Best Management Practices for Hazardous Materials/Waste Handling
Best Management Practices (BMPs) should be thought of as "good housekeeping" practices. In the automotive, towing and auto body repair industry, you may have waste streams regulated as hazardous waste by federal and state laws. Listed below are typical waste streams and minimal practices to help you comply with these regulations. Staying in compliance to these regulations will help reduce costs and liabilities associated from being in non-compliance.
What to do at an Automobile Accident Site:
When you arrive at the accident site, the Fire and Police departments will most likely have the area secured, eliminating any immediate danger. Under federal law (40 CFR 261.3 (D)& 263.30), it is your responsibility to collect any hazardous and non-hazardous waste resulting from the collision. All employees involved in the cleanup of hazardous waste must be trained to meet the requirements of OSHA Hazardous Communications or Hazardous Waste Operations and Emergency Response (29 CFR 1910).
The guidelines below apply to storage and handling of hazardous waste both on the tow truck and at the storage facility.
Typical wastes found at an accident site
1. Engine Coolant: The most common hazardous waste you will find at a collision site is engine coolant (antifreeze). Often most of the coolant has leaked from the vehicle on to the road by the time you arrive. If coolant is still leaking from the vehicle you must stop the leak before transporting the vehicle off site and use absorbents to collect any coolant that has been discharged to the ground. Once the coolant is absorbed the absorbent must be placed in a DOT approved storage container (49 CFR 171) labeled "Absorbents Contaminated with Used Antifreeze" and transported to a storage or disposal facility.
2. Engine Oil: Commonly you will encounter oil at a collision site. If oil is still leaking from the vehicle you must stop the leak before transporting the vehicle off site and use absorbents to collect any oil that has discharged to the ground. Once the oil is absorbed the absorbent must be placed in a DOT approved storage container (49 CFR 171) labeled "Absorbents Contaminated with Used Oil" and transported to a storage or disposal facility. Used Oil may be mixed with fuel wastes or other oils (I.E.: hydraulic fluid, transmission fluid, gear oil, and motor oil) provided doing so does not change the hazardous characteristic of the waste.
3. Fuel: Fuel is among the most hazardous fluids you will encounter at a collision site. If fuel is still leaking from the vehicle you must collect it and stop the leak before transporting the vehicle off site and use absorbents to collect any fuel that has discharged to the ground. Once the fuel is absorbed the absorbents must be placed in a DOT approved storage container (49 CFR 171) labeled "Absorbents Contaminated with Waste Fuel" and transported to a storage or disposal facility. A small amount of fuel waste may be mixed with used oil waste provided doing so does not change the hazardous characteristic of the waste. If a large amount of fuel is collected from the site it is advised that this be stored separately from all other wastes during transport.
4. Lead Tire Weights: Lead tire weights may be found on site while cleaning up debris. These should be separated from the other debris and transported to a recycling facility.
5. Debris: Debris generated from the collision should be swept up and collected. Often this debris will be considered non-hazardous and can be disposed of into a normal trash receptacle. However if the debris contains chrome pieces it may be regulated and will have to be disposed of as hazardous waste.
Absorbents (such as kitty litter, floor dry, rags, and absorbent pads) used in cleaning spills listed above can be disposed as follows:
- Contract a hauler to take the waste from your storage facility.
Fill out an application with the County Waste to Energy Plant (WTE) and haul your own waste to the WTE plant.
If you are using rags as an absorbent you can contract with a uniform/rag service. Contracting with one of these companies may seem expensive, but it could save you money in disposal costs or fines for improper handling. These services are permitted by state and local agencies to recycle the rags. Used rags should be placed into a closed-lid container, which is properly labeled for the rag service, who will pick up and launder them.
Whichever disposal method you choose be sure to obtain receipts, which will serve as proof of proper disposal. Since disposal of the wastes listed above require a record, you cannot dispose of these wastes at auto salvage or scrap metal recycling facilities. Keep all receipts for a minimum of three years.
Note: If absorbents are mixed together they should labeled as "absorbents contaminated with…" followed by whatever they absorbed.
Fluids and other waste collected at the site:
All waste collected at the collision site must be labeled appropriately. Antifreeze fluid should be labeled "Used Antifreeze". Oil should be labeled "Used Oil" and Fuel should be labeled "Hazardous Waste Fuel". When the vehicle and its wastes arrive at the repair facility all wastes should be placed in their appropriate, properly labeled, collection containers. In the case of Used Oil it must be placed in a storage container that is either double walled or has secondary containment. These wastes must then be hauled off site by a registered waste hauler. A receipt for disposal must be obtained and kept for a minimum of three years.
NOTE: If you are not transporting the wastes back to your facility you will need to keep a log book of the wastes collected at the accident site. If possible it is recommended that you obtain a copy of the disposal receipt when that facility has the waste hauled away.
