ECAR Fact Sheet for Missouri
Used Antifreeze

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

Antifreeze is usually made of ethylene glycol, corrosion inhibitors and foam controllers. Ethylene glycol is toxic if ingested. It is particularly dangerous because animals and children are attracted to its sweet flavor. If they drink the ethylene glycol it may cause coma or death. Some antifreeze is made of propylene glycol. This material is less hazardous to humans and animals than ethylene glycol.

The used antifreeze from a vehicle can hold contaminants that it has picked up from the vehicle engine. For example, used antifreeze may contain lead because the antifreeze has dissolved some of the lead solder in the radiator.

The Missouri Department of Natural Resources has prepared a guidance document to help auto recyclers manage used antifreeze. Much of that information is included in the fact sheet below. You can access the link to the Department's Vehicle Salvage Compliance Guide under Other Relevant Resources.

Regulations

Waste Classification. Waste antifreeze is not a listed hazardous waste under the federal hazardous waste regulations. However, it may be a hazardous waste depending on the contaminants it has picked up. The test used to find out if used antifreeze is a hazardous waste is called the Toxicity Characteristic Leaching Procedure (TCLP).

Recent studies have shown that antifreeze from cars and trucks manufactured after 1995 is not hazardous waste. This is primarily because less lead is used in radiator construction. Used antifreeze is more likely to be hazardous if it was used in heavy equipment such as bulldozers and buses.

This means that antifreeze from late-model cars and trucks that has not been mixed with other antifreeze or with other hazardous wastes does not need to be tested. In this case, you may assume that it is not hazardous and need not test it. However, used antifreeze from heavy equipment or industrial sources will need to be tested to see if it is hazardous waste unless you have some other way of knowing that it is or is not hazardous. If you wish, you can assume the antifreeze from your heavy equipment is hazardous without testing it. You would then need to dispose of it as hazardous waste.

If your used antifreeze is determined to be a hazardous waste, you must manage it according to the hazardous waste rules. Listed below are the proper management requirements or see the ECAR Hazardous Waste Fact Sheet for more detailed information.

• Label all containers in accordance with the hazardous waste rules. Remember to clearly mark the words “WASTE ANTIFREEZE - HAZARDOUS WASTE.”
• Keep storage containers closed to prevent evaporation and spills.
• Use only permitted waste transporters that have obtained an EPA identification number to transport drums of antifreeze off site.
• Keep a copy of the test results and manifests for off-site disposal in your files.
• Manage the residue or filter cartridge as a hazardous waste.

Recycling.  The Department strongly encourages antifreeze recycling. If you want to recycle your hazardous waste antifreeze on-site you must notify Department. If you recycle 2,200 lbs. or more in a month, you need a resource recovery certification. If you recycle antifreeze only from late-model cars and trucks, you do not need a resource recovery certification.

Your recycling unit will create waste such as distillation residues or used filters. You must determine if these wastes are hazardous before disposal. If the residue is nonhazardous, it can be sent to the landfill with your regular trash. However, liquids cannot go to the landfill.

There may be businesses that will bring equipment to your facility and recycle your antifreeze on-site. Again, if the antifreeze is from late model cars and trucks, these companies do not need resource recovery certification. If it is from heavy equipment or older cars, these companies will need resource recovery certification to recycle your antifreeze.

Off-site Recycling or Disposal. There are companies that pick up used antifreeze for off-site recycling or disposal. If your used antifreeze is a hazardous waste, the transporter must have a Missouri license to transport hazardous waste and the waste must have a hazardous waste manifest with it. Make sure the facility you send it to has a resource recovery certification or a hazardous waste treatment, storage and disposal permit.

Discharge to wastewater treatment plant pouring it down the drain). If the drains at your facility go to a wastewater treatment plant (not a septic system), you may be able to pour antifreeze down the drain IF you have permission from the plant. Pouring wastes down the drain is called a discharge. Some plants will not allow discharges of used antifreeze. Large quantities can harm the treatment plant. The wastewater treatment plant may not be able to remove all the contaminants from the used antifreeze. The contaminants then enter lakes, streams and rivers.

