A
Guide
on
Hazardous
Waste
Management
for Florida’s
Auto Repair
Shops
3
Hazardous wastes spilled or dumped on the
ground or disposed in dumpsters may seep into the
groundwater and contaminate drinking water sup-
plies.
Hazardous wastes may run off into the nearest
body of water where they may poison or kill fish
and other wildlife.
Hazardous wastes pose a risk to you, your employ-
ees and your community.
State and county inspectors may visit your busi-
ness to ensure that hazardous wastes are being
managed properly. State penalties range from
$100 to $50,000 per violation per day.
Reducing hazardous wastes can reduce your pro-
duction and disposal costs and reduce your risk of
future liability.
Your customers will appreciate your efforts to pre-
vent pollution.
Your community will recognize your business as a
good neighbor.
Health and Environment
Cost Savings
Public Image
Why should I care about hazardous wastes?
As a business owner, operator or employee, you may be producing
materials that can harm people and the environment. This booklet offers
helpful tips on how to:
Comply with federal and state hazardous waste regulations.
Avoid penalties by properly managing hazardous wastes.
Save money on disposal costs by reducing hazardous wastes.
2
Florida Department of
Environmental Protection
Hazardous Waste Compliance
Assistance Program
With Support From:
David Struhs, FDEP Secretary
Alan Bedwell, FDEP Deputy Secretary
John Ruddell, FDEP Waste Division
Director
Bill Hinkley, FDEP Bureau Chief, Solid
and Hazardous Waste Section
U.S. Environmental Protection Agency,
Region IV
Prepared by:
Florida Department of Environmental
Protection, Hazardous Waste
Compliance Assistance Program
Satish Kastury, Administrator
Janet Ashwood, Compliance Assistance
Project Manager
Mike Redig, Tallahassee
Glen Perrigan, Tallahassee
Charlie Goddard, Northwest District
Bill Kellenberger, Northwest District
Ashwin Patel, Northeast District
Pamela Green, Northeast District
John White, Central District
Lu Burson, Central District
Beth Knauss, Southwest District
Jeff Smith, Southeast District
Charles Emery, South District
Karen Bayly, South District
This document was published to help educate businesses on hazardous waste management
issues affecting them. The suggested options may help businesses to operate in an envi-
ronmentally appropriate manner. Some of the options may go beyond what is required to
remain in compliance with regulations. Business owners are responsible for obtaining
complete information about applicable regulations. Misrepresentations or omissions by
the Florida Department of Environmental Protection or the Florida Center for Solid and
Hazardous Waste Management do not relieve any person from any requirement of feder-
al regulations or Florida law.
These regulations are available at many
public libraries. In addition, the Florida
Department of Environmental Protection
and the United States Environmental
Protection Agency have posted links to
copies of these regulations on the agen-
cies’ Internet sites:
These sites also provide links to agency
forms, fact sheets, checklists, rule sum-
maries, answers to frequently asked ques-
tions and reports from our public informa-
tion databases. Individuals who do not
have Internet access may obtain copies of
department publications through the con-
tact information listed on page 16 of this
document.
Revised 6/2002
http://www.dep.state.fl.us
http://www.epa.gov
Florida Center for Solid and Hazardous
Waste Management
www.floridacenter.org
John Schert, Executive Director
Julie Lyons, Project Coordinator
Jon Powell, Research Assistant
5
Listed Wastes
Some industrial processes and chemical wastes are listed specifically as
hazardous in the federal regulations under 40 CFR 261, Subpart D.
Copies of the rule can be found at many public libraries, on the Internet
or may be purchased from the Government Printing Office.
Acutely Hazardous Wastes
Small amounts of very dangerous wastes, such as arsenic and cyanide
compounds, are regulated in the same way as large amounts of other
wastes. A business that generates 2.2 pounds (1 kilogram) or more of
these acutely hazardous wastes per month is subject to full regulation
under the hazardous waste rules.
Identifying Your Hazardous Wastes
It is very important to determine whether a waste is hazardous or non-
hazardous. There are several ways to identify hazardous wastes.
