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.


Does the facility dispose of spent brake washing solvent as hazardous waste?

Once the automotive shop uses a solvent to clean the brake system, the facility must manage the spent solvent properly. It is likely the solvent will be a hazardous waste because of the flammable characteristic, not the asbestos content. However, the shop must determine if the solvent meets the hazardous waste definition.


Yes–Facility manages spent solvent as a solid or hazardous waste after making hazardous waste determination.  √


No–Facility has not made a waste determination of the solvent.


N.A.–Facility does not generate brake washing solvent.

Does the facility manage used vacuum filters as asbestos-containing material waste?

The facility must collect used filters from the HEPA vacuum as well as the particles in the vacuum and dispose of them as asbestos-containing material waste. Keep the filters wet and seal them in leak-tight wrapping. Label the containers or wrapped packages using warning labels: DANGER – Asbestos, Avoid Creating Dust, Cancer and Lung Cancer.


Yes–Facility collects and manages used vacuum filters as described above.  √


No–Facility does not collect and/or manage used vacuum filters as described above.


N.A.–Facility does not generate used vacuum filters or brake pads.

How does the facility manage asbestos brake pads?


Recycling and reclamation are the preferred methods for used asbestos brake pads. If asbestos is known or suspected of being present, inform the recycling or reclamation company. If landfilling, make a determination for presence of asbestos prior to disposal. If asbestos is present, use only landfills or disposal sites approved for asbestos.If the asbestos brake pads are sent to an EPA-approved disposal site, the pads must be in containers, labeled with the name and location of the waste generator. Vehicles used to transport the asbestos must be clearly labeled during loading and unloading. Maintain the waste shipment records so that the asbestos shipment can be tracked.


Recycled off-site–A manufacturer or a recycling company collects used brake pads for recycling.  √


Disposed by vendor–A vendor disposes of the brake pads by landfilling or other means of disposal.


Other–Method of disposal is not listed here.


N.A.–Facility does not generate ACM waste.


Source: U.S. EPA Office of Enforcement and Compliance Assurance, EPA 305-B-03-004, October 2003.

Click here to send questions or comments to CCAR®.