Regulated Waste Streams at the Auto Repair/Auto Body Facility:
Paint Thinners: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
This waste stream is regulated under Federal & State regulations. You must capture any thinner waste from cleaning spray guns and equipment, and place it into an approved container for disposal or recycling. If you choose to recycle this waste, it must be calculated into your waste stream totals before it is recycled. The benefits of recycling will save you money in purchasing new product, and the disposal of excess Hazardous Waste. The problem with recycling is the initial cost to buy the equipment, and the documentation showing the recycling process. The initial cost of the distillation unit can be recouped fairly rapidly depending on the amount of paint waste that is generated monthly. For Small Quantity Generators (<220lbs monthly) distillation units can reduce your generator status, and save you time and money in compliance costs. The "still bottoms" generated from the recycling process will need to have a waste determination performed on them before the disposal method can be determined. Avoid paints that have heavy metal flakes in them. Manufactures’ have made products utilizing metallic elements without regulated metals. Check MSDS’s for these heavy metals in order to avoid them (cadmium, lead, chromium). Here are several steps that can be followed that will save you money on new product and disposal costs. (1) Any thinner waste from gun or measuring stick cleaning should be put into a closed container and allowed to settle. (2) Once the sludge has settled, gently pour off the clear liquid in to another container. The clear product can be reused for gun cleaning. (3) Pour only sludge that cannot be reused into your distillation unit or drum. This practice is challenging to implement, but it can save you hundreds of dollars if you are successful.
2. Paint Waste: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
This type of waste stream can be reduced, by ordering the least amount of material needed to perform the job. When you have left over paint from this industry, it will probably be Hazardous Waste due to the reducers, thinners, hardeners, and heavy metals (metallic paint) contained in the material. Using the excess paint for primer on non-essential parts can reduce the amount of waste for disposal.
3. Paint Booth Filters: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
This is a tricky type of waste that may be regulated depending on the materials and the procedures utilized. Do not clean paint guns by filling with thinner and "blowing out" the waste from the gun cleaning process into the paint booth filters for absorption. If you utilize this process you are generating more hazardous waste than necessary. This will add to the cost of disposal and could place the facility into a higher classification of generator. You must determine if this waste is hazardous waste or not (Toxicity Characteristic Leaching Procedure test required). Material Safety Data Sheets on the materials that are used can help you to make a waste determination. The Pollution Prevention Program can also help you to make this determination. If it is not a hazardous waste you may dispose of this waste into your normal garbage for disposal at the Waste to Energy Facility. Document in writing from your garbage hauler, that they are hauling your waste to this facility.
4. Absorbent Material: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Absorbent materials are needed when spills occur. The types, and amounts of spilled material, will determine how you need to dispose of the absorbent material used. As a general rule: use absorbent materials for oil spills only or for emergency situations where nothing else is available. Heat-treated peat moss is the preferred absorbent if this material is going to the county incinerator WTE. Do not use absorbents for spills involving gasoline, diesel, antifreeze, battery acid etc. For small spills, drips and/or dribbles, use rags provided by your rag service. Absorbents will not change the fact that a spilled hazardous substance is a hazardous waste, and must be disposed of accordingly. Heat-treated peat moss and other absorbents should be used for large spills and/or emergency spills. The substance being absorbed will dictate disposal requirements. If you have further questions about this waste, please call to verify proper disposal.
5. Parts Cleaning Machines: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
These machines come in all types and sizes. There are many options in using the various types of parts washers on the market. The most regulated systems are those that utilize low flash point or chlorinated chemicals. Do not use these types of systems. There are less regulated systems available that will allow you to manage the system without relying on a company to haul the waste away monthly. This will reduce the amount of Hazardous Waste hauled off every month, which could drop you into a less regulated classification as a generator.
Batteries need to be stored on an impervious surface, in an area shielded from the weather. Best Management Practices dictate storage of batteries, indoors, on a wooden pallet over acid-resistant material. If any cores are missing caps or are cracked, place them in an acid-resistant plastic container, along with neutralizing material for leak absorption. Prevent acid from reaching soil and surface waters. This will reduce cost for contamination clean up and limit potential penalties. If you currently use your battery supplier to dispose of spent batteries, be sure that the supplier documents the number of cores removed on your receipt. If you are not using your battery supplier to recycle batteries, you may take your used cores to a scrap metal dealer. Again, secure a receipt noting the number of cores that were recycled. Keep receipts ON SITE for a minimum of three years. When your batteries are recycled, they are not counted towards your facility’s hazardous waste totals.
