1103 Industry Overview

Industry Overview

If your business is in the vehicle maintenance category, then the products you use on the vehicles and on your equipment, tools, hands, or floor might contain hazardous materials, and the waste generated by using these products might be hazardous waste. If you generate hazardous waste, you might be subject to the Resource Conservation and Recovery Act (RCRA) requirement covering the generation, transportation, and management of hazardous waste.

Your business is classified under vehicle maintenance if you repair or maintain:

• Vans
• Trucks
• Vehicle Fleets
• Heavy equipment
• Farm equipment

Vehicle maintenance operations that might generate hazardous waste include:

• Removing oil or grease
• Removing rust, dirt, or paint
• Repairing or rebuilding
• Refinishing or restoring
• Painting
• Replacing lead-acid batteries

Hazardous Wastes from Vehicle Maintenance

Every day, mechanics and body repair personnel use products containing hazardous materials. Products containing materials that are hazardous to human health and the environment include:

Rust removers that contain strong acid or alkaline solutions
Carburetor cleaners that contain flammable or combustible liquids
Parts cleaners and degreasers that contain toxic chemicals
Paint thinners or reducers that are ignitable or contain toxic constituents
Motor oil and other petroleum products that are ignitable or contain toxic chemicals
Auto and truck batteries.

Waste that is generated as a result of using these products might be RCRA-regulated hazardous waste.

Table 1 lists typical processes/operations that use products that might contain hazardous materials and that probably generate hazardous waste. If you generate 100 kilograms (220 pounds or about half of a 55-gallon drum) or more of hazardous waste per month you must fill out a Uniform Hazardous Waste Manifest when you ship hazardous waste off your property. The Manifest requires the proper Department of Transportation (DOT) description for each waste. [2]Table 2 lists proper DOT shipping descriptions for a number of wastes that might be generated during vehicle maintenance operations. Table 1 and Table 2 are not comprehensive lists. If you suspect any waste you generate is hazardous, check with your state hazardous waste management agency or Regional epa office.

There are special provisions in the regulations for spent lead batteries and used oil. You do not have to use a Manifest when you ship used lead batteries that are destined for recycling or used motor oil that is destined for recycling. If, however, you are disposing of used oil yourself or are sending it off-site for disposal, you generally should handle it as hazardous waste because it is likely to be ignitable or toxic. Special requirements apply if you are burning used oil as fuel. Your state might have its own requirements for lead-acid batteries or used oil; check with you state hazardous waste management agency.

Waste Minimization

An effective waste minimization program can reduce the costs, liabilities, and regulatory burdens of hazardous waste management, while potentially enhancing efficiency, product quality, and community relations. Waste minimization techniques that can help you reduce the amount of hazardous waste that you generate include:

• Production planning and sequencing
  • Process/equipment adjustment or modification
  • Raw material substitution
  • Loss prevention and housekeeping
  • Waste segregation and separation
  • Recycling
• Training and supervision of employees implementing waste minimization techniques is an important part of your successful program. Call the RCRA/Superfund Hotline toll-free at 800-424-9346 (or TDD 800-553-7672 for the hearing-impaired) for waste minimization information and publications.

For further information, call the RCRA/Superfund Hotline 1-800-424-9346.

Table 1
Typical Vehicle Maintenance Operations:
Materials Used and Hazardous Wastes That Might Be Generated

Table 2
Vehicle Maintenance Waste Descriptions¹

Source: US EPA

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