Used Antifreeze

ECAR Fact Sheet for New York
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

Because of its composition, antifreeze could ordinarily qualify as a hazardous waste. But in order to encourage recycling, the state of New York will give you a break and exempt you from the burden of handling it according to the usual hazardous waste rules if you manage it properly. This fact sheet will tell you:

How to handle antifreeze to qualify for the exemption.
What you need to do if you do not qualify in order to manage antifreeze in compliance with hazardous waste rules.

Regulations

Waste Classification. Antifreeze is made up using some regulated chemicals including ethylene glycol and propylene glycol. During use, antifreeze can become contaminated with traces of fuel or metal particles. Used antifreeze should never be disposed of down storm drains or surface waters. It is illegal and dangerous to discharge antifreeze to septic systems or to the outdoors. Due to its composition, used antifreeze can be considered a hazardous waste. However, in the state of New York, used antifreeze is exempt from hazardous waste regulations if it is properly managed and:

It is used in your facility vehicles;
Given away for reuse; or
Processed for recycling either on-site or by an off-site licensed recycler. If you use an off-site recycler, you must ensure that the antifreeze is being recycled.

If you chose not to recycle used antifreeze, you have two choices:

Have a sample of the used antifreeze 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 antifreeze is hazardous and manage it as such. This approach avoids laboratory testing costs.

See the ECAR Hazardous Waste fact sheet for details about storing, handling, and shipping of hazardous wastes.

Storage of Used Antifreeze. Whether your antifreeze is new or taken from vehicles and is reused, sold or given away for reuse, its storage may be regulated by the New York Department of Environmental Conservation (DEC) Chemical Bulk Storage (CBS) Program. If you are storing nonhazardous antifreeze in an aboveground tank with a capacity of 185 gallons or greater, or are storing any amount of nonhazardous antifreeze in an underground tank, the site must be registered with DEC and comply with CBS regulations. Antifreeze stored in drums (rather than in a tank) does not require registrations under the CBS program.

As with the storage of used oil, secondary containment is required for the storage of antifreeze in aboveground tanks.

Labeling. Use the following labeling for antifreeze that will be recycled or reused. For hazardous wastes, see the ECAR Hazardous Waste fact sheet for labeling instructions.

Label used antifreeze collection equipment and containers with the words "Used Antifreeze."
Label reconditioned or recycled antifreeze containers with the words "Reconditioned or Recycled Antifreeze."
Mark used antifreeze containers with the starting date of accumulation.

If used antifreeze at your facility is a hazardous waste, see the ECAR Hazardous Waste fact sheet for additional storage requirements.

Spill Control. All petroleum spills that occur within New York State (NYS) must be reported to the NYS Spill Hotline (1-800-457-7362) within 2 hours of discovery, except spills which meet all of the following criteria:

The quantity is known to be less than 5 gallons; and
The spill is contained and under the control of the spiller; and
The spill has not and will not reach the State’s water or any land; and
The spill is cleaned up within 2 hours of discovery.

A spill is considered to have impacted land if it occurs on a paved surface such as asphalt or concrete. A spill in a dirt or gravel parking lot is considered to have impacted land and is reportable.

Filter Management. You must either manage waste antifreeze filters as hazardous waste or prove that they are non-hazardous through laboratory analysis. See the ECAR Hazardous Waste fact sheet for additional information.

Record Keeping. Keep all receipts of used antifreeze shipments and filter management. The written receipts or records must include:

Name and address of the generator and the recycling facility for off-site shipments.
The amount of used antifreeze shipped or recycled on-site.
The amount of waste antifreeze filters shipped off-site.
Date of shipment or recycling.

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

New York Conservation Rules and Regulations on Hazardous Waste Management (NYCRR 373)

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 antifreeze storage areas and management procedures.

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.
Are antifreeze storage containers and tanks properly labeled? All used antifreeze storage containers must be labeled "Used Antifreeze." All recycled or reconditioned antifreeze storage containers must be labeled "Recycled or Reconditioned Antifreeze."
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 NYS Spill Hotline.
Is your site registered with DEC and are you complying with CBS regulations? Certain aboveground storage tanks and all underground storage tanks must be registered with DEC and comply with CBS regulations.
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 certified transporter.
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).
Label used antifreeze collection equipment and containers "Used Antifreeze."
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.
Determine if the antifreeze is waste fluid or reusable and can be recycled.
Consider keeping antifreeze in two separate, closed containers: one for antifreeze that cannot be reused marked "Waste Antifreeze," and one marked "Usable Antifreeze."
Label reconditioned or recycled antifreeze containers "Reconditioned or Recycled Antifreeze."
Label antifreeze containers with the starting date of accumulation.
Install an antifreeze recycling system. [Waste antifreeze recycling methods involve two steps: (1) removing contaminants either by filtration, distillation, reverse osmosis, or ion exchange and (2) restoring critical antifreeze properties with additives. Additives typically contain chemicals that raise and stabilize pH, inhibit rust and corrosion, reduce water scaling and slow the breakdown of ethylene glycol.]
Keep any records relating to used antifreeze for at least 3 years. This includes receipts for used antifreeze shipments and any laboratory results.
Employ the following procedure for antifreeze spills on floors:

Mop up the antifreeze immediately using a dedicated cloth mop. Transfer collected antifreeze to the properly labeled antifreeze waste container for recycling.
Use rags to dry the floor. Place used rags in properly labeled waste containers and send rags to an industrial laundry. Do not saturate the rags; otherwise you will have drips on the floor as you transfer them to the waste containers.
Use a wet mop only if necessary for final cleaning. Use mild, non-caustic detergent.

Contacts

For general information on tank and bulk storage programs, contact the Bulk Storage Hotline at 518-402-9549.
NYS Spill Hotline (1-800-457-7362).

Related ECAR Fact Sheets

Hazardous Waste

Other Related Resources

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