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ECAR Fact Sheet for New Mexico
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.
How
can you tell if the brake fluid in your yard is hazardous?
You can send a sample to a laboratory. That will cost you
a testing fee. But if it is non-hazardous and you can document
that fact, you can save the costs of managing it as a hazardous
waste. You can also avoid the lab fee and simply assume it
is hazardous.
This
fact sheet will tell you:
- How to determine if a specific sample of brake fluid
is hazardous.
- What you need to do to manage hazardous wastes in compliance
with the rules.
Regulations
The
U.S. Department of Transportation issues specifications for the
three main kinds of brake fluid in use by the automotive and trucking
industry: DOT-3, DOT-4 and DOT-5. DOT-3 and DOT-4 are glycol-based
fluids and DOT-5 is silicon-based. Depending on the additives used,
brake fluid may or may not be hazardous. Even if brake fluid started
out as non-hazardous, it can become hazardous if it is contaminated
with brake cleaner or other solvents.
Brake
fluid is not crude oil-based and should not be added to and managed
with used oil. However, some companies that pick up used oil may
allow small amounts of brake fluid to be mixed with used oil. Contact the company and ask them if they allow mixing of
used oil and brake fluid. If they don’t, keep them in separate containers.
Another company may have to be used to pick brake fluid.
For
management and disposal/recycle of used brake fluid, you have two
choices:
- Have a sample of the used brake fluid analyzed by a
laboratory to find out if it is hazardous. If it is non-hazardous,
it can be shipped off-site for disposal by a licensed hauler.
If it is hazardous, then special hazardous waste rules apply.
- Assume that the brake fluid is hazardous and manage
and dispose/recycle it as such. This approach avoids laboratory
testing costs.
Links
to the Regulations. Use
the following links to view the regulations pertaining to hazardous
waste determinations and management.
New Mexico’s Hazardous
Waste Management Requirements
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 used brake fluid management procedures.
- Used brake fluid is potentially a hazardous waste.
Verify
that brake fluid was properly managed and disposed/recycled as
hazardous waste or that a hazardous waste determination was made
that indicates it is a non-hazardous waste.
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.
- Brake fluid is not crude oil-based, and therefore it
should not be added to used oil. However, some companies that pick up used oil may allow
small amounts of brake fluid to be mixed with used oil. Contact the company and ask
them if they allow mixing of used oil and brake fluid.
- Collect brake fluid in a dedicated DOT-approved, clearly
and properly labeled drum specifically for brake fluids.
- Identify a waste management company that will recycle
it.
- Don’t put brake fluid into your used oil container.
- 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 the New Mexico Environment
Department, Hazardous Waste Bureau at 505-428-2500.
- To
report a spill or leak, call the New Mexico 24-hour emergency
hotline at 505-827-9329. For non-emergencies, call 866-428-6535.
- To report an environmental incident or complaint, contact
the nearest regional office.
Related
ECAR Fact Sheets
- Hazardous
Waste
Other
Relevant Resources
- New
Mexico – Auto Salvage Guidance Document
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