Always ask for a Material Safety Data Sheet (MSDS) before
ordering any new product. The MSDS will give you valuable
information about the product.
Talk to product suppliers and manufacturers.
Read product labels.
Compare product and process information to hazardous waste
characteristics and to wastes listed in federal regulations.
If product or process
information is not available
or is inconclusive, have a
commercial lab sample
and test the waste
using the TCLP test
or other appropri-
ate analytical
tests.
A non-hazardous mate-
rial or product may
become a hazardous
waste due to contami-
nants added during
use. Lab testing
may be necessary.
4
What is a hazardous waste?
Awaste is hazardous if:
It is listed as a hazardous waste in the Title 40 Code of Federal
Regulations (CFR) Part 261, Subpart D.
It has any of the characteristics described below:
Characteristic Wastes
Ignitable
Corrosive
Reactive
Toxic
Ignitable wastes are flammable or spontaneously
combustible. If they have a flashpoint of less than
140 degrees Fahrenheit or an alcohol content of
24% or more, they are hazardous wastes.
Examples include some paints, paint solvents,
other solvents and degreasers.
Corrosive wastes can burn the skin or corrode
metals. Liquids with a pH of 2 or lower or 12.5 or
higher are corrosive. Examples include rust
removers, acidic or alkaline fluids and battery
acid.
Reactive wastes are unstable and may explode or
react violently with water or other materials.
Examples include explosives such as detonators
for air bags, cyanides and reactive peroxides
including some catalysts.
Wastes are toxic if they contain certain heavy
metals above specific concentrations, such as
chromium, lead or cadmium, or toxic organic
chemicals. Examples include some parts cleaners,
mercury switches, chromium-bearing paints and
spray booth filters.
7
Who needs to know if my business generates
hazardous waste?
Develop a contingency plan
Guidance on contingency plans is available from FDEP.
Large quantity generators must have a written plan that
includes:
* Emergency response arrangements with police, fire,
hospitals and emergency response contractors.
* Emergency coordinator’s address and phone number.
* On-site emergency equipment descriptions and locations.
* Evacuation plan and routes, including a site diagram.
* Spill reporting procedures.
Post Emergency Information
Post the following information near
every telephone:
* Fire department phone number.
* Emergency coordinator’s name and
phone number.
* Locations of fire alarms and
extinguishers.
* Locations of spill control materials.
Notify FDEP
If your business is a
small or large quantity
generator, notify FDEP
to obtain an EPA identi-
fication number. Local
environmental agencies
also should be notified.
Designate
an emergency
coordinator
This person must know
what to do in case of
fire, spill or other emer-
gency and must be on
the premises or on call
24 hours a day.
Notify local
authorities
Police and fire depart-
ments and local hospi-
tals that would respond
to an emergency need to
know that there are haz-
ardous wastes on your
property.
6
Used Oil
Lead acid batteries that are not recycled or are managed in a manner to
allow a discharge are possible hazardous wastes.
Engine coolant that is not recycled must be tested prior to disposal. It often
is a hazardous waste because of lead or solvent content. It may not be dis-
charged directly to the environment.
Spent parts cleaners and washers are considered hazardous wastes because
they have a low flashpoint (less than 140
degrees Fahrenheit) or may be
toxic. Common solvents include mineral spirits, MEK, 1,1,1-
trichloroethane and toluene. Solvents become hazardous wastes because
they are contaminated with heavy metals such as lead, cadmium, chromi-
um or barium. Do not mix spent solvents with used oil. Mixing a hazardous
cleaner with another substance may make the mixture hazardous.
Rags contaminated with used oil or solvents may be a hazardous waste. If
your shop washes rags, water must be discharged to a publicly-owned
sanitary sewer, not a storm sewer, septic tank or cesspool. If you use a
towel service, make sure the company discharges its water to a publicly-
owned sewer system.
Used oil that is not recycled or is rendered unrecyclable may be regulated
as a hazardous waste. If oil is spilled on the ground and not cleaned up
immediately, the oil and soil possibly are hazardous and may cause a
groundwater contamination problem.
