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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:

  1. Having a sample of the used brake fluid analyzed by a laboratory to find out if it is hazardous.
  2. 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

  1. For more information, contact DEQ’s Environmental Assistance Center at 1-800-662-9278.
  2. For reporting spills/releases and pollution emergencies, contact: 1-800-292-4706.

Related ECAR Fact Sheets

  1. Used Oil

Other Relevant Resources

  1. MDEQ Consolidated Manifest Procedures
  2. Recycled Materials Market Directory Oils and Solvents Category for list of recyclers

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