ECAR Fact Sheet for Michigan
Brake Fluid

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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The following fact sheet was prepared by the ECAR Center staff. Once prepared, each ECAR Center fact sheet undergoes a review process with the applicable state environmental agency(ies). You can check on the status of the review process here. Please read the disclaimer on the status page. While we have tried to present a summary of the essential information on this topic, you should be aware that other items, such as local regulations, may apply to you.

What You Need to Know

Brake fluids are not inherently hazardous, but if they contain certain additives, or if they have become contaminated with brake cleaner or other solvents, they can fall under the hazardous waste rules.

You can avoid the burden of treating brake fluid as a hazardous waste:

• If you do not contaminate it with other fluids, and
• If you handle and store it properly, and recycle it with your used oil.

This fact sheet will tell you what you need to do to avoid problems with fluids.

Regulations

Brake fluids are considered used oil and can be combined with your used oil as long as they don't contain any solvents, brake cleaners or carburetor cleaners and your recycler allows it. See ECAR Used Oil fact sheet. Remember, brake fluid contaminated with any of these materials could cause your used oil to become hazardous. If your operation still uses brake cleaners in aerosol cans, chances are they may contain chlorinated solvents which are a hazardous waste.

For management and disposal/recycle of contaminated brake fluid, you must determine if the fluids are hazardous waste by either:

1. Having a sample of the used brake fluid analyzed by a laboratory to find out if it is hazardous.
2. Use knowledge about the fluid. For example, assume that the brake fluid is hazardous if you use solvents that have cross contaminated the fluids. This approach avoids laboratory testing costs.

If it is hazardous, then the hazardous waste rules apply. See the ECAR Hazardous Waste Fact Sheet. If not, then manage as liquid industrial waste and have it shipped off-site for disposal by a permitted and registered liquid industrial waste hauler.

Links to the Regulations. Use the following links to view the regulations pertaining to used fluid management.

Michigan's Natural Resources and Environmental Protection (Act 451), Part 121 regarding Liquid Industrial Waste

Michigan's Natural Resources and Environmental Protection (Act 451), Part 111 regarding Hazardous Waste and administrative rules

Federal EPA Standards Applicable to Generators of Hazardous Waste

Federal EPA Standards for Used Oil

Self-Audit Checklist

When an inspector comes to your facility, there are certain things he or she checks to see if you are in compliance with environmental regulations. It makes good sense for you to perform a "self-audit" and catch and correct problems before they result in penalties. Also, there are some compliance incentives associated with self-audits (see Audit Policy Page). Use the following list to audit your used brake fluid management procedures.

1. Has the fluid been properly characterized as hazardous waste or liquid industrial waste? Is your brake fluid free from solvents, brake cleaners or carburetor cleaners? If the brake fluid has not been contaminated with such elements it can be recycled with your used oil if your recycler allows it to be mixed.
2. Has the fluid been shipped off-site as liquid industrial waste or hazardous waste? Do you have copies of waste manifests or shipment receipts if the transporter used a consolidated manifest? Keep records at leaste 3 years from date of shipment.

Best Management Practices (BMPs)

Most regulations tell you what you have to do to be in compliance, but they don't explain how to do it. That's where "best management practices" come into play. BMPs are proven methods that help you to get into compliance and stay there. The following BMPs are recommended for brake fluid storage areas and management procedures. See also the BMPs for Used Oil.

• Manage brake fluid in a manner similar to used oil.
• Check with your recycler before collect uncontaminated brake fluid in your container labeled "Used Oil" to make sure they allow mixing
• Recycle uncontaminated brake fluid.
• Identify a hazardous waste management company that will recycle contaminated brake fluid.
• Don't pour brake fluid down any drain or on the ground.
• Don't spray brake cleaner around brake fluid.

Contacts

1. For more information, contact DEQ's Environmental Assistance Center at 1-800-662-9278.
2. For reporting spills/releases and pollution emergencies, contact: 1-800-292-4706. 

Related ECAR Fact Sheet

1. Hazardous Waste
2. Used Oil

Other Relevant Resources

1. MDEQ Uniform Manifest Information
2. Recycled Materials Market Directory Oils and Solvents Category for list of recyclers

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