Engine Coolant
Lead Acid Batteries
Sources of Hazardous Waste
Mercury-Containing Devices
Parts Cleaners and Parts Washers
Shop Rags
Mercury-containing devices may not be incinerated or landfilled in any
quantity, not even one. They either must be recycled or handled as
hazardous waste. Recycling is easier and costs less. The department rec-
ommends recycling of all mercury-containing devices. Examples of these
devices include fluorescent and high-density discharge lamps, thermostats,
and trunk and hood light switches.
9
Labels
Transport and Disposal
HAZARDOUS WASTE
Federal Law Prohibits Improper Disposal
If found, please contact the nearest police, public
safety authority or the U.S. EPA
(Your business name, address and manifest
document number)
Make sure your transporter and disposal facility have EPA
identification numbers.
Use manifests for all hazardous wastes shipped off-site. Keep the
manifests on-site.
Inspections and Recordkeeping
Inspect containers at least once a week and keep a written log of
container inspections.
Keep a record of larger spills and use this information to identify
the spill prevention options that might help your shop.
Keep training and inspection records for three years.
Keep manifests and shipping receipts for three years.
Keep records of tests for three years.
Keep land disposal restriction forms for three years from the date
the waste was last shipped.
The above label represents proper wording for a hazardous waste
label. You must also comply with DOT.
Label every container with the type of waste and whether it is
hazardous or non-hazardous or used oil.
Include the accumulation start date (the date when waste
was first placed in the drum).
Training
Train all employees to identify, reduce and properly handle
wastes.
Train new employees before they handle hazardous wastes.
8
How should I manage hazardous wastes?
First, determine how much hazardous waste you generate each month.
The rules you must follow depend on how much you generate, how much
you store and how long you store it.
Less than 220 pounds (100 kilograms or about
half a drum): you are a “Conditionally Exempt Small
Quantity Generator.”
220 - 2,200 pounds (100-1,000 kilograms or
about half a drum to 5 drums): you are a “Small
Quantity Generator.”
More than 2,200 pounds (1,000 kilograms or
more than about 5 drums): you are a “Large Quantity
Generator.”
The following practices may be required for your business. Even if they
are not required, they are good waste management practices. Additional
information is available from FDEP.
Containers
Maintain containers in good condition. Prevent leaks, ruptures and
accumulation of rainwater on tops of drums.
If a container leaks, transfer waste to a new container.
Keep containers closed. Use self-closing funnels when adding
waste. Do not allow wastes to evaporate.
Wastes must be compatible with the container. For example, use
HDPE plastic containers for corrosive wastes.
Never place incompatible wastes such as wastes that react with
each other (e.g., acids and bases) in the same container.
Storage
Maintain adequate aisle space between container rows to allow
inspection for leaks and damages.
Store ignitable and reactive wastes at least 50 feet from
property boundaries.
Store containers with incompatible wastes in separate areas.
Time limit for SQGs is 180 days. It is 90 days for LQGs.
Minimize inventory and use a “first-in, first-out” system to prevent
the need for disposal of unused materials.
Do not discharge shop wastes to the ground surface or to septic
tanks. Plug floor drains.
Manage wastes in an appropriate manner to prevent discharges to
the environment. Keep containment structure valves closed.
Keep soiled shop towels in a clearly labeled, closed container.
Store partially used absorbents in closed, labeled containers for
reuse.
Use drip pans under leaking cars, machinery and pipes or under
removed parts rather than cleaning them up with absorbents.
The liquids could be reused or recycled if separate drip pans
are used.
Pre-clean parts with a squeegee, rag or wire brush. This approach
helps minimize or possibly eliminate the use of hazardous sol-
vents and prolongs the life of cleaning solutions.
11
Shop Practices
Contract with approved recycling services for used antifreeze,
lead-acid batteries, used oil and oil filters.
Use separate receptacles for draining used oil and antifreeze.
Educate customers about recommended maintenance schedules
and replacing fluids only when necessary.
10
How can I reduce hazardous wastes?
Reducing hazardous wastes makes good business sense. Benefits
include:
Saving money on waste management costs.
Reducing concerns about penalties and liability.
Creating a safer, healthier workplace.
Promoting positive public relations with clients, customers and
the local community.
