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ECAR Fact Sheet for Maryland
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 may have to be managed as hazardous
wastes.
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.
How
can you tell if the brake fluid in your yard is hazardous?
You can send a sample to a laboratory. That will cost you
a testing fee. But if it is non-hazardous and you can document
that fact, you can save the costs of managing it as a hazardous
waste. You can also avoid the lab fee and simply assume it
is hazardous.
This
fact sheet will tell you:
- how
to determine if a specific sample of brake fluid is hazardous
- what
you need to do to manage hazardous wastes in compliance with the
rules
Regulations
The
U.S. Department of Transportation issues specifications for the
three main kinds of brake fluid in use by the automotive and trucking
industry: DOT-3, DOT-4 and DOT-5. DOT-3 and DOT-4 are glycol-based
fluids and DOT-5 is silicon-based. Depending on the additives used,
brake fluid may or may not be hazardous. Even if brake fluid started
out as non-hazardous, it can become hazardous if it is contaminated
with brake cleaner or other solvents.
Brake
fluid is not crude oil-based and therefore it cannot be added to
and managed with used oil.
For
management and disposal/recycle of used brake fluid, you have two
choices:
- 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.
- Assume
that the brake 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.
Part
261 - Identification and Listing of Hazardous Waste
Part
262 - Standards Applicable to Generators of Hazardous Waste
Self-Audit
Checklist
When
an inspector comes to your facility, there are certain things they
check 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 oil storage areas and management
procedures.
- 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.
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
- For
compliance information, contact the Maryland Department of the
Environment at 410-537-3442.
- For
information on regulatory requirements associated with hazardous
waste, call the Hazardous Waste Program at (410) 537-3345.
Related
ECAR Fact Sheets
- Hazardous
Waste
Other
Relevant Resources
- MDE's Hazardous Waste Program Webpage
- Waste Diversion in Maryland
- Waste Permit Applications and Instructions
- MDE's Oil Control Program - Oil Pollution & Tank Management
- Maryland Recycling Market Directory
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