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                              California Department of Toxic Substances Control                               October 1988

                                    Office of Pollution Prevention and Technology Development

                                    Sacramento California



On July 17, 1991, the California Environmental Protection Agency officially came into existence and the Toxic Substances Control Program became the Department of Toxic Substances Control under that Agency. The Toxics Program is no longer affiliated with the Department of Health Services or the Health and Welfare Agency. The wording within this particular document has not been changed to indicate this new affiliation. The new mailing address follows:

Department of Toxic Substances Control

Office of Pollution Prevention and Technology Development

400 P Street, 4th Floor

P.O. Box 806

Sacramento, CA 95812-0806

(916) 322-3670



This document was prepared by Nancy S. Ostrom, under the direction of David 1. Leu, Ph.D., and Kim Wilhelm, P.E., of the California Department of Health Services, Toxic Substances Control Division, Alternative Technology Section. Dave Hartley, Paul Hadiey, Benjamin Fries and Jim Potter, also of the Alternative Technology Section, provided extensive critical comment, review and guidance during the devlopment and production of this Checklist. The Department expresses appreciation to Mr. Wesley M. Toy, P.E., Consulting Engineer, Saratoga, CA, for the preparation of the original waste audit study from which this document was derived. The Department also extends its thanks to the owners and operators of auto repair shops who reviewed this document.


This document, Hazardous Waste Reduction Checklist - Automotive Repair Shops, is a revised edition of the previous document issued by the Alternative Technology Section, titled Hazardous Waste Reduction Checklist -Automotive Repair Shops, Book 1 (originally with a light blue cover). The companion to this document, Hazardous Waste Reduction Assessment Handbook - Automotive Repair Shops, is a revised edition of the previous document titled Hazardous Waste Reduction Checklist - Automotive Repair Shops, Book 2 (originally with a gray cover). The changes in these booklets reflect many of the comments received by auto repair shop owners and operators who reviewed the original documents. These booklets may be updated as new technologies emerge and regulations change. If you have any suggestions for improving the usefulness of these documents, please call or write the Alternative Technology Section (the address and telephone number are in the Appendix).


The mention of commercial products, commercial services, their sources or their use in connection with material reported herein is not to be construed as actual or implied endorsement of such products or services.





This Checklist provides you, the auto repair shop owner and/or manager, with information that will help you to reduce the amount of hazardous waste generated in your shop. This Information is strictly for your use. This is not a form that you must fill out and return to the Department of Health Services (DHS). Complete only the sections that apply to your shop and keep it in your files for future reference. If your shop moves, grows or changes its services, go over the Checklist again to see if any new waste reduction strategies will apply to your new situation.


Do You Generate Hazardous Wastes?

Most auto repair shops generate some types of hazardous waste. Some common waste types include:

• Waste oil, lubricants and transmission fluids

• Spent solvents

• Spent caustic parts washing solution

• Parts cleaning tank sludge

• Oily waste sump sludge

• Used antifreeze

• Used lead acid batteries

Remember, if you mix a nonhazardous waste or material with a hazardous waste, the mixture may become hazardous. For example, when you use a sawdust absorbent to clean up hazardous spills in your shop, the sawdust then may become a hazardous waste. In addition, unused hazardous materials that become too old to be used may also become hazardous wastes.

In general a waste is hazardous if it is toxic, corrosive, ignitable, reactive or infectious. The criteria for determining these hazardous properties are complex. You can find the criteria in the California Code of Regulations (CCR) (Article 9 and Article 11 in Chapter 30 and Title 22). There is an order form in the Appendix if you want to request a copy of the Code. According to these regulations, it is the generator’s responsibility to use these criteria to find out if his wastes are hazardous. If you’re not sure if your wastes are hazardous or you need help understanding the criteria, call your local OHS Regional Office or the DHS Alternative Technology Section (telephone numbers are listed in the Appendix).


What Do You Do With Your Hazardous Waste?

An auto repair shop may generate several different types of hazardous waste and these wastes must be stored, handled and treated according to the regulations issued by the State of California (Chapter 30, Title 22 of the California Code of Regulations). Your Regional DHS office is the best source of additional information on your regulatoiy requirements (telephone numbers are listed in the Appendix and on the inside back cover of this booklet).

If you want to take advantage of hazardous waste management methods that will save you money, use this booklet to learn about waste reduction. Waste reduction is one of the methods that will save you money and simplify your hazardous waste management efforts.

