United States 

Environmental Protection

Agency

1EPA

Solid Waste and

Emergency 

Response

EPA530-K-99-004

June 1999

www.epa.gov/osw

■ RELEVANT

RESOURCES
FOR MORE INFORMATION CALL:

RCRA Hotline

U. S. Environmental Protection Agency

800 424-9346 or TDD 800 553-7672.

In the Washington, DC, area: 703 412-9810 

or TDD 703 412-3323.

2 Printed on paper that contains at least 30 percent postconsumer fiber.
recycling and pollution prevention options to help businesses decrease

the amount of hazardous waste they produce.

1

VEHICLE MAINTENANCE
To be considered hazardous waste, a material first must be classified as a solid waste. EPA defines

solid waste as garbage, refuse, sludge, or other discarded material (including solids, semisolids, liquids, and contained gaseous materials). If your waste is considered solid waste, you must then determine if it is hazardous waste. Wastes are defined as hazardous by EPA if they are specifically named

on one of four lists of hazardous wastes (listed wastes) or if they exhibit one of four characteristics

(characteristic wastes). Each type of RCRA hazardous waste is given a unique hazardous waste code

using the letters D, F, K, P, or U and three digits (e.g., D001, F005, P039). See pages 10 to 13 for

additional information on vehicle maintenance waste codes.

Listed Wastes. Wastes are listed as hazardous because they are known to be harmful to human

health and the environment when not managed properly, regardless of their concentrations. The

lists include the following three types of waste:

■ Non-Specific Source Wastes. These are material-specific wastes, such as solvents, generated

by several different industries. Waste codes range from F001 to F039. Examples include methylene chloride and trichloroethylene generated in the vehicle maintenance industry during car and

parts washing, degreasing, and paint removal. 

■ Specific Source Wastes. These are wastes from specifically identified industries. Waste codes range

from K001 to K161. Vehicle maintenance facilities typically do not generate specific source wastes.

■ Discarded Commercial Chemical Products. Off-specification products, container residuals,

spill residue runoff, or active ingredients that have spilled or are unused and that have been, or

are intended to be, discarded. Waste codes range from P001 to P205 and U001 to U411. 

2 RCRA IN FOCUS

ties handling hazardous

waste, which are considered part of the authorized program. 

MORE 

QUESTIONS? 

Call the RCRA

Hotline at 

800 424-9346 or TDD

800 533-7672 for 

additional information

about RCRA rules and

regulations. In the

Washington, DC, area,

call 703 412-9810 or

TDD 703 412-3323.
categories, according to how much they generate in a calendar month:

■ Large Quantity Generators (LQGs). LQGs generate greater than or equal to 1,000 kg

(approximately 2,200 lbs) of hazardous waste per month, or greater than 1 kg (approximately 2.2

lbs) of acutely hazardous waste per month.

■ Small Quantity Generators (SQGs). SQGs generate more than 100 kg (approximately 220

lbs) but less than 1,000 kg (2,200 lbs) of hazardous waste per month.

■ Conditionally-Exempt Small Quantity Generators (CESQGs). CESQGs generate less

than or equal to 100 kg (220 lbs) of hazardous waste per month, and less than or equal to 1 kg

(2.2 lbs) of acutely hazardous waste per month.

Some states do not recognize the CESQG class. Contact your state environmental agency to find

out if the CESQG status is recognized. To find your appropriate state contact, call the RCRA

Hotline at 800 424-9346.

Under the federal RCRA requirements, your generator status might change from one month to

the next as the quantity of waste you generate changes. You must comply with whichever standard

is applicable for a given month. In many cases, small businesses that fall into different generator categories at different times choose to always satisfy the more stringent requirements (usually state

requirements) to simplify compliance. Generators must “count” the amount of waste generated

during a calendar month, which involves adding up the total weight of all quantities of characteristic

and listed waste generated at a particular facility. Certain wastes, such as those that are reclaimed or

recycled continuously on site, are not counted under the federal regulations.

