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ECAR Fact Sheet for Florida
Solvent Cleaning

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

Cleaning solvents are useful, but they can cause several different types of problems if they are not handled properly.  Some solvents can pose a fire or explosion hazard.  Some can cause immediate or long-term health effects if excessively high concentrations are inhaled or absorbed through the skin.  Some can contribute to air pollution.  And most solvents can cause environmental problems if not properly disposed of.

The disposal of many types of used solvents is covered under hazardous waste rules.  Your responsibilities under these rules may depend on how much solvent you use.  For many types of solvent cleaning operations above a certain minimum size, you may also need an air pollution control permit.  This fact sheet will help you determine what permits you will need and what practices you should follow in order to keep your solvent cleaning operations safe and in compliance with the rules.


Regulations

Various methods are used to clean oil and grease from auto parts before sale. This fact sheet covers the environmental issues associated with solvent cleaning methods such as parts washers containing Stoddard solution or mineral spirits. Aqueous cleaning (e.g., pressure washers, enclosed spray washers, steam cleaning) is covered under a separate fact sheet.

The regulations applicable to your solvent cleaning operations depend mainly on the type of solvent(s) used. Some solvents are more heavily regulated than other solvents due to their potential to cause greater environmental damage and/or due to employee health impacts. In general, solvents can be placed into three categories:

  • Solvents that contain chlorine (referred to as halogenated solvents) are the most heavily regulated. Examples of halogenated solvents include trichlorethlyene (TCE), methylene chloride, and perchlorethylene (PCE or PERC). To determine the type of solvent you are using, refer to the MSDS provided with each chemical by the vendor. Any product you use that contains compounds with "..chloro..." in its list of ingredients is a chlorinated compound. Chlorinated organic solvents may be included in such products as carburetor cleaners, engine degreasers, and brake cleaners.
  • Non-halogenated solvents that have a "flash point" of less than 140oF (e.g., mineral spirits).
  • Non-halogenated solvents that have a "flash point" of 140oF or higher (e.g., light aliphatic naphthas or hydrotreated light petroleum distillates).

Note: Petroleum-based solvents are classified according to their flash point. The term "flash point" refers to the temperature at which a material could ignite if exposed to a spark. Materials with a low flash point (100-140oF) will ignite more easily than materials with a higher flash point (140-200oF.) The hazardous waste rules also use the 140oF cutoff point. Spent solvents with a flash point less than 140oF are a hazardous waste.

Spent halogenated and low flash point solvents are automatically hazardous wastes because they are toxic and/or ignitable. Non-halogenated solvents with a flash point of 140oF or higher are notnecessarily hazardous. However, users of these solvents must be cautious. Most of these solvents have a flash point just above 140oF. If the solvent becomes contaminated during use with a low flash point liquid, then the mixture may be hazardous. Also, metals such as lead may accumulate in the solvent during use causing the solvent to be a hazardous waste when it is removed from service. For non-halogenated, high flash point solvents, you can either assume they are hazardous or conduct a hazardous waste determination to find out their regulatory status. Hazardous wastes must be handled, stored and disposed of according to specific rules. For more information, see the Auto Recycling Plain Language Guide to Solid/Hazardous Waste Management.

Certain solvent cleaning operations are regulated under federal air pollution regulations referred to as National Emission Standards for Hazardous Air Pollutants (NESHAP) for Halogenated Solvent Cleaning. These rules have also been adopted by the state of Florida. The regulated processes are those that use methylene chloride, perchloroethylene, trichoroethylene, methyl chloroform, carbon tetrachloride, or chloroform in a concentration of greater than 5% with one of the following cleaning methods:

  • Immersion batch cold-solvent cleaning equipment with a capacity exceeding two gallons.
  • Remote-reservoir batch cold-solvent cleaning equipment of any volume.
  • Batch vapor cleaning equipment of any volume.
  • In-line (continuous) cold or vapor cleaning equipment of any volume.

