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ECAR Fact Sheet for Pennsylvania
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.

Transmission fluid is difficult to remove and spills are a very common occurrence. Up to eight quarts of fluid can be drained from a car’s transmission. Extra care must be taken to properly drain transmissions so that spills do not occur.

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 follow the hazardous waste requirements for storage and disposal. See the ECAR Hazardous Waste Fact Sheet.

For management and disposal/recycle of contaminated fluids, you must:

  1. Have a sample of the used 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.
  2. Assume that the fluid is hazardous and manage and dispose/recycle it as such. This approach avoids laboratory testing costs.

Transmission filters should be handled like used oil filters. This means that transmission filters are exempt from the state hazardous waste requirements if they are they are managed by one of the following methods:

  • Puncturing the filter anti-drain back valve or the filter dome end and hot-draining;
  • Hot-draining and crushing;
  • Dismantling and hot-draining; or
  • Any other equivalent hot-draining method which will remove used oil.

Also, keep in mind that "hot-drained" means draining the oil filters at temperatures near the operating temperature of the engine, not draining at room temperature. A minimum of 12 hours draining time is required for proper hot-draining. Filters that immediately drip oil when picked up are not considered drained. *Used oil drained from filters can be combined with other used oil.

Used oil filters that are not drained by the above methods must be managed as hazardous waste. Fuel filters also are considered hazardous waste and must be managed accordingly.

Disposal. If the above methods have been performed, used oil filters can be disposed of according to town and county requirements. The drained filters should be placed in covered dumpsters or containers that prevent rain infiltration. In addition, the dumpsters or containers should be capable of holding any residual used oil that may escape from the filter.

Oil Spills. If a spill occurs, you must perform the following cleanup steps:

  1. Stop the release;
  2. Contain the released used oil;
  3. Clean up and properly manage the released used oil and other materials; and
  4. If necessary, repair or replace any leaking used oil storage containers or tanks prior to returning them to service.
  5. Notify DEP’s 24-hour hotline at 800-541-2050.

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

Pennsylvania Code Used Oil Management Regulations

Federal EPA Used Oil Management Requirements


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 using proper draining methods.
  • Keep drained filters in a container marked "Used Transmission Filters."
  • Do not put undrained filters in the dumpster.

Contacts

  1. For more information, contact the DEP’s Bureau of Waste Management at 800-346-4242.
  2. To report a spill, contact DEP’s 24-hour hotline at 800-541-2050.
  3. To report an environmental incident or complaint, contact the DEP Field Office.

Related ECAR Fact Sheets

  1. Used Oil

Other Relevant Resources

  1. Pennsylvania Used Oil Collection and Recycling Sites
  2. DEP Used Motor Oil Recovery
  3. DEP Regulations on Used Oil Management
  4. Recycle Used Oil Filters


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