ECAR Fact Sheet for Washington
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 may have to be managed
as hazardous
wastes.
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 therefore it cannot be added to and managed with used oil.
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.
Washington
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.
- 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 Washington Department of Ecology Hazardous Waste and Toxics
Reduction Program at 360-407-6700.
- To report a spill or leak, call
1-800-258-5990.
- To report an environmental incident
or complaint, contact the nearest Ecology
Regional Office.
Related
ECAR Fact Sheets
- Hazardous
Waste
Other
Relevant Resources
- List
of Washington Hazardous Waste Transporters
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