• Aerosol Cans – Punctured and empty aerosol cans are exempt from the hazardous waste rules, allowing them to be recycled as scrap metal. It is recommended that all fluids be used up, cans punctured, and excess material drained in order to recycle aerosol cans for scrap metal. If a spray can malfunctions, consider returning it to the manufacturer.
  
  
• Antifreeze – Antifreeze consists of water, ethylene glycol, or propylene glycol. When in product form it is not considered hazardous; however, used antifreeze can become contaminated with heavy metal, benzene, and solvents, rendering it a hazardous waste. Used antifreeze must minimally be tested for lead, benzene, tetrachlorethylene, and trichloroethylenes using the Toxic Characteristic Leaching Procedure (TCLP); see “Characteristic Waste” discussion. Used antifreeze must go for recycling or proper hazardous waste disposal. If it does not pass the TCLP, it must be handled as a hazardous waste.
  
  Used antifreeze can be recycled using distillation, filtration, or ion exchange processes. A log documenting the volume of recycled antifreeze is required. Alternately, it can be shipped to a permitted recycling facility. Burning used antifreeze for energy recovery is not considered recycling. Used antifreeze cannot legally be poured down the sewer. Storage containers or drums of spent antifreeze are required to be marked “Used Antifreeze.” If under contract, most companies will accept spent antifreeze for recycling at no cost or very little cost.

Used antifreeze filters that do not fail the TCLP can be recycled with the used oil filters.
Best Management Practices for Managing Used Antifreeze at Vehicle Repair Facilities (PDF) is a helpful publication.

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• Ballasts – Light ballast capacitors marked “PCB” are a hazardous waste and must go for proper disposal. If the capacitor has a blue label marked “non-PCB,” it can go into the municipal solid waste.
  
  
• Batteries – The most common maintenance battery is the lead acid battery for machinery and vehicles. Guidance for indoor storage recommends stacking batteries on wooden pallets on an impervious surface. Stack batteries less than four high to eliminate cracked-cap issues. Guidance for outdoor storage recommends secondary containment away from high-traffic areas and covered from the elements.
  
  Keep spill-kit equipment near storage, especially a container of baking soda to neutralize acid releases. Broken batteries should be stored in a closed, airtight, acid-resistant storage container.
  
  Lead acid batteries can be returned to the retailer for a fee or a clause can be incorporated into the battery contract for battery exchange. Florida does not host a permitted lead reclamation facility; therefore, all lead waste must leave the state for recycling. For batteries to be considered an exempt material, a “core charge” must be cited on a receipt. An outline for the disposal method for a variety of batteries is “Where Do I Recycle Rechargeable Batteries?”
  
  
• Brake Fluid – Contaminated with chlorinated solvents, brake fluid is considered a hazardous waste. Most used oils transporters allow nonhazardous brake fluid to be added to the used oil.
  
  

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• Compressed Tanks – Although compressed tanks are not usually under the jurisdiction of the EPA, they are worth mentioning since most automotive shops are out of compliance. Under 29 CFR Occupation Safety and Health Administration, 1910.101, “Compressed Gas,” and C-6-1968, Compressed Gas Association pamphlet, the following are the compressed gas tank management requirements:
  • Transport cylinders using a cylinder cart and a safety cap;
  • Store cylinder upright and secured with approved lock-down devices;
  • Use correct pressure regulator for the specific gas;
  • Do not store cylinder with regulator in place;
  • Mark cylinder with chemical name;
  • Label cylinder to indicate if the container is empty or full (optional); and
  • If in active use, keep the hose unwound and the tank cart placed near a work station.
    
    
• Electronic Equipment - DEP recycling information for electronic equipment is found on the End-of-Life Electronics Main Web Page. In particular, computer monitors and televisions, due to their lead content, must be discarded properly. Precious metals such as gold and silver are also recovered from used electronic items. No unusable electronic equipment should be placed in the dumpster or donated to a thrift shop.
  
  
• Empty Drums – All the contents must be removed by inverting and draining, shaking, and scraping, and then the containers can be crushed, punctured, or shredded and discarded as scrap metal. All stored empty drums must be clean, dry, bung-closed, and turned on their sides to inhibit water collection as they sit. Frequently, contractors will exchange drums that held virgin product. The drums can also be picked up by companies that recondition used drums. If the drums contained non-hazardous waste or used oil, they can be burned by a municipal foundry that conducts scrap metal reclamation.
  