VEHICLE MAINTENANCE 3

I

y

nance facility stores

petroleum on the prem

in underground storag

tanks (USTs), you are 

ject to the RCRA regu

tions for USTs. Regula

requirements for UST

include instituting me

for corrosion protectio

preventing spills and o

fills, and implementati

leak detection program 

provides monitoring fo

leaks at least once ever

days. Vehicle maintena

facilities subject to the 

regulations should con

the Hotline or their st

environmental agency 

further guidance on U

requirements.
How Is Used Oil Handled?

RCRA contains special provisions for the management of used oil destined for recycling. These

management standards apply to oil refined from crude oil or any synthetic oil that has become contaminated through use by chemical or physical impurities. Used oil that will be recycled is subject

to special management standards, rather than the hazardous waste standards, unless it is treated as a

waste (i.e., you decide to send the used oil for treatment and disposal rather than recycling).

Vehicle maintenance facilities are likely to be regulated only as used oil generators. Vehicle maintenance facilities might generate used oil from changing oil for their customers, from onsite equipment, or from “do-it-yourselfers” who change their own oil. 

USED OIL GENERATORS

A used oil generator is any person, by site, who first causes used oil to become subject to 

regulation. 

Used oil standards require generators to comply with basic storage requirements. Used oil can

only be stored in containers and tanks that are in good condition (free of any visible leaks, structural

damage, or deterioration). Containers, aboveground tanks, and fill pipes used to transfer used oil

into underground storage tanks need to be clearly marked with the words “Used Oil” to prevent

mixing of used oil with hazardous waste or other materials. In the event of a release from one of

4 RCRA IN FOCUS
VEHICLE MAINTENANCE

that some states have different requirements than the federal government. Vehicle maintenance

facility owners should check with their state environmental agency for more information on the

used oil management standards in their state.

mation) are satisfied by

these conditions, EPA

believes that these substances do not need to 

routinely reported und

EPCRA when amount

do not exceed specified

limits and are stored in

underground storage

tanks at retail gas statio

5
6 RCRA IN FOCUS 

11 131PREPARE APPROPRIA 2TE

NOTIFICATION AND

CERTIFICATION

Ensure that all hazardous

waste sent off site for treat-

ment, storage, or disposal is

accompanied by appropriate

land disposal restrictions

(LDRs) program notifications

and certifications. (See page 9

for a description of LDRs.)

DISPOSAL 

Using a licensed hazardous

waste transporter, ship the

radiator repair and parts

washing waste to a RCRA

hazardous waste TSDF

accompanied by the appro-

priate manifest and land

disposal restrictions notifi-

cation and certification.

Optional destinations for

solvents include a haz-

ardous waste incinerator

that will landfill the incin-

erator ash, a hazardous

waste fuel blender who will

blend the solvents with

other wastes and then burn

them for energy recovery in

a boiler or industrial fur-

nace, or a facility that will

recycle the solvents.

PREPARE HAZARDOUS

WASTE MANIFEST 

Send a manifest along with

all hazardous waste sent off

site to a TSDF and keep a

copy on site for 3 years. The

manifest contains a certifica-

tion stating that your facility

has a program in place to

reduce the volume and toxici-

ty of waste generated to the

degree economically practica-

ble.
VEHICLE MAINTENANCE 7

8 7 10 9

PROCEDURES 

Ensure that a contingency

plan is prepared in accordance

with standards to minimize

hazards from fires, explosions, and unplanned releases.

Keep a copy of the contingency plan on site.

IMPLEMENT

PERSONNEL TRAINING

Be sure your personnel are 

thoroughly familiar with hazardous waste handling and

emergency response procedures.

CONTRACT WITH

HAZARDOUS WASTE

TRANSPORTER

To send waste off site to a

TSDF, contract with a registered hazardous waste transporter. To locate a reliable

transporter, contact a colleague to obtain a reference.

FOLLOW U.S.