How do I begin?
The shop owner or manager must be committed to waste mini-
mization and pass that commitment on to the employees.
Evaluate your shop’s wastes and identify areas where changes
can be made.
Involve employees in designing and implementing pollution
prevention measures.
Solvents
Reduce or eliminate solvent use by determining whether cleaning
is really necessary.
Use a multi-purpose solvent to reduce the types of hazardous
waste that need to be managed.
Substitute detergent-based solution for caustic solution when
cleaning; substitute water-based cleaners for solvent cleaners.
Consider switching to a water-based cleaner instead of using
chlorinated spray cans of brake cleaner or carburetor cleaner.
Use solvent sinks properly: use drip trays, allow more drainage
time, use filters to prolong solvent life and keep lids closed
when not in use.
Replace solvent only when necessary.
Use dedicated equipment to minimize cross-contamination.
Automotive Fluids
Keep used oil and other vehicle fluids segregated from solvent
wastes and carburetor cleaner.
Store large quantities of batteries in an isolated area with no
floor drains. Storage areas should be sealed with an
acid-resistant material.
Label waste containers clearly to prevent contamination of non-
hazardous wastes.
13
DO DON’T
Keep containers closed Leave containers open
DO
Keep accurate inspection logs
DO DON’T
Label all containers Leave containers
unlabeled
Dos and Don’ts
12
Identify and record quantities of hazardous waste
monthly.
Obtain an EPA identification number, if needed.
Use proper containers to collect and store wastes or
products.
Label all containers whether product or waste as to
their contents.
Keep all hazardous waste or products containing
regulated solvents closed at all times unless actively
removing from or adding to it.
Inspect all regulated management areas.
Designate an emergency coordinator.
Post emergency information near each phone.
Develop a contingency plan for emergencies.
Use manifests for all waste transported for disposal.
Keep all records for at least three years.
Checklist
This checklist will help you prevent the most common hazardous waste
violations. For more detailed information on hazardous waste manage-
ment requirements, contact FDEP.
15
Waste
Water
The most common violation is the non-determination of
whether or not something is a waste.
Abandoned products are a waste.
If you throw away containers, make sure the container is com-
pletely empty before you place it in a waste receptacle. If
you throw away aerosol cans, make sure the can has a hole
in it, and that you have drained the liquids out of the can.
If you are throwing away paint containers, be sure to drain
all the paint out of the container.
If you discharge any waste that could be construed as a haz-
ardous waste into a city sewer, you must have the written
permission of the city sewer system. The city sewer sys-
tem must be a Publicly Owned Treatment Works (POTW).
It cannot be a privately owned package plant.
If you use rags, you should send the rags to a linen service
that is served by a publicly owned sewage treatment plant.
If you use paper towels, you must make a determination as
to whether the used paper towels are a hazardous waste.
Know where your drains go. All drains that lead from a haz-
ardous materials area to a stormwater area should be
sealed shut
14
Drums
Spills
Oil
Tips from Inspectors
You cannot use used motor oil for weed control. Used oil con-
tainers must not leak and be in good shape. You must
retain your used oil filter records for three years. The
inspectors spend a lot of time on used oil inspections.
You must clean up your spills at the time of the spill.
Be sure to store old automotive batteries on a floor that is
under a roof. Do not stack batteries. If they fall over, they
will leak acid and create a spill problem.
You cannot have any mystery drums. All drums must be
labeled and have a “birthdate” on them.
Evaporation of hazardous waste is a serious violation. Do not
allow the hazardous wastes to evaporate. You must keep
the drum closed when you are not in the process of putting
waste into the drum. You also are required to keep the top
of the drum clean.
Do not store old drums outside. If they get stormwater inside
them, you will have to sample the stormwater and deter-
mine whether or not the water in the drum is hazardous.
Insist that the person who sold you the drum and its con-
tents takes the drum back when you are done with it.
Inspectors go into dumpsters and walk the entire property line
of a business. They go back into trees looking for orphan
drums and distressed/dead vegetation.
Transport
The only generators who are allowed to transport their own
waste are conditionally exempt small quantity generators.