Waste Reduction Checklist

This Hazardous Waste Reduction Checklist for Automotive Repair Shops contains a list of questions about the ways you generate and manage your hazardous waste, and hints that will help you spot the waste reduction options that suit your shop. When you have finished with these questions, keep the booklet in your files so that you can refer back to it later to see if it has helped you reduce your hazardous waste.

If you want more information on certain topics or you want to do a more complete analysis, consult the Waste Reduction Assessment Handbook for Automotive Repair Shops.


Waste Reduction Assessment Handbook

The Hazardous Waste Reduction Assesemnt Handbook contains detailed information about waste reduction and hazardous waste management, and includes tables for summarizing waste amounts, estimating the costs of different waste management methods, and evaluating your waste reduction options. These activities are complex. If you don't have the time to do an assessment, but you are still interestd in the results, consider hiring a consultant to do the work for you. Together the Checlist and Handbook form a do-it-yourself balance sheet for wast generation. To get a copy of the Hazardous Waste Reduction Assessment Handbook for Auto Repair Shops, call or write the Alternative Technology Section, Toxic Substances Control Division, Department of Health Services at (916)324-1807.

Remember, this information is for your use only. Complete only the sections in the booklets that will help you reduce your hazardous wastes. You may want to review these booklets each year, or every other year, to see if your waste reduction options are working and if there are any new options you can use. Most of the information and hints in the Checklist and Handbook are aimed at the shop that generates small amounts of hazardous waste. If your shop is large or your operations are complex, you may want to hire a consultant to help you with a hazardous waste assessment.





Reducing your hazardous wastes can help you comply with hazardous waste regulations. You can also save money by reducing your waste disposal costs. Waste reduction can also help you to reduce your liability since it reduces the chances that your waste will be improperly disposed to the environment and require cleanup. Finally, reducing your hazardous waste will help protect your employees’ health and safety because it will reduce exposure to hazardous substances, especially when you include employee training or material substitution in your waste reduction program.



Waste reduction describes waste management approaches that reduce hazardous waste amounts:

Source reduction - substituting input material, or changing production processes or waste handling methods to reduce the amount of waste generated.

Recycling - employing onsite or offsite techniques to remove or destroy contaminants from a waste stream so that the material can be reused.

Treatment - employing onsite or offsite techniques which remove some portion or all of the hazardous components in a waste to make it either nonhazardous or less hazardous.


To be successful, your waste reduction program must be organized. It is not hard to organize waste reduction, but you will need to spend some time at first to get started. Keep in mind the following eight principles of waste reduction.


Eight Principles of Waste Reduction

1.Shop owners and managers must be committed to waste reduction for it to work.

2.You should know the types of hazardous materials you use and the types of hazardous waste you generate, how you generate it, and how much you generate.

3. You should know how your hazardous waste is managed and how much your present waste management costs.

4.Good housekeeping reduces spills and other waste.

5.Store different waste types in separate containers. Make sure your containers are leak-proof and kept covered. Avoid spillage when filling containers with waste.

6.Train all your employees in hazardous waste handling and your waste reduction methods.

7.Be aware of the hazardous materials regulations that apply to you. Assign an employee to keep track of environmental regulations. Have this contact person keep a reference binder or file with regulatory information, telephone numbers, and a short record of telephon, calls (such as the d~te, who they spoke with and what was discussed).

8.Keep up-to-date on new technologies for waste reduction. The Alternative Technology Section in the Department of Health Services is a good source for information on technologies. Trade magazines, newsletters, trade associations, and equipment suppliers are also good sources of information.


The preferred answers are in bold print and helpful hints are in the right hand column.

Raw Materials



How often do you inventory your supplies to spot unnecessary accumulation?_________________

Do you minimize your shop’s stock to keep supplies from becoming too old to be used?

___Yes ___No

If your shop keeps large amounts of supplies, do you use a first-in, first-out material usage policy to prevent materials from deteriorating in storage?

___Yes ____No

Do you maintain, and enforce, a clear policy of using raw materials only for their intended uses?

___Yes ___No






Do you generate hazardous wastes due to spills during raw material or waste handling or storage, or during repairs? ___Yes ____No


If yes, describe the frequency of thepills:_____________________________




You may generate additional hazardous waste if you store raw materials or hazardous wastes improperly. Store them in covered containers. A locked, covered, indoor area with a concrete floor and curbs for spill containment would be ideal for storage. Inspect the storage area often, at least once each month to look for leaky containers or improper storage.


Do you inspect the storage area(s) to make sure containers aren’t leaking and are stored properly?

___Yes ____No

Do you store different waste types in separate

containers? ___Yes ___No

How long do you usually store your hazardous wastes?


Are storage containers covered?

