ECAR Fact Sheet for Colorado
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

In the State of Colorado, 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. 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 that are a hazardous waste.

For management and disposal/recycle of contaminated brake fluid, you must:

1. Have a sample of the used fluid 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 hauler. If it is hazardous, then special hazardous waste rules apply.
2. Assume that the fluid is hazardous and manage and dispose/recycle it as such. This approach avoids laboratory testing costs.

Links to the Regulations. Use the following links to view the regulations pertaining to hazardous waste determinations and management.

Colorado Used Oil Management Requirements

Federal EPA Used Oil Management Requirements

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. Is your brake fluid free from solvents, brake cleaners or carb cleaners? If the brake fluid has not been contaminated with such elements it can be recycled with your used oil.
2. Used brake fluid is potentially a hazardous waste. Verify that contaminated brake fluid was properly managed and disposed/recycled as hazardous waste or that a hazardous waste determination was made that indicates it is a non-hazardous waste. If not contaminated, brake fluids can be combined with your used oil.

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.

• Manage brake fluid in a manner similar to used oil.
• Collect uncontaminated brake fluid in your container labeled "Used Oil."
• Recycle uncontaminated brake fluid as used oil.
• Identify a 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 the Colorado Department of Health and Environment’s technical assistance line at 303-692-3320, or toll-free at 888-569-1831, if outside of the 303 area code.
2. To report a spill or leak, at minimum, call the Colorado 24-hour Emergency Spill/Release Reporting Line at 877-518-5608 and the Local Emergency Planning Committee at 303-273-1622, immediately or within 24-hours. Refer to the Spill Response Fact Sheet to determine your reporting requirements.
3. To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR Fact Sheets

1. Hazardous Waste
2. Used Oil
3. Spill Response Fact Sheet

Other Relevant Resources

1. Colorado Used Oil Generators Checklist
2. Colorado's Automotive Salvage Yard Waste Management Practices

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