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Antifreezeantifreeze

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This section covers environmental regulatory aspects of dealing with used antifreeze. The focus is on federal and state regulations, disposal options and best practices, including recycling.

There are two types of antifreeze commonly in use today-ethylene glycol and propylene glycol. The most common is ethylene glycol antifreeze, which is odorless, sweet tasting (but toxic), and usually greenish-yellow in color. Propylene glycol antifreeze, usually pink, is less toxic than ethylene glycol. Extended life antifreeze, usually orange, contains additional additives and is available in both ethylene and propylene bases. (The glycols themselves are colorless - manufacturers add colorants to help identify the type of glycol used in the product.)

 


Who is covered by the regulations?

U.S. EPA and all states have environmental regulations that affect the management and disposal of used antifreeze. Any business that generates used antifreeze is subject to these rules.

What is the purpose of the regulations?

Ethylene glycol is toxic to people and animals. Especially because of its sweet taste, waste antifreeze that is improperly stored or disposed of can poison animals or children. In addition, waste antifreeze can cause microscopic organisms to grow out of control and consume the oxygen normally available to higher organisms, causing significant impacts on wastewater treatment systems, groundwater, drinking water supplies, and lakes and streams.

In addition, waste antifreeze can pick up heavy metals such as lead from the solder used in radiator systems, and other sources. Lead contamination can reach high enough levels to cause the waste antifreeze to be classified as a hazardous waste.

To prevent these potential consequences, EPA and all states regulate antifreeze disposal, either under regulations that apply specifically to waste antifreeze, or under their general wastewater and solid/hazardous waste regulations.

Regulations

The most applicable regulation affecting used antifreeze is the Resource Conservation and Recovery Act (RCRA). EPA has delegated RCRA hazardous waste authority to the states, except for Alaska and Iowa. Therefore, unless your facility is in one these two states, your focus will be on your state regulations rather than those of the U.S. EPA. Note that facilities located on Indian lands may be under federal jurisdiction.

EPA encourages the concept of antifreeze recycling because of its environmental benefits (see Antifreeze Recycling). However, there are no special federal regulations that pertain to waste antifreeze to help promote widespread recycling (EPA estimates that only 12% of antifreeze is recycled). As with most other non-exempt wastes generated by businesses, under federal RCRA rules, the generator must make a hazardous waste determination and if the waste is hazardous, it must be managed and treated/disposed of as a hazardous waste (see Hazardous Waste Determination and Managing Hazardous Waste). Waste antifreeze that is determined to be non-hazardous can be recycled off-site or on-site. Waste antifreeze that has been classified as hazardous can still be recycled. However, in that case, hazardous waste rules apply to transportation and to treatment and recovery processes (which increases the compliance burden and adds significant cost to the management of the waste antifreeze). Most states follow this federal course and do not have special provisions for antifreeze. However, some states have enacted regulations and/or policies that remove these barriers to used antifreeze recycling. These are discussed below.

A major hurdle to increased recycling of used antifreeze is its potential to be hazardous due to the presence of lead and other toxic metals. These metals may be leached into the antifreeze from the radiator systems of vehicles during normal use. (The Kansas Department of Health and Environment reported in 1997 that 40% of the used antifreeze samples they tested failed the toxicity test.) Several sources report that newer radiators are less likely to leach these toxic metals; however the risk remains (e.g., Kansas Department of Health and Environment). Testing each volume of used antifreeze to make a hazardous waste determination would be too costly and relying on "knowledge" of the waste could be inaccurate. To work around this difficulty, some states have excluded used antifreeze from its normal hazardous waste burden when it is properly managed and recycled. Four states (LA, MI, NH and WI) regulate used antifreeze as a Universal Waste when it is properly managed and recycled. A number of other states similarly exclude used antifreeze from hazardous wastes rules when it is properly managed and recycled (AR, FL, GA, KS, MN, NV, OR, VT, and WA). The details of the rules vary from state to state (see below), so check with your state to be certain you are in compliance.

For all states, a hazardous waste determination must be made on all residual wastes produced by the antifreeze recycling process, such as filters and sludge, and these wastes managed appropriately. Such wastes typically contain concentrated heavy metals and other contaminants removed from the antifreeze.

The following states have posted regulatory, policy or guidance information on their websites concerning used antifreeze. Please email us if you are aware of applicable information for your state not listed here and we will update the list accordingly.