___Yes ___No

Have you installed containment, such as a curb or dike, in storage areas to minimize the area contaminated by a spill? ___Yes ___No

Are your personnel trained in proper raw material and hazardous waste handling and storage techniques? ___Yes ___No

Miscellaneous Auto Repair Waste


If you change engine oil, flush radiators, replace dead batteries, or perform similar repairs, then you may produce hazardous wastes such as spent antifreeze solution, spent lead acid batteries, spent transmission fluid, used oil and/or waste fuel. Reducing spills will help reduce the amount of unnecessary waste. However, since you can’t stop using oil and batteries and other supplies, recycling and treatment are the best waste reduction approaches for these types of waste. Some haulers and recyclers are listed in the Appendix.



Does an oil recycler coiled your waste oil?

___Yes ___No


Does a battery collector remove your used batteries? ___Yes ___No


Do you take used batteries to a storage or recycling facility? ___Yes ___No


Does a recycler or equipment leasing service collect your spent antifreeze solution?

___Yes ____No


Do you use a laundry service to clean your dirty

rags and uniforms? ___ Yes ____No


While replacing brake shoes, do you collect and contain any loose asbestos waste that may be released? ____ Yes ____ No





Parts cleaning operations usually generate spent solvent waste in the form of solvent sink mineral spirits and immersion (carburetor) cleaner solvent. Other solvents you may generate include other types of degreasers and paint thinners. If you spill these materials or use them for purposes other than parts cleaning, degreasing or removing paints you may generate additional unnecessary waste. Solvents also evaporate easily.





Do you use parts cleaning solvent for uses other than cleaning parts?

____Yes ____ No

Are the solvent sinks and/or dunk buckets located near the auto service bays to minimize the amount of solvent spilled? ____ Yes ___ No



Do you allow the deaned parts to drain in the sink for a few minutes after cleaning to minimize the amount of solvent dripped on the floor?

___ Yes ___ No


When immersing parts in solvents, do you pull them out slowly? ____ Yes ___ No



When cleaning parts with mineral spirits solvent, do you use a solvent sink rather than a dunk bucket or dip tank? ____ Yes ____ No


f you do use a solvent tank, do you keep it covered whennotinuse? ___ Yes ____ No


Does a hazardous waste hauler coiled your solvent waste for recycling or treatment?

____ Yes ____ No



Do you own onsite solvent recovery equipment, such as a distillation unit? ____ Yes ____ No


Water-Based (Aqueous) Hazardous Waste


In auto repair shops aqueous hazardous waste refers to water-based detergent wastes and waste suinp solids that are hazardous because they contain caustics, high levels of metals, and/or oily dirt. These wastes are typically generated by engine parts washing equipment.




If you answered "yes" to any of the choices, then you probably generate aqueous detergent waste, aqueous caustic waste, and / or waste sump solids.

Can you replace your aqueous cleaning equipment

(like hot tanks and jet spray washers) with a dry

system such as a high temperature oven?

___ Yes ____ No


Do you use a detergent based cleaning solution instead of a caustic based solution when you are cleaning aluminum engine parts? ___ Yes ____ No


Do you use a drip tray on hot tanks to minimize the amount of waste spilled on the floor?

____ Yes ___ No


Are the hot tank(s) and/or jet spray washer(s) located near the auto service bays?

___ Yes ___ No

Do you pre-rinse the dirty engine parts (two-stage cleaning process)? ___ Yes ___ No




Do you remove the sludge and solids from your cleaning equipment and reactivate the remaining solution to use it again? CI Yes CI No



Do you screen out sludge and solids before they reach the waste sump?

___ yes ___ No

Do you lease hot tank(s)?

___ Yes ___ No

Do you lease jet spray washer(s)?

___ Yes ___ No




Do you own your hot tank(s)?

___ Yes ___ No

Do you own your jet spray washer(s)?

___ Yes ___ No


Does a hazardous waste hauler coiled your aqueous waste for recycling or treatment?

___ Yes ___ No

Do you own onsite aqueous waste treatment equipment? ___ Yes ___ No


Do you recycle your radiator flush water?

___ yes ___ No





Many waste reduction techniques cost little or nothing to use. For example:

• Improve inventory control

• Reduce quantities in storage

• Use first-in, first-out policy for any stockpiled supplies

• Increase storage area inspections

• Place equipment in convenient locations within the shop

The following table lists the waste reduction options discussed in the cheddist. Use it to identify the ones you are most likely to use. Refer back to this table from time to time to make sure you’re doing eveiytlting you can to reduce wastes. Because cost is an important part of your waste reduction decisions, the Waste Reduction Assessment Handbook for Auto Repair Shops contains a method for comparing costs.






