Checklists: Check Antifreeze
Used Antifreeze Information
Shop Tour Stop #1
The following questions and guidance are taken from the Consolidated Screening Checklist for Automotive Repair Facilities Guidebook.
A √ next to a response in the guide indicates that is the preferred response in terms of environmental compliance. If you select a response without a √, you may still be in compliance; however, you should verify that you are in compliance by contacting the appropriate federal or state regulatory agency and discussing your activity with them.
When stored, does the facility contain, segregate, and label used antifreeze?
- Contained–Contained. Containers are closed (e.g., lids are on, caps are screwed on tight, except when actually adding or removing liquid).
- Segregated–Used antifreeze is in its own container and not mixed with other liquids.
- Labeled–Labels or color coding indicates that the container holds only antifreeze. In contrast to used oil, there are no specific labels for antifreeze. To be considered properly labeled, the drum/container/tank should simply have the words “used antifreeze,” or “waste antifreeze,” or “antifreeze only,” or similar wording that distinguishes antifreeze storage from oil and solvent storage. Words can be spray painted, stenciled, crayoned, or more formally labeled.
Yes–Used antifreeze is contained, segregated, and labeled. √No–Used antifreeze is not contained, segregated, and labeled.
N.A.–Facility does not generate used antifreeze.
Has the facility determined if it generates any antifreeze that is a hazardous waste?
Used antifreeze may be characterized as hazardous waste by testing or by process knowledge.
- If a facility makes the hazardous/nonhazardous determination solely by testing, it must test each batch of antifreeze changed from each vehicle serviced.
- If a facility uses process knowledge, the determination must involve a demonstrated understanding of the potentially hazardous constituents in antifreeze. Such a demonstrated understanding could include a combination of the information on the MSDS for the type of antifreeze used, a referral to a previous test that demonstrated that antifreeze from new vehicles does not contain metals, and/or having a procedure to ensure that any suspect antifreeze is segregated from antifreeze known not to be hazardous.
There are two functional indicators that can assist the shop owner/manager in determining whether the antifreeze is not (or is likely to be) a hazardous waste. First, antifreeze is considered hazardous if it is mixed with a hazardous waste such as cleaning solvents. Second, antifreeze removed from a cooling system that contains lead either within the engine or the cooling (radiator) system likely contains enough lead to characterized the antifreeze as “toxic.”
Yes–Facility has determined whether its used antifreeze is hazardous by testing or by process knowledge. √
No–Facility has not determined whether its used antifreeze is hazardous or not.
N.A.–Facility does not generate used antifreeze.
Does the facility reclaim used antifreeze on-site in a closed loop system?
To avoid having to manage and dispose of used antifreeze as a hazardous waste, a facility can reclaim used antifreeze in a closed loop system that connects directly to the radiator, filters the antifreeze, and returns it directly back into the vehicle. EPA does not consider such reclaimed material to be a solid waste. Thus, even though the antifreeze may be hazardous, it is not a hazardous waste because the antifreeze is returned to its original use as a coolant.
Non-closed systems are available that connect to a used antifreeze storage drum. However, because these are not closed loop systems, the antifreeze in the drum may be considered a hazardous waste and must be stored according to the hazardous waste regulations.
Yes–Facility reclaims used antifreeze in a “closed loop” system. √
No–Facility does not reclaim used antifreeze in a “closed loop” system.
N.A.–Facility does not generate used antifreeze.If not reclaimed in a closed loop system, how does the facility manage the antifreeze?
Antifreeze that is determined not to be a hazardous waste is not counted towards the monthly hazardous waste count. Antifreeze that is hazardous must be managed according to the hazardous waste regulations.
- Recycled on-site–Facility manages used antifreeze accordingly, depending on whether the antifreeze is determined to be a solid waste or hazardous waste. √
- Recycled off-site–Facility sends used antifreeze off-site for recycling. √
- Landfill–Facility disposes used antifreeze at a landfill. Many landfills accept antifreeze as a separate waste. This does not mean antifreeze deposited in the dumpster with other shop waste.
- Mixed with other fluids–Facility mixes used antifreeze with used oil, solvents or other fluids.
- UIC Well–Facility discharges used antifreeze into an underground injection control (UIC) well. The facility should immediately stop this method of disposal!
Source: U.S. EPA Office of Enforcement and Compliance Assurance, EPA 305-B-03-004, October 2003.