Facilities Management—Vehicle Maintenance

This page provides environmental compliance assistance information for vehicle maintenance operations.  Topics include:

• Hazardous Waste
  • Hazardous Waste Identification
  • State Hazardous Waste Rules
  • Universal Wastes
  • State Universal Waste Rules
• Wastewater/Stormwater
• Oil Storage Tanks
• Vehicle Air Conditioning Maintenance

Hazardous Waste

Hazardous Waste Identification. 

Many wastes from typical vehicle maintenance activities are likely to be considered "hazardous wastes", as defined by the federal Resource Conservation and Recovery Act (RCRA). Facilities are required to handle and dispose of hazardous wastes according to a detailed (and sometimes confusing) set of rules. Violations of hazardous waste regulations are among the most common reasons for fines and other penalties being applied to healthcare facilities. Any facility that generates hazardous waste can be held liable for any mismanagement of its wastes even after the wastes leave the facility. In addition, these materials can harm employees, others in the community, and the environment. Thus it is important for every healthcare facility to know what wastes are created during vehicle maintenance and repair, and to determine whether they fall under the hazardous waste classification.

The table below provides information on typical wastes created in vehicle maintenance shops.

Source: Consolidated Screening Checklist for Automotive Repair Facilities Guidebook, EPA, Oct. 2003.

In addition to the items listed above, many vehicles contain components that require special handling. Some, like mercury switches found in tilt sensors for trunk and hood lights, and mercury force sensors found in ABS (anti-lock brake) systems, are unlikely to need replacement in ordinary maintenance. But if they are removed from the vehicle, they should be sent to an authorized collector for proper recycling or diposal. Other items, while not regulated as hazardous materials under RCRA, can nevertheless cause significant environmental damage if discarded improperly. Examples include lead-containing items such as wheel weights, batteries and battery cable connectors, printed circuit boards, and radiator and heater cores.

• The EPA website provides a description of the National Vehicle Mercury Switch Recovery Program, together with links to state and local programs. Links to more information on mercury switches, including lists of which vehicles contain them, and how to find them, can be found at a page posted by EPA Region 5.
• Information on lead wheel weights can be found at the Lead Free Wheels website, a project of the Ann Arbor, MI Ecology Center.

For additional information on this topic, refer to the section on hazardous waste. 

State Hazardous Waste Rules.

In most cases states have published their own set of hazardous waste rules.  Although state rules closely follow the federal rules, there are often some important differences.  To find your state's regulations, along with permit forms, guidance, contact information and other helpful resources use the RCRA/Hazardous Waste Resource Locator.

Universal Wastes.

Universal wastes are a special category of hazardous waste.  In 1995, EPA issued the Universal Waste Rule as an amendment to the hazardous waste program to reduce the regulatory burden on businesses by providing an alternative and less stringent set of management standards for certain types of wastes that potentially would be hazardous under the hazardous waste program.  Common vehicle maintenance wastes covered under federal rules (rules in your sate may vary) include lead-acid batteries and mercury-containing switches.

For more information on this topic, go to the section on managing Universal Waste.

State Universal Waste Regulations. 

Most of the federal hazardous waste regulations are adopted nearly verbatim by the states because under RCRA, states cannot have less stringent rules.  However, state adoption of the federal universal waste rule is optional because the rule is less stringent than the original hazardous waste requirements under RCRA.  Also, states can create different standards (except for batteries due to the Battery Act), but they have to be equivalent to the federal regulations (i.e., they must provide equivalent protection, cannot regulate fewer handlers, etc.).  Therefore, it is important that you investigate the universal waste rules in your state by using the Universal Waste State Resources Locator.

Wastewater/Stormwater

Vehicle maintenance activities at healthcare facilities will come under the wastewater or stormwater permits issued to the healthcare facility.  These rules are discussed elsewhere on the VetCA website (see Wastewater Regulations and Stormwater.

Of particular concern in the vehicle maintenance areas are activities such as:

• repair and maintenance of on-site vehicles,
• vehicle cleaning,
• chemical storage and handling, and
• fueling of vehicles.

To minimize water pollution, vehicle operations should:

• store materials indoors that may contaminate stormwater,
• close dumpsters and seal them to prevent water from entering or exiting,
• install oil/water separators and properly maintain them (e.g., sludge removal), and
• use dry methods of cleanup rather than hosing down areas with large volumes of water.

Oil Storage Tanks

Facilities with fleet vehicles, such as ambulances, may keep fuel or oil in underground storage tanks (USTs) or above ground storage tanks (ASTs) and may also have USTs for on-site diesel generators. If a healthcare facility vehicle maintenance operation uses or stores oil it may be subject to the Spill Prevention Control Countermeasure (SPCC) rule of the Clean Water Act. Veterinary facilities that have a total aboveground oil storage capacity exceeding 1,320 gallons or an underground storage capacity exceeding 42,000 gallons are subject to spill prevention control and countermeasure (SPCC) plan requirements (see guidance documents under More Resources).  Veterinary facilities meeting these criteria must prepare and implement a SPCC plan to prevent any discharge of oil into navigable waters.  See VetCA's Oil Storage Tank section for more information.

Vehicle Air Conditioning Maintenance

Refrigerants (Freon, R-12, R-22, R-134a) are the chemicals used in vehicle air conditioning. Federal regulations state that it is illegal to vent any refrigerant to the environment during repair, service, maintenance, recycling or disposal of refrigeration and air conditioning equipment because of the harmful effect of these chemicals on our atmosphere.

Refrigerants must be processed using one of the following methods:

• Recovery - removing refrigerant from air conditioning units and storing it in a container without testing or processing it; or
• Reclaiming - processing refrigerant, usually by distillation, until all impurities are removed and it meets resale specifications.

Spent refrigerants that are not reclaimed or recycled are regulated wastes. EPA requires use of certified refrigerant recycling equipment when servicing vehicle air conditioners. Anyone in who works on vehicle air conditioning systems must also be certified by an EPA-approved organization. Each facility must either have a certified person on-site or bring in a person certified to perform this work. For more information on motor vehicle air conditioning, see EPA's Just the Facts for MVACs: EPA Regulatory Requirements for Servicing of Motor Vehicle Air Conditioners.