Checklists: Check Used Filters
| Used Filter 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.
Used oil filters are exempt from federal hazardous waste requirements as long as the filters:
According to federal regulations, a facility can dispose of filters as solid waste (in some states) provided that the filter has been hot-drainedto remove residual used oil. This means that no matter what draining option is used, one should remove the filter from a warm engine and drain it immediately. Four distinct methods of hot-draining can be used:
Used oil filters storage containers must be protected from wet weather by a cover, either indoors in the shop, or if outdoors, in a shed or lean-to. In addition, make sure the container can hold any used oil that seeps from the filters.Used fuel filters can be drained using the same procedure as used oil filters, then tested to determine if they are hazardous. If the fuel filters are hazardous, they must count toward the facility�s generator status. Store used fuel filters in a separate, marked, fireproof container. If the facility is a CESQG, dispose of used fuel filters in a licensed landfill or give them to a hazardous waste hauler. If the facility is an SQG or LQG, then it must use a hazardous waste hauler with an approved EPA ID number.
Note: Disposal requirements for used filters may vary by state, contact you state hazardous waste agency to assure proper disposal. For more information regarding state filter management regulations, referrals to state agencies, and companies that provide filter management services, refer to the Used Filter Hotline at (800) 993-4583. This hotline is sponsored by the Filter Manufacturers Council.
Does the facility completely drain used oil filters and/or used fuel filters before disposal?
How does the facility manage/dispose of used oil filters?
Does the facility inspect used oil filter storage areas for oil spills and leaks?
The automotive repair shop should regularly inspect all areas where oils are received, stored and changed. Use one of the following indicators to identify oil spills: (1) sheen on water, (2) stained soil, (3) lack of vegetation, or (4) visible leaks on the floor. If the shop stores enough oil on-site, there should be a Spill Prevention, Control, and Countermeasures (SPCC) plan available in the event of a spill or leak. The SPCC plan contains detailed information on spill cleanup and remediation. All spills should be contained and cleaned up immediately after detection. Many shops keep absorbent materials close to oil storage and handling locations, in case of an accidental spill.
Has the facility determined if its used fuel filters are hazardous?
How does the facility manage/dispose of used fuel filters?
|Source: U.S. EPA Office of Enforcement and Compliance Assurance, EPA 305-B-03-004, October 2003.
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