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ECAR Fact Sheet for Kentucky
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.

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


Regulations

In the State of Kentucky, brake fluids are not considered used oil because it is not crude-based, and cannot be combined with your used oil. See ECAR Used Oil fact sheet.

For management and disposal/recycle of used brake fluid, you have two choices:

  1. Have a sample of the used brake 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 brake fluid is hazardous and manage and dispose/recycle it as such. This approach avoids laboratory testing costs.

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.

Kentucky Used Oil Regulations (Chapter 44)

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. Used brake fluid is potentially a hazardous waste. Verify that 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.
  2. Properly store and dispose of brake fluid. Collect brake fluid in a separate, marked, closed container and identify a waste hauler that will recycle it. If your brake fluid is determined to be nonhazardous, check whether the landfill will accept brake fluid absorbed with cat litter.

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.

  • Brake fluid is not crude oil-based, and therefore it should not be added to used oil.
  • Collect brake fluid in a dedicated DOT-approved, clearly and properly labeled drum specifically for brake fluids.
  • Identify a waste management company that will recycle it.
  • Don’t put brake fluid into your used oil container.
  • 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 Kentucky Department for Environmental Protection, Division of Waste Management, at 502-564-6716 or contact the nearest regional office.
  2. To report a spill or leak, call 1-800-928-2380 or 502-564-2380.
  3. To report an environmental incident or complaint, contact the nearest regional office

Related ECAR Fact Sheets

  1. Hazardous Waste
  2. Used Oil

Other Relevant Resources

  1. Kentucky Salvage Yard Guidance Document
  2. Kentucky Auto Repair Shop Guidance Document
  3. Kentucky Used Oil Spill Prevention Control & Countermeasures


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