7. Used Oil: 40 CFR 279 | FAC 62-710 | F.S. 403.7545
To ease the burden of managing too many storage containers, used oil should be stored in one above ground storage tank (AST), if possible. If it is necessary for you to use 55-gallon drums as storage containers, they must be in good condition. 40 CFR 279.22(b) states: containers and aboveground storage tanks used to store used oil at generator facilities must be in good condition (no severe rusting, apparent structural defects or deterioration) and not leaking (no visible leaks). Drums must also be Department of Transportation (DOT) approved. Used oil containers that are not double walled must be placed within a secondary containment system. The secondary containment system must have the capacity to hold 110% of the volume of the largest container within the containment system. Your used oil containment area should have a sealed oil-resistant coating and be under cover. This will prevent rain from entering the storage area, mixing with oil and, subsequently, becoming contaminated. Make sure that all containers are capped when you are not transferring used oil from temporary containers. This provides additional assurance that water will not enter the container and contaminate the oil. The storage container and any fill pipes to the storage container must be labeled "Used Oil". The "Used Oil" signage must be visible from all approaches on the container (i.e. on each side). If you are using drums, each individual drum must be labeled. Receipts from the used oil hauler must be kept on site for a minimum of three years. When selecting a used oil hauler, be sure to check with the Florida Department of Environmental Protection about the company’s record of compliance.
8. Used Oil Filters: 40 CFR 279 | FAC 62-710 | F.S. 403.7545
There are limited options available for disposing of this type of waste. You can no longer dispose of used oil filters into the solid waste stream. All filters should be completely drained of any free flowing oil (crushed preferably) and placed into a marked container with a secure lid. You can dispose of these filters in two basic ways; (1) After containerizing the filters they can be hauled to the Waste to Energy facility or (2) You can contract with a hauler to have them haul the filters to the WTE. The recommended BMP for draining and crushing filters is to "hot drain" the filter for 24 hours. Hot draining filters will minimize the volume of used oil inside the filter, and crushing them will reduce the amount of space used in the container. This can save you quite a bit of money if you are having a private hauler take them. (Check with your filter hauler before crushing). Do not crush filters by driving a vehicle over them! Label all drums "Used Oil Filters" and keep all receipts from the hauler a minimum of three years to show proof of proper disposal. Store the drum with lid closed inside a containment area to eliminate contamination from rain.
9. Waste/Used Anti-Freeze: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Waste antifreeze must be stored in separate waste containers and properly labeled. These containers should be marked "used antifreeze" for recycled antifreeze or "waste antifreeze" for antifreeze that is hauled as hazardous waste. Before disposal as waste antifreeze, a waste determination must be performed. This will require testing utilizing TCLP for heavy metals. Depending on the test result, it may be hazardous waste and will require you to have the appropriate hauler remove this waste with proper documentation (manifesting). Keep the receipt showing proper disposal for a minimum of three years. Recycling anti-freeze on site is the preferred management practice. Recycling on site reduces your monthly hazardous waste totals and can minimize the regulations that you are required to comply with by reducing your generator status. Recycling on site is done three different ways depending on the quality of the antifreeze and the amount generated. (1) Antifreeze should be put back into the vehicle that it was taken out of whenever possible. (2) Recycling this waste on site with a machine owned by the facility is another option. If you own your own antifreeze-recycling machine you will have filters that will need to be changed occasionally. These filters build up heavy metals over time and should have a waste determination preformed on them before disposal, or simply be handled as a hazardous waste and manifested as such. A logbook should be kept with the amount of antifreeze recycled and the date, which should be kept for a minimum of three years. (3) There are several contractors that will come to your site to recycle your antifreeze. This service works well for all types of facilities, from Large Quantity Generators to Conditionally Exempt Small Quantity Generators. Even if you decide that you don’t want the recycled product you can have the recycling contractor haul it for cheaper than it would cost to have it hauled by a hazardous waste hauler. Make sure that anti-freeze is not stored in a container that cannot be completely emptied because any sludge will sink to the bottom of the container. Once in the container, the sludge may not be able to be removed if it is a large tank. A container with a wide opening is preferred (55gal. drum with an open top that clamps on and meets DOT standards).
Receipts from the recycler or the hazardous waste hauler should be kept for a three-year minimum. For facilities that recycle their own anti-freeze documentation needs to be kept in the form of a logbook with date, and amounts recycled.
10. Air Conditioning Repair: 40 CFR 82 | FAC 62-281 | F.S. 403.061
The procedure for this type of operation depends on the type of machine you have. A system that captures, recycles, and places the Freon back into the system being serviced is preferable to a system that merely catches Freon and places it into a container for shipment off site. A logbook should be kept on amounts of Freon reclaimed and used to charge machines. A total accounting of all Freon bought, charged into systems, and reclaimed should be a part of your everyday best management practices. Do not discharge Freon to the atmosphere. If your current system is being upgraded be sure to recycle any mercury thermostats that are replaced. Make sure your equipment is registered with the Florida Department of Environmental Protection (FDEP) and the employee has the proper training to perform the work (ASE Certified). All associated paperwork for this operation must be kept on site. Any records pertaining to reclamation and disposal need to be kept on site for a minimum of three years.
