ECAR Fact Sheet for Rhode Island
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.

You can avoid the burden of treating brake fluid as a hazardous waste:

• If you do not contaminate it with other fluids, and
• If you handle and store it properly, and recycle it with your used oil.

This fact sheet will tell you what you need to do to avoid problems with fluids.

Regulations

*Used oil shall include, but not be limited to, lubricating oils and greases, engine oils, metal working fluids, emulsive coolants, hydraulic fluids, refrigeration oils, electrical insulating oils, silicon oils, and wire drawing oils.

Used Brake fluid often contains additives and may be contaminated with solvents (e.g., brake cleaner). When used brake fluid is disposed of, these contaminants may cause the fluid to be considered a hazardous waste and you must follow the rules on management and disposal of hazardous waste (see Hazardous Waste fact sheet).

However, EPA does not consider used brake fluid to be a hazardous waste when it is combined with used oil and recycled or burned as fuel, even if it has hazardous characteristics. Instead the recycled used brake fluid should be treated as used oil and managed under the used oil regulations.

Links to the Regulations. Use the following links to view the regulations pertaining to hazardous waste determinations and management.

EPA Memorandum regarding used brake fluid and other automotive fluids.

Rhode Island's Hazardous Waste Management Requirements

Rhode Island's Used Oil Recycling Act

Standards for the Management of Used Oil (Code of Federal Regulations, 40 CFR Part 279)

Part 261 - Identification and Listing of Hazardous Waste

Part 262 - 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.

1. Is your brake fluid free from solvents, brake cleaners or carb cleaners? If the brake fluid has not been contaminated with such elements, it can be recycled.
2. Used brake fluid is potentially a hazardous waste. Verify that contaminated 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.

• Recycle used brake fluid along with used oil.
• Train your employees on the proper methods for handling used oil.
• Do not contaminate used oil with even small amounts of gasoline, brake cleaner, carburetor cleaner, or other solvents.
• Keep storage containers closed when not actively adding or removing material.
• When storing drums keep an aisle space between drums to allow for inspection for leaks and damage.
• Install secondary containment to prevent the release of used oil to the environment.
• Inspect containers and secondary containment structures on a weekly basis to be certain that they are in good condition. Keep written records of these inspections for at least 3 years.
• Try to prevent spills when dismantling vehicles. If spills do occur, clean up with rags. After wringing out the saturated rag into the used oil drum, you can have the rags laundered.
• Avoid using absorbents for brake fluid/oil spills unless there is a threat of the spill spreading to soil or water. Oily absorbents must be evaluated prior to disposal to determine whether they are hazardous or nonhazardous.
• Before contracting a transporter for your used oil, make sure to check for the transporter’s state certification.
• Get receipts for used oil shipments and store them in your records for at least 3 years.

Contacts

1. For more information, contact the Rhode Island DEM, Office of Waste Management at
   401-222-2797.
2. To report a spill or leak, immediately call the DEM at 401-222-1360 or, if after hours, call the
   24-hour emergency number at 401-222-3070.
3. To report an environmental incident or complaint, contact the DEM Offices.

Related ECAR Fact Sheets

1. Hazardous Waste
2. Used Oil

Other Relevant Resources

1. EPA – Used Oil Fact Sheet
2. Rhode Island - Permitted Hazardous Waste Transporter List
3. Rhode Island - Waste Oil Vendors
4. Rhode Island's Hazardous Waste Compliance Workbook for Generators

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