Getting Started

The step-by-step instructions in this fact sheet can help you reduce

waste, avoid regulatory problems, and save money! This fact sheet is

the first in the “Pollution Prevention Tool Kit,” a series of fact sheets

highlighting the Best Environmental Practices for auto repair shops

and fleet maintenance facilities. This fact sheet contains the following

information:

• Step-by-step instructions for reducing your waste generation

• Tables to help you assess your waste stream volumes and costs

before and after implementing the recommended practices

• References to other fact sheets in the series that contain detailed

information on recommended practices 

• Specific guidance on how common auto repair and fleet maintenance

shop wastes are regulated.

How to Minimize Your Waste Generation Now

Use the table on page 2 to inventory your current practices and waste

streams. Then refer to the recommended Best Environmental Practices

described in the fact sheets cited on page 3. Test and implement as

many recommended practices as possible, and then re-inventory your

waste streams on page 3. 

If you reduce your total monthly volume of 

hazardous waste to less than 100 kilograms or 

27 gallons, you will have significantly fewer hazardous waste regulations to comply with. 

Is your waste hazardous?

You are ultimately responsible for determining whether the wastes

generated in your shop are regulated as hazardous wastes. You can

apply your knowledge of shop operations and of the materials you

use to determine whether a waste is regulated as a hazardous waste.

If you suspect that a waste may be hazardous but are not sure, either

assume that it is hazardous and pay for proper waste disposal or

recycling, or have the waste tested to get a definitive determination. 

Local laboratories and hazardous waste disposal companies can

sample and test a waste for you using approved methods. The test

results will tell you whether the waste is hazardous or not. If it is not

hazardous, and if both the chemicals and process you use to generate

that waste do not change, you can rely on the test results for that

one sample as proof that the waste is not hazardous in the future.

That is, the waste generated by the process in the future will be

assumed to have characteristics similar to the current waste. Make

sure to keep a copy of each test result in your files in case a hazardous waste inspector ever questions your waste determination. 

Your air emissions and sanitary sewer discharges are regulated by

your local air district and sewer agency, respectively. You should consult them about air and sewer discharge requirements. 

PROFIT THROUGH PREVENTION

Reducing your Waste = Fewer Hazardous Waste Regulations 

Large Quantity Small Quantity Generates Less Than

Generator (LQG) Generator (SQG) 100 Kilograms Hazardous Waste

>1,000 kgs or 275 gallons 100 to 999 kgs or less than 100 kgs or

or more per month 27 to 275 gallons per month* 27 gallons per month

5 drums or more per mo. 1/2 drum to 5 drums Less than 1/2 drum

At least 78 regulations At least 67 regulations

*no more than 6,000 kilograms onsite at any one time. 

^In California, if you are a small or large quantity generator, there are basic hazardous waste management

requirements that you must meet. See back page for details,

–––> –––>

PROFIT THROUGH PREVENTION

Best Environmental Practices for Auto Repair and Fleet Maintenance

Oil

Only

Remember that a hazardous waste may never be

discharged into a sanitary sewer, storm drain,

ditch, dry well, or septic system!

November 2001
BEST ENVIRONMENTAL PRACTICES FOR AUTO REPAIR AND FLEET MAINTENANCE

Waste Stream Regulatory Guidance for “Traditional” Practices

A Waste solvents and solvent sludges are generally hazardous unless testing demonstrates otherwise.

B Waste antifreeze may be hazardous depending on its metal concentration. In a 1999 federal survey of sampling studies, about half the waste

antifreeze samples proved to be hazardous wastes. If waste antifreeze is hazardous, you may not discharge it into a sanitary sewer, storm

drain, ditch, dry well, or septic system. Test your waste antifreeze or count it as a hazardous waste.

C Used aerosol cans should be disposed of in trash or recycled as scrap metal if they are completely empty. Dispose of used aerosol cans as

hazardous waste if they are not empty and their contents are hazardous. Do not count empties as hazardous waste.

D Spent brake washing solvent is very likely to be a hazardous waste. 

E Used rags and paper towels are very likely to be a hazardous waste if they are contaminated with gasoline or solvent. If the solvent product

used contained an F-listed chemical at a 10 % or greater concentration, the contaminated rags or towels will be a hazardous waste 

(see “What is an F-listed Chemical” on page 4). If solvent on rags or towels is not an F-listed chemical, use your knowledge or test the rags 

or towels to determine whether they are hazardous. If they are hazardous, it is illegal to dispose of them in trash. Have used rags laundered

(recycled) by an industrial laundry, or dispose of them as a hazardous waste. 

