ECAR Fact Sheet for California
Antifreeze

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

Because of its composition, antifreeze may be classified as a hazardous waste if it is not recycled.  In order to encourage recycling, the state of California will give you a break and exempt you from the burden of handling it according to the usual hazardous waste rules if you manage it properly. This fact sheet will tell you:

• How to handle antifreeze to qualify for the exemption
• What you need to do if you do not qualify in order to manage antifreeze in compliance with hazardous waste rules

Regulations

Waste Classification. Antifreeze is made up using some regulated chemicals including ethylene glycol and propylene glycol. During use antifreeze can become contaminated with traces of fuel or metal particles. Due to its composition, used antifreeze can be considered a hazardous waste. However, in the state of California, used antifreeze is exempt from hazardous waste regulations if it is properly managed and:

• It is used in your facility vehicles;
• Given away for reuse (be sure to document who you give the antifreeze to and how much); or
• Processed for recycling either on-site, by a mobile service, or by an off-site recycler. If you use an off-site recycler, you must ensure that the antifreeze is being recycled.

If you chose not to recycle used antifreeze, you have two choices:

1. Have a sample of the used antifreeze analyzed by a laboratory to find out if it is hazardous. If it is non-hazardous, it can be shipped off-site for disposal by a licensed industrial wastewater transporter. If it is hazardous then it must be managed, transported, and manifested as a hazardous waste.
2. Assume that the antifreeze is hazardous and manage it as such. This approach avoids laboratory testing costs.

See the ECAR Hazardous Waste fact sheet for details about storing, handling, and shipping of hazardous wastes.

Storage of Used Antifreeze. Used antifreeze must be stored in containers meeting DOT specifications/UN performance criteria and must be in good condition. This means:

• No severe rusting;
• No bulging or major dents; and
• No visible leaks.

Do not accumulate used antifreeze for longer than 180 days.

Labeling. Use the following labeling for antifreeze that will be recycled or reused. For hazardous wastes, see the ECAR Hazardous Waste fact sheet for labeling instructions.

• Label used antifreeze collection equipment and containers with the words "Used Antifreeze."
• Label reconditioned or recycled antifreeze containers with the words "Reconditioned or Recycled Antifreeze."
• Mark used antifreeze containers with the starting date of accumulation.

If used antifreeze at your facility is a hazardous waste, see the ECAR Hazardous Waste fact sheet for additional storage requirements.

Spill Control. If a spill occurs, you must perform the following cleanup steps:

1. Stop the release;
2. Contain the released antifreeze;
3. Clean up and properly manage the released antifreeze and other materials; and
4. If necessary, repair or replace any leaking antifreeze storage containers or tanks prior to returning them to service.

See Best Management Practices for additional instruction on antifreeze cleanup.

If you store used antifreeze outdoors, the storage area must be addressed in your Spill Prevention and Countermeasures (SPCC) Plan (see ECAR Fact Sheet Spill Prevention and Countermeasures (SPCC) Plan).

If used antifreeze at your facility is a hazardous waste, see the ECAR Hazardous Waste fact sheet for additional requirements.

Filter Management. You must either manage used antifreeze filters as hazardous waste or prove that they are non-hazardous through laboratory analysis. See the ECAR Hazardous Waste fact sheet for additional information.

Record Keeping. Keep all receipts of used antifreeze shipments and filter management. The written receipts or records must include:

• Name and address of the generator and the recycling facility for off-site shipments.
• The amount of used antifreeze shipped or recycled on-site.
• The amount of used antifreeze filters shipped off-site.
• Date of shipment or recycling.

Links to the Regulations. Use the following links to view the regulations pertaining to used antifreeze storage and management.

California’s Hazardous Waste Management Requirements

Federal EPA Standards Applicable to Generators of Hazardous Waste

Self-Audit Checklist

When an inspector comes to your facility, there are certain things they check 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 antifreeze storage areas and management procedures.

1. Is used antifreeze stored in drums, tanks or other containers that are in good condition? Open containers, and rusting or leaking containers cannot be used for antifreeze storage.
2. Are antifreeze storage containers and tanks properly labeled? All used antifreeze storage containers must be labeled "Used Antifreeze." All recycled or reconditioned antifreeze storage containers must be labeled "Recycled or Reconditioned Antifreeze."
3. Is the area around the used antifreeze storage containers free of releases? Releases must be stopped and the released material cleaned up and managed properly.
4. Are outdoor used antifreeze storage areas addressed in your Spill Prevention and Countermeasures (SPCC) Plan? Your SPCC must identify potential sources of stormwater pollution and specify appropriate measures to reduce the discharge of pollutants.
5. Is used antifreeze transported to a recovery facility by a certified transporter? Check your records and verify that all shipments of used antifreeze were removed from your property by a state certified transporter. The California Department of Toxic Substances Control maintains a Registered Hazardous Waste Transporter Database.
6. Is oil, solvent or other materials mixed with used antifreeze? Verify that there are separate, clearly labeled containers for each type of material, and that used antifreeze is not mixed with used oil, solvents and other materials.

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 used antifreeze storage areas and management procedures.

• Use separate equipment for the collection of used antifreeze (funnels, pads, storage containers).
• Label used antifreeze collection equipment and containers "Used Antifreeze."
• Drain antifreeze from radiators and heater cores as soon as possible.
• Keep used antifreeze free from cross-contamination with other wastes, including used oil, fuels, degreasers or radiator flush chemicals.
• Determine if the antifreeze is waste fluid or reusable and can be recycled.
• Consider keeping antifreeze in two separate, closed containers: one for antifreeze that cannot be reused marked "Used Antifreeze," and one marked "Usable Antifreeze."
• Label reconditioned or recycled antifreeze containers "Reconditioned or Recycled Antifreeze."
• Label antifreeze containers with the starting date of accumulation.
• Install an antifreeze recycling system. [Used antifreeze recycling methods involve two steps: (1) removing contaminants either by filtration, distillation, reverse osmosis, or ion exchange and (2) restoring critical antifreeze properties with additives. Additives typically contain chemicals that raise and stabilize pH, inhibit rust and corrosion, reduce water scaling and slow the breakdown of ethylene glycol.]
• Keep any records relating to used antifreeze for at least three years. This includes receipts for used antifreeze shipments and any laboratory results.
• Employ the following procedure for antifreeze spills on floors:
• Mop up the antifreeze immediately using a dedicated cloth mop. Transfer collected antifreeze to the properly labeled antifreeze waste container for recycling.
• Use rags to dry the floor. Place used rags in properly labeled waste containers and send rags to an industrial laundry. Do not saturate the rags; otherwise you will have drips on the floor as you transfer them to the waste containers.
• Use a wet mop only if necessary for final cleaning. Use mild, non-caustic detergent.

1. Contact the DTSC Public and Business Liaisons at 800-728-6942, or go to http://www.dtsc.ca.gov. Follow the “Toxic Questions?” and “Contact a Live Person!” links to the page listing each of the Duty Officers’ email addresses.
2. To report large spills and releases to the environment, contact your local emergency response offices (usually 911) as well as the Office of Emergency Services Warning Center: 800-852-7550.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Related Resources

1. Managing Hazardous Waste Main Web Page (CA DTSC)
2. Partners in the Solution Guidance Manual (State of CA Auto Dismantlers Assn.)

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