ENVCAR Fact Sheet
Brake Fluid

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

Regulations

The U.S. Department of Transportation issues specifications for the three main kinds of brake fluid in use by the automotive and trucking industry: DOT-3, DOT-4 and DOT-5. DOT-3 and DOT-4 are glycol-based fluids and DOT-5 is silicon-based. Depending on the additives used,

brake fluid may or may not be hazardous. Even if brake fluid started out as non-hazardous, it can become hazardous if it is contaminated with brake cleaner or other solvents.

Brake fluid is not crude oil-based and therefore it cannot be added to and managed with used oil.

For management and disposal/recycle of used brake fluid, you have two choices:

1. Have a sample of the used brake fluid 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 brake fluid is hazardous and manage and dispose/recycle it as such. This approach avoids laboratory testing costs.

Links to the Regulations. Use the following links to view the regulations pertaining to hazardous waste determinations and management.

Part 261 - Identification and Listing of Hazardous Waste

Part 262 - Standards Applicable to Generators of Hazardous Waste

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 used oil storage areas and management procedures.

1. Used brake fluid is potentially a hazardous waste. Verify that brake fluid was properly managed and disposed/recycled as hazardous waste or that a hazardous waste determination was made that indicates it is a non-hazardous waste.

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 oil storage areas and management procedures.

• Because brake fluid is not crude oil-based, and therefore it should not be added to used oil.
• Collect brake fluid in a dedicated DOT-approved, clearly and properly labeled drum specifically for brake fluids.
• Identify a waste management company that will recycle it.
• Don’t put brake fluid into your used oil container.
• Don’t pour brake fluid down any drain or on the ground.
• Don’t spray brake cleaner around brake fluid.

Contacts:

1. DEP Hazardous Waste Compliance Assistance Program: 800-741-4337.

Related ENVCAR Fact Sheets:

Other Relevant Resources

Waste Brake Fluid, A Recyclable Product