ECAR Fact Sheet for Hawaii
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

Used antifreeze, through contact with a car's cooling system, may contain traces of lead and benzene, making it a possible hazardous waste. If not properly managed and stored, these pollutants can seep into soil and groundwater harming people and the environment.

But in order to encourage recycling, the State of Hawaii 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 benzene and lead. Used antifreeze should never be disposed of down storm drains or surface waters. It is illegal and dangerous to discharge antifreeze to septic tanks, dry wells or to the outdoors.

Due to its composition, used antifreeze can be considered a hazardous waste. However, if used antifreeze is recycled, it doesn't need to be treated as hazardous waste. Recycling can be done on-site or off-site by an antifreeze recycling service. Contact the Hawaii Department of Health (DOH) at 808-586-4226 for more information.

If you recycle on-site, filters and sludges produced from recycling may be hazardous. Therefore, you will need to determine if these wastes are hazardous.

Used antifreeze that is not recycled and therefore, disposed of, must be handled in one of two ways:

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 hauler or discharged to a municipal wastewater treatment system. You must check with your local water treatment authorities and a permit may be required). If it is hazardous, then special hazardous waste rules apply.
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 and Labeling. Store antifreeze in closed containers on an impermeable concrete surface with spill controls. Consider keeping antifreeze in two separate, closed containers: one for antifreeze that cannot be reused marked "Waste Antifreeze Only," and one marked "Usable Antifreeze Only."

Spills. Clean up all spills right away. Keep spill control equipment in a central location, accessible to all employees. To report a spills, contact the Hawaii Department of Health Office of Hazard Evaluation and Emergency Response 24-hour hotline at 808-247-2191, or 808-586-4249 during regular office hours.

Filter Management. Waste antifreeze filters and particulate generated from recycling antifreeze also must be managed as hazardous waste or proven 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 waste 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 management.

Hawaii's Hazardous Waste Management Requirements (unofficial online version)

Federal EPA Standards Applicable to Generators of Hazardous Waste

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 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 waste antifreeze should be labeled "Waste Antifreeze Only," and antifreeze that can be recycled or reused, should be marked "Usable Antifreeze Only."
3. Is the area around the used antifreeze storage containers free of releases? Releases must be stopped; the released material cleaned up and managed properly and reported to DOH.
4. 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.
5. 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).
• Drain antifreeze from radiators and heater cores as soon as possible.
• Keep waste 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.
• Recycle by reuse, distillation, filtration or ion exchange. Recycling can be done on-site or off-site by an antifreeze recycling service.
• Consider keeping antifreeze in two separate, closed containers: one for antifreeze that cannot be reused marked "Waste Antifreeze," and one marked "Usable Antifreeze."
• Do not dispose of antifreeze down storm drains, in septic tanks, dry wells or on bare ground.
• Keep any records relating to used antifreeze for at least 3 years. This includes receipts for used antifreeze shipments and any laboratory results.

Contacts

1. For more information, contact the Hawaii Department of Health (DOH), Solid and Hazardous Waste Branch, Hazardous Waste Section at (808) 586-4226.
2. To report a spill or leak, or to report an environmental incident or complaint, call the Hawaii Department of Health Office of Hazard Evaluation and Emergency Response 24-hour hotline at 808-247-2191, or 808-586-4249 during regular office hours.

Related ECAR Fact Sheets

1. Hazardous Wastes

Other Related Resources

1. Directory of Environmental Businesses in Hawaii, 2000
2. Hawaii Recycling Industry Guide

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