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ECAR Fact Sheet for Massachusetts
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
In
Massachusetts, brake fluid is regulated as a
hazardous waste if it is destined for disposal. You can avoid the burden
of treating brake fluid as a hazardous waste if it is recycled,
but you must have a permit from the Massachusetts Department of
Environmental Protection (DEP) to do so.
This
fact sheet will tell you what you need to do to avoid problems with
brake fluid.
Regulations
Even
though the State of Massachusetts does allow brake fluid to be combined
with used oil, unlike most states, Massachusetts has not adopted
the federal regulations that apply to used oil management. Massachusetts’
requirements for “waste oil” are stricter than the federal rules
and more complicated. Under state law, waste oil (brake fluid) is
designated as a listed hazardous waste and
is regulated as a hazardous waste if it is destined for disposal. See the ECAR Used Oil fact sheet.
For
management and disposal/recycle of contaminated brake fluid,
you must:
- Contract with a licensed transporter to pick up your
waste oil for recycling or disposal.
- Save your shipping records for at least three years.
Links
to the Regulations. Use
the following links to view the regulations pertaining to hazardous
waste determinations and management.
Massachusetts Waste Oil 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.
- 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.
- Used brake fluid is potentially a hazardous waste.
Verify
that contaminated brake fluid was properly managed and disposed/recycled
as hazardous waste. If not contaminated, brake fluids can be combined
with your used oil,
but it still may need to be handled as hazardous waste.
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.
Taking
the precautions listed below will help you avoid waste oil accidents,
limit your legal liability, and protect both your workers and the
environment.
- Store waste oil in sturdy, leakproof metal containers
or in a tank approved by your local fire department.
- Label the container or tank and the storage
area in large letters: “Waste Oil,” Toxic,” and “Hazardous Waste.”
- If you generate more than 27.5 gallons of waste
oil per month: Add the date to the label to show when you started
filling the storage drum.
- Keep containers closed unless you are adding
or removing used oil.
- Place containers on a surface made from any
material (such as concrete) that waste oil cannot pass through.
The surface should have no cracks or gaps. If outdoors, put a
curb around the area to contain a leak or spill equal to 110%
of the volume of the tank.
- Store waste oil away from drains or ignition
sources.
- Check containers and storage areas each week
for spills or leaks from lids, seals, and seams.
- Keep cleanup and containment materials ready
for immediate use.
- Write an emergency response plan, post the instructions
in an easily visible spot in the shop, and train employees in
the procedures.
Contacts
- For more information, contact
the Massachusetts Department of Environmental Protection at 617-338-2255 or 800-462-0444, or contact
the DEP Regional Service Center
near you.
- To report a spill or leak, call
the 24-Hour DEP Emergency Response hotline at 617-556-1133 or
888-304-1133.
- To report an environmental incident
or complaint, contact the Environmental
Strike Force at 617-556-1000 or 888-VIOLATE (1-888-846-5283).
Related
ECAR Fact Sheets
- Hazardous Waste
- Used Oil
Other
Relevant Resources
- Massachusetts
– Waste Oil Regulations for Auto Repair Shops
- Massachusetts Fact Sheet
- A Summary of Requirements for Small Quantity Generators of Hazardous
Waste
- Massachusetts Fact Sheet – The Very Small Quantity
Generator of Hazardous Waste
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