AL

AK

AZ

AR

CA

CO

CT

DE

FL

GA

HI

ID

IL

IN

IA

KS

KY

LA

ME

MD

MA

MI

MS

MO

MN

MT

NE

NV

NH

NJ

NM

NY

NC

ND

OH

OK

OR

PA

RI

SC

SD

TN

TX

UT

VT

VA

WA

WV

WI

WY

Alabama: No specific information found concerning regulation of used antifreeze.

Alaska: No specific information found concerning regulation of used antifreeze. Alaska has not been delegated RCRA hazardous waste authority and therefore, EPA rules apply. There are no special federal regulations that pertain to waste antifreeze to help promote widespread recycling.

Arizona: No specific information found concerning regulation of used antifreeze.

Arkansas: Antifreeze is exempt from hazardous waste regulations if it is recycled.

California: The California Department of Toxic Substances Control (DTSC) considers ethylene glycol itself, at a concentration of greater than 33 percent by weight, to be capable of causing spent antifreeze to exhibit a State characteristic of hazardous waste. Also, DTSC considers not only lead, but copper and zinc, at sufficient concentrations to be capable of causing spent antifreeze to exhibit a State characteristic of hazardous waste. However, since PE's treated antifreeze apparently contains ethylene glycol at a concentration of 37 percent by weight, the treated antifreeze would generally exhibit a State characteristic of hazardous waste.

Colorado: All wastes, including used antifreeze, must be evaluated to determine if they are hazardous wastes. Used antifreeze that contains listed hazardous wastes or exhibits a characteristic of hazardous waste must be managed following all hazardous waste notification, generator, and transportation requirements.

Connecticut: A hazardous waste determination must be conducted in order to determine whether your used antifreeze is hazardous or non-hazardous waste. If the antifreeze has been determined to be non-hazardous, it is considered a Connecticut regulated waste and must be either recycled or disposed of via a permitted waste hauler. There are no specific storage requirements for non-hazardous used antifreeze. Antifreeze which has been determined to be hazardous waste, must either be recycled or disposed of via a permitted hazardous waste hauler. While stored on-site, it must be managed in accordance with hazardous waste storage requirements. See Appendix A for more information. If you recycle hazardous antifreeze on-site, you must file a DEP Recycling Registration with the CT-DEP at least 30 days prior to recycling.

Delaware: No clear policy on recycling of used antifreeze. Presumably, it must be managed as a potential hazardous waste.

Florida: In order to promote the collection and recycling of used antifreeze by generators and handlers, the Florida Department of Environmental Protection has developed Best Management Practices (BMPs) for antifreeze that is destined for recycling. Used antifreeze may be recycled on-site or off-site using the BMPs. Used antifreeze generated from vehicle repair facilities is exempt from hazardous waste regulation if it is recycled according to the BMPs. If you don't recycle antifreeze, a hazardous waste determination must be made.

Georgia: Hazardous waste testing of used antifreeze is only required if the waste antifreeze is not destined for recycling.

Hawaii: No specific information found concerning regulation of used antifreeze.

Idaho: No specific information found concerning regulation of used antifreeze.

Illinois: No specific information found concerning regulation of used antifreeze.

Indiana: Each generator is responsible for making a hazardous waste determination and can make the determination based on either test results or knowledge of the waste and how it was generated and managed. Used antifreeze can be recycled by various methods and returned to use as an antifreeze. If this option is selected, and the antifreeze is being managed as a hazardous waste, the actual recycling process is exempt from regulation under the Hazardous Waste Rules; however, management of hazardous waste antifreeze before recycling, and the residue after recycling, is subject to the hazardous waste rules.

Iowa: No specific information found concerning regulation of used antifreeze. Iowa has not been delegated RCRA hazardous waste authority and therefore, EPA rules apply. There are no special federal regulations that pertain to waste antifreeze to help promote widespread recycling.

Kansas: Generators of used antifreeze who intend to recycle this material either on-site or through a legitimate commercial recycling service, do not need to conduct hazardous waste testing (i.e., TCLP analyses). Kansas Department of Health and Environment (KDHE) does not view antifreeze destined for recycling as a potential hazardous waste and the used antifreeze can be transported under a bill of lading or contractual arrangement rather than under a hazardous waste manifest.