The rules only apply to solvent cleaning operations above a minimum size, (e.g., open-top vapor degreasers with an open area of 10.8 square feet or more). However, local rules may vary and you should check with DEP concerning your operations. To comply with the NESHAP you may need to obtain a permit and install equipment that prevents evaporative losses of solvent and/or follow certain work practices. For more information see DEP's web page for halogenated solvent degreasers and the NESHAP regulation identified below.

Waste Management and Disposal/Recovery Options. Parts washer solvents are considered wastes when they are removed from the washer unit, or if they remain in an idle parts washer over 90 days after the unit ceases operation. Unless testing proves otherwise, spent solvents should be managed as a hazardous waste. The waste solvents must be stored in containers that are in good condition and made of materials or lined with materials that are compatible with the stored wastes. The container must always be closed during storage, except when it is necessary to add or remove wastes. It also cannot be opened, handled, or stored in a manner that may cause it to rupture or leak. Containers holding hazardous waste must be clearly marked with the words "hazardous waste" and the date on which accumulation of the waste began.

A generator may accumulate as much as 55 gallons of hazardous waste in containers at or near the point of generation where wastes initially accumulate as long as the conditions in the above paragraph are followed, with the exception of the accumulation date. This is known as satellite accumulation. The date must be marked on the container once the 55-gallon limit is reached and the waste must be moved to the container storage area or off-site within three days.

A company registered with the DEP must transport hazardous waste, including waste solvent, sent off-site. The transporter must have a hazardous waste ID number issued by EPA or DEP. The wastes must be sent to a facility that is authorized to accept spent solvent. This may include a treatment, storage, or disposal facility, a recycler, or a boiler or industrial furnace.

Links to the Regulations. Use the following links to view the regulations pertaining to solvents.

Florida Hazardous Waste Regulations

Federal Hazardous Waste regulations Part 261 - Identification and Listing of Hazardous Waste

Federal Hazardous Waste regulations Part 262 - Standards Applicable to Generators of Hazardous Waste

Florida Solvent Metal Cleaning Air Rules (62-296.511).


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 solvent cleaning operations.

  1. Determine the regulatory status of your spent solvent. Determine if your spent solvent is a hazardous waste. This can be accomplished by referring to the MSDS for the solvent or by testing. If it is hazardous, verify that the hazardous waste rules for storage and disposal/recovery are followed. You may also have reporting and recordkeeping requirements, depending on your regulatory status (determine your regulatory status).
  2. Determine if your solvent cleaning operations require an air permit. Certain minimum sized halogenated solvent cleaning processes require air permits.

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 solvent cleaning.

  • Reduce the quantity of solvent used by implementing a two-stage cleaning system. The first stage should clean the dirtiest parts. The second stage uses cleaner solvent for final cleaning and rinsing. When the cleaning solution in the second stage is no longer effective, it can then be used to replace the solvent in the first stage. Fresh solvent is then used to replace the second stage.
  • Parts washers should have a recirculating feature with built-in filtration to continuously remove dirt and contaminants. This will extend the life of the solvent.
  • Drip racks or trays can help increase drainage from parts to minimize solvent loss.
  • When not in use, lids on parts washers should be kept closed to reduce evaporative solvent loss.
  • Do not combine spent solvent with used oil. If any hazardous substance (e.g. solvent cleaner, brake cleaner) is suspected of contaminating a load of used oil, the transporter may refuse to pick it up, leaving the you to deal with managing the contaminated used oil as hazardous waste.
  • Contract with a solvent management company to supply and recycle solvent.

Contacts

  1. Air Resource Management District Offices
  2. Small Business Assistance Program (SBAP)
  3. DEP Hazardous Waste Compliance Assistance Program: 800-741-4337.

Related ECAR Fact Sheets

  1. Hazardous Waste

Other Relevant Resources

  1. DEP's web page for halogenated solvent degreasers.

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