ECAR
Fact Sheet for Michigan
Window-Washing
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
The
main thing to remember about window-washing fluid is not to mix
it with any other fluid that could turn it into a hazardous waste.
If you keep it uncontaminated, it does not have to be a waste
at all -- it can even be of value to you, since recovered window-washing
fluid can be resold or given to customers or employees.
But
even if you have kept it clean, do not pour it down the drain.
Regulations
Window-washing
fluid is mainly water with small amounts of alcohol and detergent
and possibly antifreeze. Unless window wiper fluid is mixed with
other fluids, it can be reused or recycled. Window-washing fluid
cannot be disposed of onto the ground, in septic tanks, in sewer
systems, or storm drains.
Manage
unwanted window washing fluid as liquid industrial waste if it is
not reused. Waste manifests would need to accompany wastes shipped
off-site by a permitted and registered transporter. Label containers
and keep them closed, and protected from weather, fire, physical
damage, and vandalism. Also keep outside of container clean.
If
window-washing fluid is combined with other fluids, the mixture
may be a hazardous waste and you should perform a hazardous waste
determination. See the ECAR Hazardous Waste fact sheet for more information.
Links
to the Regulations.
Use the following links to view the regulations pertaining to window
washing fluid.
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 Management and administrative rules
Federal EPA Standards Applicable
to Generators of Hazardous Waste
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 procedures for management and disposal
of window-washing fluid.
- Window-washing
fluid can be managed as a nonhazardous waste if it is not combined
with other fluids. Verify that window-washing fluid is accumulated
into separate storage containers and that no other types of fluids
are added to these containers.
- Make
sure containers are labeled and stored properly.
- Keep
copies of waste manifests for at least 3 years from shipment
- Window-washing
fluid cannot be disposed of onto the ground, in septic tanks,
in sewer systems, or storm drains. Verify that procedures
are in place to properly manage and dispose/recycle window-washing
fluid.
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 window-washing fluid:
- Drain
window-washing fluid during dismantling and before vehicle is
stored in the yard.
- Store
window-washing fluid on a concrete (impermeable) surface in covered
containers that are clearly marked (e.g., "Reclaimed Window-washing
Fluid."
- Reuse
reclaimed window-washing fluid in facility or employee vehicles.
- Sell
or give away reclaimed window-washing fluid to customers.
Contacts
- For
more information, contact MDEQ’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
None.
Other
Relevant Resources
None.
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