F California regulates oily wastes and may count oil-soaked absorbents as hazardous waste, unless recycled in accordance with state law.

G Sludges from traps and oil/water separators may contain heavy metals or solvents. Test sludges yearly to determine whether they

contain heavy metals or solvents. 

H Wash water or mop water is generally not counted as a hazardous waste. However, if wash or mop water was used for cleaning spill contaminated floors it may be hazardous waste, and may not be placed in a sanitary sewer. For example, washing gasoline into the drain would be

illegal disposal of a hazardous waste (waste gasoline is hazardous because of its ignitability and benzene content). Even if it is not hazardous

waste, wash or mop water must meet sewer discharge requirements limiting its oil and grease content, etc. Check with your sewering agency

for requirements

STEP 1: Calculate your current generator status

Complete the worksheet below to identify and quantify hazardous wastes now leaving your shop.

Process Traditional Practice Waste Stream Is Waste Amount per Month

Hazardous? Quantity of Disposal

(use notes below) Hazardous Waste Cost

Parts Washing Solvent Service Waste Solvent A

Coolant Changing Off-site Recycling or Disposal Waste Antifreeze B

Brake Washing Aerosol Spray Cans Waste Cans C

Solvent Service Waste Solvent D 

Lubricating and Aerosol Spray Cans Waste Cans C

Spot Cleaning Used Rags or Paper Towels E

Floor Cleaning Disposable Rags or Used Rags or Paper Towels E

Paper Towels

Dry Absorbents Used Absorbent F

Hosing With Water H Trap or Separator Sludges G

Cleaning Service Wash or Mop Water H

Other Processes Used oil, oil filters, lead acid

(California Wastes) batteries, etc.

Determine your generator status by adding up the quantity of all hazardous wastes 

(Multiply gallons by 8 to convert to pounds) 

Determine your monthly waste management costs for all waste streams
BEST ENVIRONMENTAL PRACTICES FOR AUTO REPAIR AND FLEET MAINTENANCE

Waste Stream Regulatory Guidance for Best Practices

I

Waste metal filters should be recycled with oil filters as a “hazardous waste-exempt scrap metal waste”; other waste filters should be disposed

of as a hazardous waste or tested. In one study, one out of two filters tested positive as a hazardous waste because of the presence of lead.

J

Waste aqueous solution should be shipped off site as a hazardous waste or tested. In two studies, 75 percent of waste aqueous solutions

tested positive as hazardous wastes because of their lead and cadmium concentrations. Microbial solutions may last for years. Extend 

solution life by pre-cleaning parts with a rag, filtering, and removing oil. 

K Antifreeze recycling sludges or resins should be shipped off site as a hazardous waste or tested. In a 1999 federal survey of sampling studies,

about half the waste antifreeze samples proved to be hazardous wastes due to metals content. Antifreeze recycling sludges and resins are

likely to contain even higher concentrations of metals than waste antifreeze. 

L Antifreeze recycling filters made of metal should be recycled with oil filters as a “hazardous waste-exempt scrap metal waste”; for nonmetal

filters, make your own determination based on your process knowledge or testing. 

M Mop water should be nonhazardous and can be disposed of in a sanitary sewer, provided that all floor spills are first cleaned up using dry

cleanup methods. If the floor drain is capped, pour the mop water into a work sink (local sewer agency approval is required). Mop water and

other waste material should never be discharged to a storm drain, ditch, dry well, or septic system.

N Used absorbent should be used only to clean up gasoline or solvent spills; in emergency situations; or for cleanup of old, pitted shop floors.

Test the used absorbent or use your knowledge of what was spilled to determine whether the used absorbent is hazardous. Absorbent saturated with gasoline or solvents will very likely be a hazardous waste. 

STEP 2: Implement as many best practices as you can 

The enclosed fact sheets provide many suggestion on how to implement them.

STEP 3: Calculate your new generator status

After implementing as many Best Practices as possible, recalculate your waste volumes and costs.

Process Best Practice Waste Stream Is Waste Amount per Month

Hazardous? Quantity of Disposal

(use notes below) Hazardous Waste Cost

Parts Washing Aqueous Spray Cabinet, Waste Filters I

Ultrasonic unit, 

Microbial Sink-top, Waste Aqueous Solution J

or Immersion unit

Coolant Changing On-site or Off-site Recycling Sludges or Resins k

Waste Filters L

Brake Washing Aqueous Brake Washing Waste Solution J

Lubricating and Refillable Spray Bottles Used Rags or 

Spot Cleaning Paper Towels E

Floor Cleaning Spill Prevention and Used Rags or 

Dry Cleanup Methods Paper Towels E

Mop Water M

Used Absorbent N

Other Processes Used oil. oil filters, lead-acid

(California Wastes) batteries, etc.