  
• Floor Dry – If it holds non-hazardous oil or fluid, small amounts of floor dry can be bagged and placed in the dumpster, but this method of disposal requires written verification to the solid waste hauler. Otherwise absorbents that come in contact with hazardous waste must be managed as RCRA hazardous waste. This waste can be very costly to dispose of since it is very heavy. Some new methods of recycling floor dry are available through composting or distillation and refortification of the fine particles.
  
  

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• Fuel Filters – Most fuel filters are handled as a hazardous waste. Metal fuel filters can be handled with the used oil filters if drained for at least 24 hours and dried. Glass filters are managed separately and require waste determination; if non-hazardous, they can be disposed of in the dumpster or recycled with other glass.
  
  
• Mercury/Fluorescent Lamps – Refer to the Florida Department of Education's Mercury Eliminiation in Florida Schools web site to review guidance on storage, management, and disposal of mercury-containing devices, and to review the Florida State Contract for Mercury Recycling. Store lamps to prevent breaking and label each container “Spent Mercury-Containing Lamps.” Lamps should not be stored for over one year. Do not break or crush lamps unless using a machine designed for this function. You may also want to visit Florida Department of Environmental Protection's Registered Handlers of Mercury Containing Lamps and Devices web page.
  
  
• Paints – Latex paint not containing any hazardous metals per the Material Safety Data Sheet is considered nonhazardous. Oil-based paints are considered hazardous for solvents and metals, but the brushes, rollers, and applicators are not; they can go to the landfill once dried.
  
  
• Rags – All disposable shop towels, wipes, or rags that come in contact with a regulated solvent may qualify as a hazardous waste. Store these rags in a fire-retardant container with a self-closing lid labeled “Used Shop Towels.” It is best to contract with a laundry service that maintains a National Pollution Discharge Elimination System (NPDES) permit. Keep metal shavings and overwhelming odors from emanating out of the rags, and the rag-laundering partnership will go smoothly. An accountability system should be set up to track whether rags are being thrown into the municipal trash or not being returned from the launderer.
  
  
• Solvent Cleaning – Many parts washer fluids, degreasers, and spray-on solvents can be hazardous due to flash point (over 140° F) or contamination with heavy metals. Filtration and distillation reduce the amount of hazardous waste and at the same time recycle the solvent for reuse, but are only cost-effective when large amounts of spent solvent are generated. There are other methods that use microbes in aqueous detergents to generate biodegradable, nontoxic, noncaustic by-products without having to change out the parts washer fluid.
  
  Alternatively, if you are a Conditionally Exempt Small Quantity Generator (CESQG), you can use a solution that has a flash point that exceeds 140° F and contains less than 1,000 ppm halogens (mainly chlorine), which allows this non-hazardous waste to be directly added to your used oil. For this type of disposal, it may be necessary to conduct a mini-TCLP (metals only) to qualify material as a non-hazardous waste. The Environmental Compliance for Automotive Recyclers hosts a fact sheet for Florida Solvent Cleaning.
  
  

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• Smoke Detectors – Smoke detectors commonly contain a small amount of Americium 241, a radioactive material. Detectors’ normal life span is approximately ten years. The only way to be sure a smoke detector is still working is to test the detector with artificial smoke. Many detector companies will accept spent detectors. The majority of detectors are manufactured by First Alert Corporation, which will accept old detectors via mail to First Alert, Radioactive Waste Disposal, 780 McClure Road, Aurora, Il, 60504-2495or call 1-800-323-9005. Most other smoke detectors are manufactured by a Canadian firm called American Sensors, which can be contacted at 1-800-387-4219. It is recommended to return these detectors by surface rather than air mail.
  
  
• Storage Area Inspections – Small Quantity Generators (see “Generator Size Determination”) are required to document storage area container inspections. CESQGs are not required to document such inspections, but are also encouraged to inspect containers for:
  
  

  Drum Closed?	Storage Time Limit OK?	Cracks in Floor?
  Drum Labeled Correctly?	Accumulation Limit OK?	Outdoor Area Secure?
  Label Visible?	Spills or Leaks?	Outdoor Area Shaded?

  
  

  Other required information on the inspection log includes date of the inspection, any problems noted, signature by the inspector, and any corrective action taken.

