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ECAR Fact
Sheet for Michigan
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
Fluids,
like gear oil, power steering fluid and transmission fluid, are
not inherently hazardous, but if they contain certain additives,
or if they have become contaminated with other solvents, they can
fall under the hazardous waste rules.
You
can avoid the burden of treating fluids as a hazardous waste:
- If
you do not contaminate them with other fluids, and
- If
you handle and store them properly, and recycle them with your
used oil.
This fact sheet will tell you what you need to do to avoid
problems with fluids.
Regulations
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 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.
- Using
knowledge about the fluid. For example, assume the brake fluid
is hazardous if you use solvents that have cross contaminated
the fluids and manage and dispose/recycle it as such. 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).
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:
- Manage
transmission fluids like you manage used oil.
- Do
not dispose of transmission fluid in a storm drain, septic tank,
dry well, sewer system or dumpster.
- Remove
fluid from transmission filters by draining for 24 hours.
- Keep
drained filters in a container marked "Used Transmission
Filters."
- Do
not put undrained filters in the dumpster.
- Talk
to your used oil recycler about mixing transmission fluids with
other used oil before adding it.
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 Sheets
- 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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