This appendix contains sources for more Information on many

of the topics contained In this checklist.




For questions about these booklets, specific waste types or treatment alternatives, COntact:

Alternative Technology Section

Toxic Substances Control Division

Department of Health Services

714/744 P Street

P.O. Box 942732

Sacramento, CA 94234-7320

(916) 324-1807

For information about your regulatory requirements, use the mailing addresses and phone numbers below to contact the OHS regional office nearest you (also see the map on page 23):

Region 1— Sacramento Region 3— Los Angeles
Toxic Substances Control Division Toxic Substances Control sion
Department of Health Services Department of Health Services
4250 Power Inn Road 107 South Broadway, Rm 7011
Sacramento, CA 95826 Los Angeles, CA 90012
(916) 739-3145 (213) 620-2380

Region 1— Fresno

Toxic Substances Control Division

Department of Health Services

5545 East Shields Avenue

Fresno, CA 93727

(209) 445-5938

Region 4 — Long Beach

Toxic Substances Control Division

Department of Health Services

245 West Broadway, Suite 360

Long Beach, CA 90802


Region 2— Emeiyville

Toxic Substances Control Division

Department of Health Services

2151 Berkeley Way, Annex 7

Berkeley, CA 94704

(415) 540-2043

To order the California Code of Regulations or the Health and Safety Code, complete and mall the form on page 21 to:

Department of General Services

Publication Section

P.O. Box 1015

North Highlands, CA 95660

(there is a charge for the regulations)

For information on haulers, contact:

Surveillance and Enforcement

Toxic Substances Control Division

Department of Health Services

714/744 P Street

P.O. Box 942732

Sacramento, CA 94234-7320

(916) 323-6042

To get an EPA or California ID number, contact:

Program Monitoring and Personnel Section

Toxic Substances Control Division

Department of Health Services

714/744 P Street

P.O. Box 942732

Sacramento, CA 94234-7320



For general questions about small quantity generators or federal regulations, call:

U.S. EPA, Small Quantity Generator Hotline (800) 368-5888

U.S. EPA, RCRA (Resource Conservation and Recovery Act) Hotline (800) 424-9346

U.S. EPA, RCRA Hotline, Region LX, San Francisco, CA (800)231-3075





The following table lists some hazardous waste recyclers, haulers, equipment leasing and service companies and equipment manufacturers. This list Is not complete and Inclusion on this list does not constitute an endorsement by DHS. Contact your local DHS Regional Office before using a facility, service or equipment you are not familiar with.

To supplement this list, each year DHS publishes and distributes, free of charge, the California Waste Exchange Directory of Industrial Recyclers. To request this document, contact the Resource Recovery Unit in the Alternative Technology Section at (916)324-1807. For more information on haulers, contact Surveillance and Enforcement (telephone number is on page 16).

To find the names of other equipment leasing and service companies, and equipment distributors and manufacturers in your area, consult trade publications, trade associations and other shops and vendors. The telephone directory for your area or the nearest metropolitan area is also a good source of information.

Listings in the Yellow Pages may be found under several headings, including but not limited to:


State of California--Environmental Protection Agency





The statutes (Chapters 6.5 through 6.98, Division 20, California Health and Safety Code) were enacted by the Legislature. Recent history indicates that the laws change to some extent each year, usually effective January first. To keep up to date with the laws, reorder them each year because no amendment service is available.

The regulations (Title 22, California Code of Regulations [CCR], Division 4.5) were adopted by the California Department of Toxic Substances Control (DTSC) within the scope of DTSC authority under the laws. The regulations may change at any time during the year according to specified administrative procedures. Therefore, continuous amendment service is available by annual subscription, but is useful only in conjunction with the complete regulations (i.e., Title 22, CCR, Division 4, which includes Division 4.5).

The statutes and regulations are not identical. Therefore, both may be needed to obtain complete information.

Copies of the hazardous waste control laws administered by DTSC may be ordered from the California Department of General Services, Publications Section. Copies of the hazardous waste control regulations may be ordered from Barclays Law Publishers. Addresses and phone numbers for each are below:

LAWS: Department of General Services, Publications Section P.O. Box 1015

North Highlands, CA 95660 Phone: (916) 973-3700 (Information only; NO phone orders)

REGULATIONS: Barclays Law Publishers

File No. 42021, P.O. Box 60000

San Francisco, CA 94160-2021 Phone: (415) 244-6611


See REVERSE side for information and forms to order both the statutes and regulations.