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• Used Oil – Used oil must be stored in Department of Transportation (DOT)-approved containers in good condition visibly displaying the words “Used Oil.” Used oil containers must be protected from the elements and stored on an oil-impermeable surface painted with sealant with secondary containment per 40 CFR 279 and Chapter 62-710, FAC. This also applies to the storage of used oil filters. Owners or operators who spill or release more than 25 gallons of petroleum or petroleum products on a pervious surface must report the discharge to the National Response Center, Florida DEP, or State Warning Point (see “Emergencies, Training, and Recordkeeping”).
  
  

  The used oil rules allow you to mix used crankcase oil, synthetic oils, brake fluid, transmission fluid, hydraulic oil, power steering fluid, and lubricating greases into one drum or tank, but prohibit the addition of vegetable or animal fats. Avoid contact with solvents, brake cleaner, and carburetor cleaner with oil, and do not mix antifreeze, solvents, gasoline, degreasers, paint, or other automotive fluids with used oil or with solid waste heading to the landfill. Do not spray used oil on roads as a dust retardant or on the ground for weed control.

  If used oil is recycled, also known as re-refined, it is not presumed a hazardous waste and the volume or weight is not counted toward generator size; however, local rules may be more stringent. All transporters must be DEP-registered used oil transporters and the recycler must be a state-permitted used oil processor.

  
  For more information, please see:
  
  
  • Discharge Notification
  • EPA Used Oil Management(PDF)
  • DEP Used Oil General Information
  • DEP Currently Registered Used Oil Handlers
  • DEP Used Oil Generator Checklist(Word)
    
    
• Used Oil Filters – All used oil filters (and transmission filters) were banned from landfills in 1995; however, household filters are exempt from this ban per Chapter 62-710.850, FAC. Burning them through a Waste to Energy (WTE) facility for energy recovery and metal recycling is allowed in certain counties. Otherwise, generators must drain (24 hours prior to disposal), consolidate, and crush used oil filters for off-site recycling by a DEP-registered used oil filter processor. Used oil filters must be stored in DOT-approved containers in good condition that visibly display the words “Used Oil Filters.” Containers must be protected from the elements and stored on an oil impermeable surface covered with sealant per Chapter 62-710.850(6), FAC.
  
  

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• Tires – Waste tires should be covered to prevent collection of standing water when stored in a central location with no more than 1,500 tires at one time. Burning or burying waste tires is prohibited. Almost a quarter million tires are scrapped in the United States each year, with over 80% of the tires now being retreaded, recycled, or used as fuel.
  
  

  For more information, please see:

  • EPA Scrape Tire Management in the Southeast
  • EPA Markets for Scrap Tires(PDF)
  • DEP Tires - General Information
  • DEP’s Environmental Compliance Workbook for Automotive(PDF)
    

Common School Waste Discussion

Be careful; there are many instances in which the disposal contractor is not disclosing the actual volume of waste on the disposal manifest. For example, the manifest documents the disposal of a 55-gallon drum of a hazardous waste, but in reality the drum only contained 20 gallons. It is very important to cite the actual volume or weight of the hazardous waste on the manifest and separately outline all non-hazardous waste going to a Treatment, Storage, and Disposal (TSD) facility in Section 14, “Special Handling Instructions and Additional Information,” so that the waste is not counted against your generator size. If this is not done, it may affect your generator size. Generators may only exceed their waste allowance one month out of each year.

Surprisingly, art departments can generate up to 20% of all hazardous waste at a school. Solvents used for oil-based paints and pigments containing lead, cadmium, and chromium can be considered hazardous. If this art waste goes for infrequent disposal through the management of a satellite accumulation site, a mini-TCLP may disqualify it as a hazardous waste.

Additionally, photography laboratories use neutralizers, fixers, and developer solution by-products. Contracts often provide for quarterly or semiannual pickups for disposal. The fixer is hazardous for silver content; the developer can be considered non-hazardous at the end of the development process. Contact your local domestic wastewater treatment facility for more information. DEP’s Photo Shop publication(PDF) is a good resource to review.

During the physical facility inspection, one of the most common violations is leaving the bung open on a drum containing a hazardous waste. This can be rectified by the purchase of a snap lid funnel that can be easily opened and closed while adding or removing waste. Larger versions of these funnels can also accommodate used oil filters so they can drain overnight while also keeping the container closed. Another common violation is poor fluorescent lamp storage and labeling. Lamps should be in a dedicated storage area, out of traffic, organized, and labeled “Used Lamps.”  For further information visit DEP’s Currently Register Hazardous Waste Transporters.

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