DEPARTMENT OF

TRANSPORTATION (DOT)

PACKAGING STANDARDS

Before shipping waste off site

for treatment, storage or disposal, you should package,

label, and mark waste containers in accordance with all

applicable DOT requirements. Call the DOT

Hotline at 800 467-4922 for

information.
REQUIREM

The following 

As noted, your state 

REGULATORY L

REQUIREMENT

EPA IdentificationNumberHazardous WasteIdentificationUsed Oil StandardsWaste CountingAccumulation AreaOther AccumulationAreas (Time andQuantity Limits)Accumulation UnitRequirementsAir EmissionsPreparedness andPrevention
Contingency PlanPersonnel TrainingDOT PackagingOffsite Managementof WasteOnsite Managementof WasteManifestLand DisposalRestrictionsNotificationHazardous WasteMinimizationBiennial ReportRecordkeeping
10 RCRA IN FOCUS

Lead dross, zinc, copper, and spent sulfuric acid.

D002 and D008.

■ Arrange for spent battery collection and recycling.

■ Ship waste using a registered transporter to a hazardous waste TSDF for treatment and

disposal.

■ Install longer life batteries.

Body Repair and Refinishing

Scrap metal.

D006, D007, and D008.

Chemicals Used 

and/or Generated

Possible RCRA

Waste Codes

Potential Recycling

Treatment and

Disposal Methods

Potential Pollution

Prevention Methods

PROCESS

Chemicals Used 

and/or Generated

Possible RCRA

Waste Codes 
VEHICLE MAINTENANCE 11

Potential Pollution

Prevention Methods

PROCESS

Wastes Generated

Possible RCRA

Waste Codes

Potential Recycling,

Treatment, and

Disposal Methods

p ppqg 

■ Use a long-lasting, high-performance oil that needs less frequent changing.

■ Use fluids (e.g., brake, transmission, etc.) that do not contain chlorinated hydrocarbons.

Rustproofing, Painting, and Paint Removal

Spent halogenated and nonhalogenated solvents such as acetone, toluene, benzene,

xylene, methanol, methylene chloride, isopropyl alcohol; waste paint thinner and paint; paint

filters; and spent rags and wipes.

D001, D035, F002, and F003.

■ Keep waste paint and paint sludge separate from waste thinner.

■ Collect rustproofing drippage and dispose of properly.

■ Collect hazardous waste and ship it using a registered transporter to a hazardous waste

TSDF for treatment and disposal.

■ Reclaim solvents and paint thinners on site (small stills are available in a variety of volumes), or send for recycling.

■ Give leftover paint to the customer.

■ Use recyclable paint filters.
12 RCRA IN FOCUS

Product Storage and Storage Tank Cleaning

Various solvents and petroleum products potentially outdated or off-specification.

D001 and F001.

■ Ship off-specification and outdated products using a registered transporter to a hazardous waste TSDF for treatment and disposal.

■ Reclaim/reuse off specification products.

■ Use a first in, first out policy in storage areas to prevent materials from becoming 

outdated.

■ Computerize inventory control.

■ Routinely inspect storage areas.

■ Comply with UST design standards and monitoring to prevent leaks.

PROCESS

Wastes Generated

Possible RCRA

Waste Codes 

Potential Recycling,

Treatment, and

Disposal Methods

Potential Pollution

Prevention Methods
VEHICLE MAINTENANCE 13

Waste Codes

Potential Recycling,

Treatment, and

Disposal Methods

Potential Pollution

Prevention Methods

D001, D002, D008, and F002.

■ Properly store wastes in hazardous waste accumulation tanks or containers.

■ Ship hazardous waste using a registered transporter to a hazardous waste TSDF for

treatment and disposal.

■ Use good housekeeping practices to prevent contaminants from reaching the floor 

(drip pans, worker training and incentives, proper containers for wastes).

■ Use less hazardous cleaners (biodegradable when possible).

■ Do not use solvents for cleaning floors.

■ Avoid disposing of partially used rags or absorbents. Use them to their limit.
RCRA IN FOCUS

for appropriate containment or diversionary structures to prevents spills of oil from reaching

navigable waters. 

Oil Pollution Prevention Regulation Resources:

■ 40 CFR Part 112

■ Internet access: <www.epa.gov>

THE CLEAN AIR ACT 

The Clean Air Act (CAA) regulates air pollution. It includes national emission standards for new

stationary sources within particular industrial categories. It also includes national emission standards

for hazardous air pollutants, which are designed to control the emissions of particular hazardous air

pollutants (HAPs). Vehicle maintenance facilities might have to comply with NESHAP regulations

if they use halogenated solvent cleaning machines. The CAA also seeks to prevent the accidental

release of certain hazardous chemicals and to minimize the consequences of such releases. 