Determine your new generator status by adding the monthly quantities of all hazardous wastes. 

(Multiply gallons by 8 to convert to pounds) Compare the total quantity to the Step 1 total.

Estimate your new monthly waste disposal costs for all waste streams. Compare the total cost to Step 1 total.
BEST ENVIRONMENTAL PRACTICES FOR AUTO REPAIR AND FLEET MAINTENANCE

What Being a Generator of Less than 100 Kilograms Means to Your Shop

If you generate less than 100 kilograms per month of hazardous wastes or less than one kilogram of extremely hazardous waste, you have significantly fewer hazardous waste requirements to comply with and many more waste management options. In addition to local air pollution regulations and wastewater discharge rules, you must comply with the following basic hazardous waste management requirements:

1) Identify all hazardous waste you generate;

2) Do not store more or accumulate hazardous waste onsite exceeding the regulatory time frame that applies to you.

3) Legitimately use, reuse, or recycle your waste on site, or ensure 

delivery of your hazardous waste to one of the following:

- A state or federally regulated hazardous waste treatment, 

storage, or disposal facility (TSDF)

- A local government collection center that is authorized to accept 

hazardous waste from small businesses, if available.

4) Obtain a California ID or EPA ID number.

5) Comply with preparedness and prevention, contingency plan and

emergency procedures requirements.

6) Comply with container and tank system management standards.

7) Comply with recordkeeping requirements.

If you have questions about your generator requirements, contact your local CUPA representative or the DTSC Duty Officer at 800-728-6942 or

via DTSC website at http://www.dtsc.ca.gov

What is an F-Listed Chemical?

An F-Listed chemical is a chemical that makes each waste it contaminates

a hazardous waste no matter what its concentration in the waste is.

Even one drop of an F-listed chemical on a shop rag, in absorbent, or in

used oil or antifreeze is enough to make a regulated hazardous waste.

Find out which products in your shop contain F-listed chemicals, and be

very careful not to contaminate your wastes with them. Check the

Material Safety Data Sheet (MSDS) for each product you use. If the

product is an aerosol or liquid solvent (parts cleaner, brake cleaner, etc.)

and has any of the following chemicals in it at a concentration of 10 percent or more, all waste streams contaminated by the product must be

properly managed as hazardous wastes: acetone; methanol; 1,1,1-

trichloroethane; methyl ethyl ketone; methyl isobutyl ketone; xylenes;

benzene; ethyl benzene; toluene; perchloroethylene; trichloroethylene;

and dichloromethane (methylene chloride).

“The Pollution Prevention Tool Kit is a great resource for our industry. Repair shops can realize significant compliance benefits and cost savings by following the sound recommendations provided.”

—Larry Moore, Past President, Automotive Service Councils of California

Mention of trade names, products, or services does not convey, and should not be interpreted as conveying, U.S. EPA, California Department of Toxic Substances Control

(DTSC) or any local government approval, endorsement, or recommendation. 

*Second reprint by DTSC, November 2001.

Your state or local government environmental agencies have additional information about compliance and pollution prevention opportunities for auto

repair shops and fleet maintenance operations in your state or area. For information on California regulatory compliance issues contact your nearest

Department of Toxic Substances Control (DTSC) Regional Office by calling 1-800-728-6942. You may also access the CAL EPA website at

www.calepa.ca.gov for links to California Regulatory Agencies. To obtain additional copies “The Pollution Prevention Tool Kit, Best Environmental

Practices for Auto Repair” (Document number 626) or “The Pollution Prevention Tool Kit, Best Environmental Practices for Fleet Maintenance” (Document

625) contact “DTSC’s Office of Pollution Prevention and Technology Development (OPPTD)” at 1-800-700-5854. Accompanying videos, “Profit Through

Prevention”are available at the same phone number for either auto repair (Document number 1504) or fleet maintenance (Document number 1504). DTSC’s

OPPTD also provides technical assistance and pollution prevention resources to businesses and government agencies. Electronic versions of the fact

sheets can be found at: www.dtsc.ca.gov/PollutionPrevention/Vehicle_Service_Repair.html