All other generators must use a hazardous waste hauler
who has a permit from the FDEP and the US EPA.
17
16
Your Trade Associations
Many trade associations have published guides to help you find solutions
to your hazardous waste management problems.
Available publications include:
Summary of Hazardous Waste Regulations
Requirements for Conditionally Exempt Small Quantity Generators
Requirements for Small Quantity Generators
Handbook for Small Quantity Generators of Hazardous Waste
Additional information on hazardous waste reduction and regulations is
available from many sources.
Florida Department of Environmental Protection
The Small Business Assist-ance Program helps businesses with environ-
mental concerns and problems related to compliance with air regulations.
Assistance is confidential and staff experts have business experience.
Phone: (800) 722-7457
U.S. Environmental Protection Agency
The EPA has published a series of industry-specific guidelines and hand-
books on preventing pollution and complying with hazardous waste reg-
ulations.
RCRA Hotline: (800) 424-9346
Where can I get more information?
Florida Small Business Assistance Program
District offices and the Tallahassee office offer technical assistance, fact
sheets and other publications on hazardous waste regulations.
Hazardous Waste Compliance Assistance Program
Phone: (800) 741-4DEP
(850) 245-8707
Fax: (850) 245-8810
Information about the Universal Waste rule can be found at:
http://www.dep.state.fl.us/waste/categories/mercury/pages/laws.htm
or by calling (800) 741-4DEP
1918
Offices of the Florida Department of
Environmental Protection
Hazardous Waste Regulation Section
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(800) 741-4DEP
Northwest District
160 Government Center
Pensacola, FL 32501
(850) 595-8300
Northeast District
7825 Baymeadows Way, Suite 200B
Jacksonville, FL 32256
(904) 807-3300
Central District
3319 Maguire Blvd.
Orlando, FL 32803
(407) 894-7555
South District
P.O. Box 2549
2295 Victoria Ave., Suite 364
Fort Myers, FL 33902-2549
(239) 332-6975
Escam
bia
Santa
Rosa
Oka-
loosa
Walton
Holmes
Wash-
ington
Jackson
Bay
Gulf
Cal-
houn
Franklin
Liberty
Gadsden
Leon
Wakulla
Jeffer-
son
Taylor
Madison
Hamilton
Lafay-
ette
Dixie
Levy
Gil-
christ
Union
Brad-
ford
Alachua
C
o
lu
m
b
ia
Baker
Nassau
Duval
Clay
Putnam
S
t. J
o
h
n
s
Flagler
Suwan-
nee
Southwest District
3804 Coconut Palm Dr.
Tampa, FL 33619
(813) 744-6100
Citrus
Hern-
ando
Pasco
Hills-
borough
Pinellas
S
u
m
te
r
Polk
Manatee
Hardee
De Soto
Sara-
sota
Marion
Lake
Volusia
Semi-
nole
Orange
Osceola
B
re
v
a
rd
Indian
River
Marion
Jeffer-
son
Area
shown
High-
lands
St.
Lucie
Martin
Palm
Beach
Broward
Hendry
Glades
Char-
lotte
Lee
Collier
Dade
Mon-
roe
Okee-
chobee
Southeast District
400 N. Congress Ave.
West Palm Beach, FL 33401
(561) 681-6600
Levy
This project and the preparation of this brochure was funded in
part by a Section 3011 Hazardous Waste Management State
Program grant from the U.S. Environmental Protection Agency
(US EPA) through a contract with the Hazardous Waste
Management Section of the Florida Department of Environmental
Protection. The total cost of the project was $60,000, of which
$45,000 or 75 percent was provided by the US EPA.
Nonprofit Org
U.S. POSTAGE
PAID
Gainesville, FL
Permit No. 94
University of Florida
Florida Center for Solid and
Hazardous Waste Management
2207-D N.W. 13th Street
Gainesville, FL 32609
(352) 392-6264
Fax: (352) 846-0183
For additional information contact:
Janet Ashwood
Florida Department of Environmental Protection
Hazardous Waste Compliance Assistance Program
Tallahassee, FL
Phone: (800) 741-4337
(850) 245-8707