Kentucky: No clear policy on recycling of used antifreeze. Presumably, it must be managed as a potential hazardous waste.

Louisiana: Used antifreeze can be managed as a universal waste if recycled.

Maine: No specific information found concerning regulation of used antifreeze.

Maryland: No specific information found concerning regulation of used antifreeze.

Massachusetts: No clear policy on recycling of used antifreeze. Presumably, it must be managed as a potential hazardous waste.

Michigan: Used antifreeze can be managed as a universal waste if recycled.

Minnesota: Used antifreeze destined for recycling does not have to be evaluated and shown to be nonhazardous.

Mississippi: No specific information found concerning regulation of used antifreeze.

Missouri: Radiator repair shops managing waste antifreeze primarily used in heavy equipment or industrial sources may find toxic levels of lead in their waste antifreeze. This antifreeze must be characterized. If the antifreeze is found to contain lead or other hazardous constituents above regulated levels, it is hazardous waste and is subject to hazardous waste management requirements for on-site handling, transportation and disposal.

Montana: No clear policy on recycling of used antifreeze. Presumably, it must be managed as a potential hazardous waste.

Nebraska: A hazardous waste determination must be performed. On-site recycling of hazardous antifreeze is allowed by Title 128. Small and large quantity generators (SQG & LQGs) can have their hazardous waste recycled off site but the spent antifreeze, if hazardous waste, is subject to full SQG or LQG regulation.

Nevada: Under the authority of Nevada Revised Statutes (NRS) 459.485, used antifreeze is regulated a nonhazardous waste IF it is being recycled. The actual recycling can be performed at the businesses where the antifreeze is generated or at a permitted antifreeze recycling facility. If the used antifreeze is not being recycled, a Nevada business is responsible for making the waste determination on the used antifreeze and disposing of it according to the waste determination results.

New Hampshire: Used antifreeze can be managed as a universal waste if recycled. On-site recycling at a generator's facility is not subject to permitting requirements. Generators may purchase an antifreeze distillation or filtration unit and recycle their own antifreeze on-site, hire a contractor to come in with a mobile recycling unit, or ship the antifreeze to a recycling facility.

New Jersey: No specific information found concerning regulation of used antifreeze.

New Mexico: No specific information found concerning regulation of used antifreeze.

New York: No specific information found concerning regulation of used antifreeze.

North Carolina: Antifreeze is regulated as hazardous waste if the results from the Toxic Characteristics Leaching Procedure (TCLP) indicate metal contents that meet or exceed RCRA thresholds.

North Dakota: No clear policy on recycling of used antifreeze. Presumably, it must be managed as a potential hazardous waste.

Ohio: The generator of the antifreeze must evaluate it to determine if it is hazardous. If it is a hazardous waste, you can still recycle it but there are restrictions on who can recycle it. The hazardous antifreeze can only be recycled, on-site, by the generator of the antifreeze or at a permitted hazardous waste facility. Recycling by the generator, on-site, includes the generator hiring a commercial antifreeze recycler to come to their site and recycle the antifreeze.

Oklahoma: No specific information found concerning regulation of used antifreeze.

Oregon: Generators do not need to perform a hazardous waste determination of antifreeze that is recycled. A hazardous waste determination must be made on any antifreeze waste which is not recyclable. Used antifreeze that is to be recycled does not count toward monthly hazardous waste generator totals. Commercial recycling facilities will not be required to conduct a hazardous waste determination on used antifreeze received provided the recycling facility manages and legitimately recycles the antifreeze in accordance with these best management practices and the operating permit.

Pennsylvania: No specific information found concerning regulation of used antifreeze.

Rhode Island: No clear policy on recycling of used antifreeze. Presumably, it must be managed as a potential hazardous waste.

South Carolina: Waste antifreeze is exempt from regulation as a hazardous waste provided that: it does not exceed any of the following concentrations of these primary contaminants of concern after laboratory testing: lead 5.0 mg/l, benzene: 0.5 mg/l. Antifreeze is not counted in waste total when reused or recycled on-site.

South Dakota: No specific information found concerning regulation of used antifreeze.

Tennessee: No clear policy on recycling of used antifreeze. Presumably, it must be managed as a potential hazardous waste.

Texas: Texas has no specific regulations on the management of used antifreeze. As with any solid waste, the generator of used antifreeze is responsible for determining, either by process knowledge or by analytical testing, whether the waste is hazardous. If the waste is hazardous, it must be managed according to the hazardous waste regulations.