11. Shop Rags 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Do not use disposable shop rags in certain processes at your facility. If you do use disposable rags and they are contaminated, they must be hauled as hazardous waste. To avoid this problem contracting with a uniform service may be a better option for limiting your liability. Contracting with a company that will supply you with clean rags on a regular basis may be expensive, but it could save you money in fines for improper disposal of hazardous waste. These contractors are permitted by state and local agencies to wash the rags, which are considered recyclable items. Used rags should be placed into a closed-lid container, which is properly labeled for the rag service. They will then pick up and launder the rags. Make sure that you receive receipts, which will serve as your documentation. Keep all receipts for a minimum of three years. Use shop rags instead of absorbent for small drips and dribbles. Do not mix rags together with different waste into the same storage container, they may be reactive to one another and become a fire hazard.
12. Aerosol Cleaners: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
There are many different kinds of aerosol cleaners that promise that they are "environmentally friendly". Read the label and consult the Material Safety Data Sheet for the listing of active ingredients. If any of the ingredients contain the word "chlor", the aerosol contains chlorinated solvents. Chlorinated solvents are one of the main regulated ingredients in aerosol cleaners. Avoid using chlorinated cleaners. They can cross-contaminate other waste streams. There are other regulated ingredients in products, so read labels and MSDS carefully.
Once an aerosol can is "empty", by federal definition, it can be dispose of in your normal trash. The definition of "empty" is the point at which the atmospheric pressure inside the can is the same as the pressure outside the can, with all material dispersed. If the container cannot be emptied, it must be treated as hazardous waste if any regulated material remains inside. You may want to look at purchasing cleaners in bulk that use reusable containers. These reusable containers can be pressurized with your own air compressor. This will save cost in purchase of materials and reduce the number of disposed containers.
13. Discarded Gasoline & Diesel Fuel: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Fuels removed from vessels that cannot be used must be disposed of as hazardous waste. This includes both proper labeling and documentation of the management activities. Waste gasoline should be stored separately from other wastes. Please consult the hauler’s list provided to you for a list of companies that can legally haul this waste.
14. Fluorescent Bulbs: 40 CFR 273.13 | FAC 62-737 | F.S. 403.7186
Fluorescent bulbs/devices are considered hazardous waste because they contain the element Mercury. However, if you recycle your Fluorescent bulbs/devices, they do not qualify as hazardous. Please call the SQG program for a list of fluorescent bulb recyclers and handling instructions. Caution: if a supplier tells you that their bulbs are environmentally safe remember that they are trying to sell you a product, and that they may not be familiar with the State and Local regulations that pertain to the proper recycling or disposal of these mercury-containing bulbs. Lamps or devices with any mercury must be recycled.
*Material Safety Data Sheets are a good start to determine if your waste stream will be hazardous waste. They do have their limitations if they are too vague. They do not take into account what process or system the product may be used in, or what your management practices are for preventing cross contamination. MSDS’s are free for use and can be received from your supplier of the product. Before purchasing any product, request the MSDS to see what is in it to help avoid cost associated with the purchase/use of the product.
Do not use any chlorinated solvents.
Do not use one container as the "catch all" for all fluid draining procedures. This can cause cross contamination of waste.
Do not store any materials/waste near storm drains, ditches, creeks, rivers, canals or any bodies of water that would be contaminated if a spill occurs.
Do not throw away or send receipts to a bookkeeper that shows your disposal of waste materials. They are required to remain on site for a minimum of three years. This includes contracts with hazardous waste haulers.
Do not take the word of any sales person who will not supply MSDSs for the product he/she is selling. Some will say that the material is biodegradable or environmentally friendly, but the process that you use the material in may contaminate the product and cause it all to be regulated (i.e. equipment degreasing and rinsing).
Do not mix any waste with another waste. This will increase your cost for disposal. The most common mistake is to mix the wrong materials together into the used oil. Check with your used oil hauler for what is acceptable to mix together into the bulk used oil container. Get this in writing from your hauler!
Do not dispose of any material into your septic system, sanitary sewer, or storm sewer. If you want to do this you must have written permission from the Regulatory agency that permits that particular system. Septic System-Department of Health and Rehabilitative Services, Sanitary Sewers-whatever utility district you are in, Storm Sewer-Department of Environmental Protection.
Do not store hazardous waste out of containment areas. Make sure all containers are labeled properly (include dates where necessary).
Do not hesitate asking any questions when it comes to managing your hazardous waste stream. There are no dumb questions except for the ones you don’t ask.
If you have any questions, please call the Division of Natural Resources Management, Pollution Prevention (P2) Program at 239-533-8821. The P2 Program is here to serve your interest in the proper management of hazardous waste.
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