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ECAR Fact
Sheet for Massachusetts
Transmission Fluid, Power Steering Fluid and Gear Oil
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, transmission fluid is regulated as a hazardous waste if it is destined for disposal. You can avoid the burden
of treating transmission 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.
Transmission
fluid is difficult to remove and spills are a very common occurrence.
Up to eight quarts of fluid can be drained from a car’s transmission.
Extra care must be taken to properly drain transmissions so that
spills do not occur.
This fact sheet will tell you what
you need to do to avoid problems with fluids.
Regulations
Unlike most states, the State of
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 is designated as a listed hazardous waste and is regulated as a hazardous
waste if it is destined for disposal.
Gear
oil, power steering fluid and transmission fluid are not regulated
as a hazardous waste if they are recycled. These crude-based petroleum
products can be managed like or with your used oil ONLY IF they
have not been mixed with or contaminated by hazardous wastes
such as solvents, brake cleaner or carburetor cleaner. Do not dispose
of crude-based petroleum products in a storm drain, septic tank,
dry well, sewer system or dumpster. Refer to the Used Oil Fact Sheet.
If
the fluids have been contaminated by other solvents, you must follow
the hazardous waste requirements for storage and disposal. See the
ECAR Hazardous Waste Fact Sheet.
For
management and disposal/recycle of contaminated fluids, 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.
Transmission
filters should be handled like used oil filters. This means that
transmission filters are exempt from the state hazardous waste requirements
if they are they are managed by following these steps:
- Remove the
filter from the engine while warm and immediately drain free-flowing
oil.
- Put
the drained oil in your waste oil drum or tank.
- Puncture
the filter dome. Place the filter on a rack to drain into a waste
oil drum or tank for 12 hours. OR…After 12 hours of draining,
crush the filter.
- Store
the used filter in a separate, closed metal container that is
labeled “Waste Oil Filters.”
- Ship
the used filters to a recycler or discard them in a dumpster after
12 hours of draining. Drained filters are not classified as a
hazardous waste.
*Oil
collected from draining must be managed with your waste oil as a
hazardous waste.
Spill
Control. If an oil spill occurs as a result
of draining or handling waste oil filters, you must perform the
following cleanup steps:
- Stop the release;
- Contain the released waste oil;
- Clean up and properly manage the released waste oil
and other materials; and
- If necessary, repair or replace any leaking waste oil
storage containers or tanks prior to returning them to service.
- Notify DEP at 617-338-2255
or 800-462-0444.
Links
to the Regulations.
Use the following links to view the regulations pertaining to waste
oil filter 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).
For
a self-audit checklist for these fluids, follow the steps on the
ECAR Used Oil Fact Sheet.
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 management and recycle of used
transmission fluid/gear oil:
- 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
- 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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