A list of permitted recyclers and transporters in Missouri are listed under “Other Relevant Resources.”

Spills. Notification of hazardous substance releases must be made to the Department hot line at (573) 634-2436, or the National Response Center at (800) 424-8802, at the earliest practical moment upon discovery. The following information must be provided:

• Substances involved.
• Whether the substance is an extremely hazardous substance.
• The medium or media into which the release occurred.
• Any known or anticipated acute or chronic health risks associated with the release.
• Advice regarding medical attention necessary for exposed individuals.
• Proper precautions to take as a result of the release including evacuation.
• Amount of substance released or in danger of being released.
• Location of the hazardous substance emergency and directions to the site.
• Names, addresses, and phone numbers of persons that may have information on the substances involved.
• When the hazardous substance emergency occurred.
• Duration of the release.
• When the release was discovered.
• Actions taken to clean up the hazardous substance and to end the hazardous substance emergency and when those actions will be taken.

Upon request, written follow-up notifications are required for releases of hazardous and extremely hazardous substances.

Links to the Regulations. Use the following links to view the regulations pertaining to used antifreeze management.

Missouri Hazardous Waste Regulations (Division 25)

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 antifreeze storage areas and management procedures.

1. Is used antifreeze stored in drums, tanks or other containers that are in good condition? Open containers, and rusting or leaking containers cannot be used for antifreeze storage.
2. Are antifreeze storage containers and tanks properly labeled? All waste antifreeze should be labeled “Waste Antifreeze Only,” and antifreeze that can be recycled or reused, should be marked “Usable Antifreeze Only.”
3. Is the area around the used antifreeze storage containers free of releases? Releases must be stopped; the released material cleaned up and managed properly and reported to the Department as soon as practicable.
4. Is used antifreeze transported to a recovery facility by a certified transporter? Check your records and verify that all shipments of used antifreeze were removed from your property by a state licensed transporter and that the waste has a hazardous waste manifest with it.
5. Is oil, solvent or other materials mixed with used antifreeze? Verify that there are separate, clearly labeled containers for each type of material, and that used antifreeze is not mixed with used oil, solvents and other materials.

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 used antifreeze storage areas and management procedures.

• Use separate equipment for the collection of used antifreeze (funnels, pads, storage containers).
• Drain antifreeze from radiators and heater cores as soon as possible.
• Keep waste antifreeze free from cross-contamination with other wastes, including used oil, fuels, degreasers or radiator flush chemicals.
• Keep antifreeze storage containers closed at all times.
• Determine if the antifreeze is waste fluid or reusable and can be recycled.
• Recycle by reuse, distillation, filtration or ion exchange. Recycling can be done on-site or off-site by an antifreeze recycling service.
• Wear eye protection, clothing that covers exposed skin and rubber gloves when transferring antifreeze. Pour slowly and carefully to avoid splashing.
• Consider keeping antifreeze in two separate, closed containers: one for antifreeze that cannot be reused marked "Waste Antifreeze," and one marked "Usable Antifreeze."
• Do not dispose of antifreeze down storm drains (unless you have permission from your wastewater treatment plant), in septic tanks, dry wells or on bare ground.
• Keep any records relating to used antifreeze for at least 3 years. This includes receipts for used antifreeze shipments and any laboratory results.

Contacts

1. For more information, contact the Missouri Hazardous Waste Program at 573-751-3176.
2. To report a spill or leak, call the 573-634-2436.
3. To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR fact sheets

1. Hazardous Wastes

Other Related Resources

1. MoDNR Antifreeze webpage
2. Pollution Prevention During Vehicle Salvage
3. Missouri Antifreeze Waste Management Guide
4. Missouri Hazardous Waste Transporters
5. Missouri Hazardous Waste Treatment, Storage and Disposal Facilities

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