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ECAR Fact Sheet for Michigan
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, and recycle it with your used
oil.
This fact sheet will tell you what you need to do to avoid
problems with fluids.
Regulations
Brake fluids are considered used oil and can be combined
with your used oil as long as they don’t contain any solvents, brake
cleaners or carburetor cleaners and your recycler allows it. See
ECAR Used Oil fact sheet. Remember, brake fluid contaminated with any
of these materials could cause your used oil to become hazardous.
If your operation still uses brake cleaners in aerosol cans, chances
are they may contain chlorinated solvents which are a hazardous waste.
For management and disposal/recycle of contaminated brake
fluid, you must determine if the fluids are hazardous waste by either:
- Having
a sample of the used brake fluid analyzed by a laboratory to find
out if it is hazardous.
- Use
knowledge about the fluid. For example, assume that the brake
fluid is hazardous if you use solvents that have cross contaminated
the fluids. This approach avoids laboratory testing costs.
If
it is hazardous, then the hazardous waste rules apply. See the ECAR
Hazardous Waste Fact Sheet.
If not, then manage as liquid industrial waste and have it shipped
off-site for disposal by a permitted and registered liquid industrial
waste hauler.
Links to the Regulations. Use the following links to view the
regulations pertaining to used fluid management.
Michigan’s Natural Resources and
Environmental Protection (Act 451), Part 121 regarding Liquid Industrial
Waste
Michigan’s Natural Resources and
Environmental Protection (Act 451), Part 111 regarding Hazardous
Waste and
administrative rules
Federal EPA Standards Applicable
to Generators of Hazardous Waste
Federal
EPA Standards for Used Oil
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.
- Has
the fluid been properly characterized as hazardous waste or liquid
industrial waste? Is your brake fluid
free from solvents, brake cleaners or carburetor cleaners?
If the brake fluid has not been contaminated with such elements
it can be recycled with your used oil if your recycler allows
it to be mixed.
- Has
the fluid been shipped off-site as liquid industrial waste or
hazardous waste? Do you have copies of waste manifests or
shipment receipts if the transporter used a consolidated manifest?
Keep records at leaste 3 years from date of shipment.
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. See also the BMPs for Used Oil.
- Manage
brake fluid in a manner similar to used oil.
- Check
with your recycler before collect uncontaminated brake fluid in
your container labeled "Used Oil" to make sure they
allow mixing
- Recycle
uncontaminated brake fluid.
- Identify
a hazardous waste management company that will recycle contaminated
brake fluid.
- Don’t
pour brake fluid down any drain or on the ground.
- Don’t
spray brake cleaner around brake fluid.
Contacts
- For
more information, contact DEQ’s Environmental Assistance Center
at 1-800-662-9278.
- For
reporting spills/releases and pollution emergencies, contact:
1-800-292-4706.
Related
ECAR Fact Sheet
- Hazardous
Waste
- Used
Oil
Other
Relevant Resources
- MDEQ Consolidated
Manifest Procedures
- Recycled Materials Market Directory
Oils and Solvents Category for list of recyclers
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