CAA Resources:

■ 40 CFR Parts 50 to 99

■ Control Technology Center, Office of Air Quality, Planning and Standards, EPA, general information: 919 541-0800, publications: 919 541-2777

■ Internet access: <www.epa.gov/ttn/catc>

COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND

LIABILITY ACT (CERCLA OR SUPERFUND)

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 

of 1980, commonly known as Superfund, authorizes EPA to respond to releases, or threatened

Part 263—Standards

applicable to transporters

of hazardous waste.

Part 264—Standards for

owners and operators of

hazardous waste and

specific types of hazardous waste management facilities.

Part 265—Interim status

standards for owners and

operators of hazardous

waste TSDFs.

Part 266—Standards for

the management of specific hazardous wastes

and specific types of

hazardous waste management facilities.

continued

14
VEHICLE MAINTENANCE

e State egecy Repoe Coo(cotact avaabe oRCRote)

■ Internet access: <www.epa.gov/opptintr/tri/index.htm> and <www.epa.gov/swercepp>

SAFE DRINKING WATER ACT 

The Safe Drinking Water Act (SDWA) mandates that EPA establish regulations to protect human

health from contaminants present in drinking water. Under the authority of the SDWA, EPA developed

national drinking water standards and created a joint federal-state system to ensure compliance with

these standards. EPA also regulates underground injection of liquid wastes under the SDWA to protect underground sources of drinking water. 

SDWA Resources:

■ 40 CFR Parts 141 to 148

■ SDWA Hotline: 800 426-4791

■ Internet access: <www.epa.gov/ogwdw>

TOXIC SUBSTANCES CONTROL ACT

The Toxic Substances Control Act (TSCA) allows EPA to collect data on chemicals to evaluate,

assess, mitigate, and control risks that might be posed by their manufacture, processing, and use.

The vehicle maintenance industry is required to report information as necessary to allow EPA to

develop and maintain this inventory. 

TSCA Resources:

■ 40 CFR Parts 702 to 799

■ TSCA Hotline: 202 554-1404

■ Internet access: <www.epa.gov/internet/oppts>

See the regulations at

<www.access.gpo.gov/nara

FOR MORE

INFORMATION

For additional info

mation on any of

these laws, contact the

RCRA Hotline at 

800 424-9346 or 

703 412-9810 in the

Washington, DC, area

TDD (hearing

impaired): 800 553-76

or 703 412-3323 in the

Washington, DC, area

15
Clearinghouse/Hotline

U.S. Environmental Protection Agency

Small Business Ombudsman (2131C)

401 M Street, SW.

Washington, DC 20460

Phone: 800 368-5888

Fax: 202 401-2302

Home page: 

<www.smallbiz-enviroweb.org>

Helps private citizens, small businesses,

and smaller communities with questions

on all program aspects within EPA.

EPA Headquarters Library

U.S. Environmental Protection Agency

Headquarters Library

401 M Street, SW, Room 2904

Washington, DC 20460

Phone: 202 260-5921 or 5922

Fax: 202 260-6257

E-mail: library-HQ@epa.gov

Home page: <www.epa.gov/natlibra/

liblists.html>

g, 

Phone: 202 512-1800

Fax: 202 512-2250

Home page: <www.access.gpo.gov>

Prints and distributes the Code of Federal

Regulations. Title 40, Parts 260 to 299, contains most of the RCRA requirements.

National Response Center

(NRC)

Phone: 800 424-8802

In the event of a fire, explosion, or other

release of hazardous waste that could

threaten human health outside the facility,

call the NRC to report the emergency.

The NRC will evaluate the situation and

help you make appropriate emergency

decisions.

gg(

links to more than 25 automotive industry

Internet sites)
and operators understand how best to

comply with federal hazardous waste

management regulations. This booklet

defines the three categories of hazardous

waste generators and assists small businesses in determining if federal regulations apply. This document also explains

g

Fuel for Thought...How to Reduce Wastes

at Your Shop (EPA305-K-96-002) lists

practical pollution prevention tips for

vehicle maintenance shops.