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:

1. Contract with a licensed transporter to pick up your waste oil for recycling or disposal.
2. 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:

1. Remove the filter from the engine while warm and immediately drain free-flowing oil.
2. Put the drained oil in your waste oil drum or tank.
3. 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.
4. Store the used filter in a separate, closed metal container that is labeled "Waste Oil Filters."
5. 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:

1. Stop the release;
2. Contain the released waste oil;
3. Clean up and properly manage the released waste oil and other materials; and
4. If necessary, repair or replace any leaking waste oil storage containers or tanks prior to returning them to service.
5. 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

1. 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.
2. To report a spill or leak, call the 24-Hour DEP Emergency Response hotline at 617-556-1133 or 888-304-1133.
3. 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

1. Used Oil

Other Relevant Resources

1. Massachusetts - Waste Oil Regulations for Auto Repair Shops
2. Massachusetts Fact Sheet - A Summary of Requirements for Small Quantity Generators of Hazardous Waste
3. Massachusetts Fact Sheet - The Very Small Quantity Generator of Hazardous Waste

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