19. Store bundles in a dry, secured indoor area. Keep them away from ignition sources, stage lighting, and the stage house. Never stage them in a corridor, exit, or exit access. Means of egress must be kept continuously free of obstructions (National Fire Protection Association [NFPA], 2024, §7.1.10.1). Minimize the time between removal and pickup.

Phase 6: Transfer and Close Out

20. Be present at pickup. Confirm the count and obtain a receipt identifying the receiving facility.
21. File the records (see below). Remove the retired pieces from the drapery inventory and from the flame certification file.

Where Treated Cotton and IFR Diverge

Treated cotton:

• Keep it dry at every step.
• Provide the treatment SDS and the manufacturer’s statement to the hauler.
• Ask any textile recycler specifically whether it accepts flame-retardant-treated fabric before you deliver.
• Never compost or mulch it.

IFR fabric:

• With no topical treatment on record, it is generally the simpler waste stream.
• It is still subject to the generator determination and to any state textile restrictions.
• Document the absence of topical treatment in the determination.

Both:

• Never reuse as performance drapery without a new flame test and certification.
• Release for non-performance reuse only with written disclosure that flame resistance is not warranted, and only with risk management approval.

Script: Calling Your Waste Hauler

We developed the following script, especially for Community Theaters, Educational Facility, and others to help ensure you have the correct information to provide. Use this as a guide rather r than a hard script and adjust as necessary for your situation. 

Have your inventory, determination, and SDS in front of you before you call. Record the representative’s name, the date and time, and every answer.

Introduction. Hello, my name is [Name], [Title] at [Institution], [Address]. Our account number is [Number]. I’m calling to arrange disposal of retired theatrical stage curtains, and I’d like to confirm how you want them handled before we schedule anything.

What we have. We have [number] pieces of stage drapery, approximately [total weight] pounds and [volume] cubic yards once bagged.

• [Weight] pounds are cotton fabric treated with a water-based flame retardant, [product name] made by [Rosco Laboratories / Turning Star].
• [Weight] pounds are inherently flame-retardant polyester with no added chemical treatment [or: treated with (product name)].
• The solution may contain substances like Bromine, Chlorine, and Phosphorous based solutions.

Our determination. Our [facilities / EHS office] has reviewed the safety data sheet for the treatment product and made a written determination that these curtains are nonhazardous solid waste. The curtains are manufactured articles, so they don’t have their own SDS. I can email you the treatment product’s SDS and our determination today.

Condition.

• All metal has been removed, including hem chain, weights, and hardware.
• The fabric has been vacuumed, is dry, and is packed in [clear bags / tied bundles] of no more than 51 pounds each, each one labeled with its contents.
• [There is no paint, mold, or animal contamination.] [or: (Number) pieces have (describe contamination), and they are bagged and labeled separately.]
• None of this material came from a fire safety curtain.

My questions:

1. Can you accept this in our regular service, or does it need a bulk pickup or a roll-off?
2. Does your landfill or waste-to-energy facility require a waste profile or other paperwork for chemically treated textiles?
3. Do you want the SDS and our determination in writing before pickup, and where should I send them?
4. [If your state restricts textile disposal:] Since our state restricts textile disposal, do you offer textile recovery, or can you refer us to a recycler that accepts flame-retardant-treated fabric?
5. Do you have any packaging, bag type, weight, or placement requirements?
6. What documentation will we receive confirming pickup and the receiving facility?
7. What is the cost, and what is the earliest pickup date?

Closing. Please email me a written confirmation of what you’ll accept, the pickup date, and any paperwork you need. My email is [email] and my phone is [phone]. Thank you.

Records to Retain

• The drapery inventory with estimated weights
• Treatment records and the SDS version used
• The manufacturer’s written statement on proprietary components
• The written waste determination
• The asbestos status confirmation from the AHERA designated person or facilities
• The hauler’s written acceptance and the pickup receipt
• Scrap metal recycling receipts

Small and large quantity generators must keep records supporting waste determinations (Hazardous Waste Determination and Recordkeeping, 2026). Retain this file as recommended practice regardless of generator status.

Never Do This

• Remove drapery from a counterweighted batten before unloading the arbor.
• Cut, fold, or sample any component of a fire safety curtain. Even during the decommissioning process.
• Shake, beat, or blow out dusty goods.
• Wash, hose, or store treated cotton outdoors.
• Pour leftover treatment product down a drain.
• Burn drapery on site.
• Stage bundles in an exit path.
• Give retired drapery to another venue as compliant stage goods.

References

Asbestos, 29 C.F.R. § 1926.1101 (2026). https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.1101

Hazard Communication, 29 C.F.R. § 1910.1200 (2026). https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200

Hazardous Waste Determination and Recordkeeping, 40 C.F.R. § 262.11 (2026). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-262/subpart-A/section-262.11

J.R. Clancy. (n.d.). Counterweight rigging systems: System manual (Publication No. 003-1035-02). Wenger Corporation. https://www.wengercorp.com/Lit/JR%20Clancy_Wenger/JR%20Clancy_Counterweight%20Rigging%20Systems_System%20Manual_003-1035-02.pdf

Massachusetts Department of Environmental Protection. (n.d.-a). MassDEP waste disposal bans. https://www.mass.gov/guides/massdep-waste-disposal-bans

Massachusetts Department of Environmental Protection. (n.d.-b). Clothing and textile recovery. https://www.mass.gov/guides/clothing-and-textile-recovery

National Emission Standard for Asbestos, 40 C.F.R. pt. 61, subpt. M (2026). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-61/subpart-M

National Fire Protection Association. (2024). NFPA 101: Life safety code. https://www.nfpa.org/codes-and-standards/nfpa-101-standard-development/101

Occupational Safety and Health Administration. (n.d.). State plans. https://www.osha.gov/stateplans

Respiratory Protection, 29 C.F.R. § 1910.134 (2026). https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134

Rosco Laboratories. (2022). Roscoflamex NF safety data sheet (Rev. 2). https://ca.rosco.com/sites/default/files/content/resource/2023-01/Roscoflamex-NF-SDS-27oct2022.pdf

Theatrecrafts. (n.d.). Asbestos in the theatre. https://theatrecrafts.com/pages/home/topics/safety/asbestos-in-the-theatre/

Toxicity Characteristic, 40 C.F.R. § 261.24 (2026). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-261/subpart-C/section-261.24

Turning Star. (n.d.-a). Treatment and testing FAQ. https://turningstar.com/faq

Turning Star. (n.d.-b). Product guide. https://turningstar.com/product-guide

Turning Star. (2024). Flamexx CLS-6 safety data sheet (Version 1.0). https://img1.wsimg.com/blobby/go/d7fb93a4-9b58-431b-a395-36d8e8f36172/downloads/4b3f51bb-0b85-4f28-a0c9-5cec745abd12/SDS%20CLS-6%202024.pdf

U.S. Environmental Protection Agency. (n.d.). Asbestos frequently asked questions. https://www.epa.gov/sites/default/files/documents/asbestosfaqs_0.pdf

Waters, T. R., Putz-Anderson, V., & Garg, A. (1994). Applications manual for the revised NIOSH lifting equation (DHHS [NIOSH] Publication No. 94-110). National Institute for Occupational Safety and Health. https://www.cdc.gov/niosh/docs/94-110/

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