Utah: The generator of used antifreeze is responsible for determining, either by process knowledge or by analytical testing, whether the waste is hazardous. If the waste is hazardous, it must be managed according to the hazardous waste regulations regardless of whether it is recycled or disposed of.

Vermont: Waste antifreeze managed in accordance with Section 7-203(m) is exempted from hazardous waste regulations.

Virginia: No specific information found concerning regulation of used antifreeze.

Washington: Ethylene glycol antifreeze has a special regulatory status in Washington State. If antifreeze is properly recycled, it is exempt from most dangerous-waste regulations and will not be counted toward generator status.

West Virginia: No specific information found concerning regulation of used antifreeze.

Wisconsin: Used antifreeze can be managed as a universal waste if recycled.

Wyoming: No specific information found concerning regulation of used antifreeze.

Compliance Options

In states where used antifreeze can be managed as a universal waste, or can be excluded from hazardous waste rules by proper recycling, this is easily the best compliance option. Check with your state regulatory agency for details, including possible container labeling, storage and recordkeeping/reporting requirements.

In states where a hazardous waste determination must be performed, businesses may be able to classify their used antifreeze as non-hazardous waste using their "knowledge" of the waste and possibly some limited testing. For example, if a truck fleet is made up of similar vehicles of similar age, and the same type of antifreeze is used in all the trucks, then the chemistry of the waste antifreeze generated by the fleet could be assumed to be consistent. In such cases, if testing of representative samples of used antifreeze shows that the waste is well below hazardous thresholds, then it could be concluded that all used antifreeze generated by this fleet is non-hazardous. Such a determination may not be allowed in all states, and in states that do permit it, the determination would have to be well documented (e.g., antifreeze MSDS, sampling procedures, test results, etc.) and any records would have to be maintained for at least three years. Any changes to the type of antifreeze used would create a need to redo the determination. Also, periodic testing may also have to be performed to show that the characteristics of the waste antifreeze have not changed. It is recommended that you check with your state agency before making this determination because they may have strict guidelines or written guidance for you to follow.

If a facility makes the hazardous/nonhazardous determination solely by testing, it must test each batch of antifreeze changed from each vehicle serviced.

Disposal of used antifreeze is another compliance option. Disposal may include incineration, landfilling or discharge to a city sewer. The rules vary by state and, in some cases, locality. For example, in some areas, small volumes of used antifreeze (e.g., less than 50 gal.) can be discharged to a Publically Owned Treatment Works (POTW) provided that it is pre-approved by the local authority. Check with your state and local authorities for disposal options.

Best Practices

Used antifreeze makes up a significant portion of many businesses' waste streams. A recycling program can significantly reduce costs associated with the handling, storage and disposal of used antifreeze. Recycling antifreeze can also reduce new material purchase costs. New technology allows antifreeze to be recycled on-site and reconditioned with additives at a cost that is significantly lower than the cost of purchasing new antifreeze.

The following BMPs are recommended for reducing the volume, toxicity and environmental impacts of used antifreeze:

  • Use 'long life' or 'extended life' antifreezes. These are available as ethylene or propylene glycol based and use organic acid technology (OAT) additives extending the service life to five years.
  • Determine when antifreeze needs to be changed out by testing whether characteristics such as freeze protection and corrosion inhibition are adequate. Don't change out antifreeze unless necessary, to avoid creating a waste product.
  • Use separate equipment for the collection of used antifreeze (funnels, pads, storage containers).
  • Keep waste antifreeze free from cross-contamination with other wastes, including used oil, fuels, degreasers or radiator flush chemicals.
  • Employ the following procedure for antifreeze spills on floors:
    • Mop up the antifreeze immediately using a dedicated cloth mop. Transfer collected antifreeze to the properly labeled antifreeze waste container for recycling.
    • Use rags to dry the floor. Place used rags in properly labeled waste containers and send rags to an industrial laundry. Do not saturate the rags; otherwise you will have drips on the floor as you transfer them to the waste containers.
    • Use a wet mop only if necessary for final cleaning. Use mild, non-caustic detergent.
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More Resources

Antifreeze Recycling - EPA fact sheet.

CCAR-Greenlink - Methodology for determining if used antifreeze is hazardous.



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