ENVCAR Fact Sheet
Used Antifreeze

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ENVCAR Fact Sheets
Other Relevant Resources

Regulations

• it is used in your facility vehicles;
• given away for reuse; or
• processed for recycling either on-site or by an off-site recycler. If you use an off-site recycler, you must ensure that the antifreeze is being recycled.

1. Have a sample of the used antifreeze analyzed by a laboratory to find out if it is hazardous. If it is non-hazardous, it can be shipped off-site for disposal by a licensed hauler. If it is hazardous, then special hazardous waste rules apply.
2. Assume that the antifreeze is hazardous and manage it as such. This approach avoids laboratory testing costs.

See the ENVCAR Hazardous Waste fact sheet for details about storing, handling, and shipping of hazardous wastes.

• No severe rusting
• No bulging or major dents; and
• No visible leaks.

Do not accumulate used antifreeze for longer than 180 days.

Labeling. Use the following labeling for antifreeze that will be recycled or reused. For hazardous wastes, see the ENVCAR Hazardous Waste fact sheet for labeling instructions.

• Label used antifreeze collection equipment and containers with the words "Used Antifreeze."
• Label reconditioned or recycled antifreeze containers with the words "Reconditioned or Recycled Antifreeze."
• Mark used antifreeze containers with the starting date of accumulation.

Aboveground used antifreeze storage tanks larger than 550 gallons must be registered with DEP. To find out how to register a tank, call the DEP Storage Tank Regulation Section at 850-488-3935. If you plan to replace a storage tank or remove a tank from service, notify DEP before you begin the work.

If used antifreeze at your facility is a hazardous waste, see the ENVCAR Hazardous Waste fact sheet for additional storage requirements.

1. Stop the release;
2. Contain the released antifreeze;
3. Clean up and properly manage the released antifreeze and other materials; and
4. if necessary, repair or replace any leaking antifreeze storage containers or tanks prior to returning them to service.

See Best Management Practices for additional instruction on antifreeze cleanup.

If you store used antifreeze outdoors, the storage area must be addressed in your Spill Prevention and Countermeasures (SPCC) Plan (see ENVCAR Fact Sheet Spill Prevention and Countermeasures (SPCC) Plan).

If used antifreeze at your facility is a hazardous waste, see the ENVCAR Hazardous Waste fact sheet for additional requirements.

Filter Management. You must either manage waste antifreeze filters as hazardous waste or prove that they are non-hazardous through laboratory analysis. See the ENVCAR Hazardous Waste fact sheet for additional information.

Record Keeping. Keep all receipts of used antifreeze shipments and filter management. The written receipts or records must include:

• Name and address of the generator and the recycling facility for off-site shipments.
• The amount of used antifreeze shipped or recycled on-site.
• The amount of waste antifreeze filters shipped off-site.
• Date of shipment or recycling.

Links to the Regulations. Use the following links to view the regulations pertaining to used antifreeze storage and management.

Identification and Listing of Hazardous Waste

Interim Guidance on the Management of Antifreeze Destined for Recycling

Storage Tank Registration

Self-Audit Checklist

When an inspector comes to your facility, there are certain things they check to see if you are in compliance with environmental regulations. It makes good sense for you to perform a "self-audit" and catch and correct problems before they result in penalties. Also, there are some compliance incentives associated with self-audits (see Audit Policy Page).

Use the following list to audit your antifreeze storage areas and management procedures.

1. Is used antifreeze stored in drums, tanks or other containers that are in good condition? Open containers, and rusting or leaking containers cannot be used for antifreeze storage.

2. Are antifreeze storage containers and tanks properly labeled? All used antifreeze storage containers must be labeled "Used Antifreeze"." All recycled or reconditioned antifreeze storage containers must be labeled "Recycled or Reconditioned Antifreeze."

3. Is the area around the used antifreeze storage containers free of releases? Releases must be stopped and the released material cleaned up and managed properly.

4. Are outdoor used antifreeze storage areas addressed in your Spill Prevention and Countermeasures (SPCC) Plan? Your SPCC must identify potential sources of stormwater pollution and specify appropriate measures to reduce the discharge of pollutants.

5. Is used antifreeze transported to a recovery facility by a certified transporter? Check your records and verify that all shipments of used antifreeze were removed from your property by a state certified transporter. You can check on your transporter’s certification by contacting DEP.

6. Is oil, solvent or other materials mixed with used antifreeze. Verify that there are separate, clearly labeled containers for each type of material, and that used antifreeze is not mixed with used oil, solvents and other materials.

Best Management Practices (BMPs)

Most regulations tell you what you have to do to be in compliance, but they don’t explain how to do it. That’s where "best management practices" come into play. BMPs are proven methods that help you to get into compliance and stay there. The following BMPs are recommended for used antifreeze storage areas and management procedures.

• Use separate equipment for the collection of used antifreeze (funnels, pads, storage containers).

• Label used antifreeze collection equipment and containers "Used Antifreeze."

• Drain antifreeze from radiators and heater cores as soon as possible.

• Keep waste antifreeze free from cross-contamination with other wastes, including used oil, fuels, degreasers or radiator flush chemicals.

• Determine if the antifreeze is waste fluid or reusable and can be recycled.

• Consider keeping antifreeze in two separate, closed containers: one for antifreeze that cannot be reused marked "Waste Antifreeze," and one marked "Usable Antifreeze."

• Label reconditioned or recycled antifreeze containers "Reconditioned or Recycled Antifreeze."

• Label antifreeze containers with the starting date of accumulation.

• Install an antifreeze recycling system. [Waste antifreeze recycling methods involve two steps: (1) removing contaminants either by filtration, distillation, reverse osmosis, or ion exchange and (2) restoring critical antifreeze properties with additives. Additives typically contain chemicals that raise and stabilize pH, inhibit rust and corrosion, reduce water scaling and slow the breakdown of ethylene glycol.]

• Keep any records relating to used antifreeze for at least three years. This includes receipts for used antifreeze shipments and any laboratory results.

• 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.

1. DEP Hazardous Waste Compliance Assistance Program: 800-741-4337.
2. If an oil spill of more than 25 gallons occurs, immediately contact the State Warning Point by phone at (850) 413-9911.
3. DEP Storage Tank Regulation Section: 850-488-3935.

Related ENVCAR fact sheets

• Hazardous Wastes
• Spill Prevention Control and Countermeasures (SPCC) Plan
• Management of Sorbent Material

Other Related Resources

List of Antifreeze Recyclers (9/27/01)
Storage Tank Resources