Good question! And, with so many types of waste streams, the answer is it depends.
Common waste streams include used oil, filters, coolants, and gasoline as well as universal wastes, wheel weights, tires, brake dust, sanding booths, oil and water separators, parts washers, and paint and thinner wastes.
Let’s take a closer look at each of these waste streams and discuss how to tell what you should do with them to comply with environmental regulations.
Universal waste
This category includes very commonly generated waste that can be recycled so they do not need to be counted as hazardous waste. Think car batteries and household batteries, fluorescent lamps and light fixtures, electronic waste, such as computer monitors, printers, and anything else electronic with metal that’s recyclable, as well as aerosol cans.
The habit may be to throw an aerosol can in the trash, and if the can is completely empty, this may be perfectly acceptable depending on applicable state regulations. But, if any propellant remains that could be flammable or potentially toxic. In that case, use an aerosol can puncture device to capture theliquid that comes out and the propellant, too. If you properly do this with an approved device, the aerosol can may be managed as universal waste.
Sanding dust and paint booth filters
Be careful with these because they could contain heavy metals like barium or the seven other heavy metals, including mercury, listed on the regulations for toxics. As a best practice err on the side of caution and assume there are some hazardous properties with these, and don’t just throw them in the trash. Consider, too, that when sanding paint off a vehicle that has metals in it, the sanding dust could also be hazardous, so plan accordingly regarding disposal.
Oil/water separator
This type of mechanical device, which needs to be hooked up to the city sewer system (not a stormwater system), allows a small amount of oil to be poured down a drain where it’s captured. Two waste streams result—oil on top and sludge at the bottom. And, you have two options: Conduct a Toxicity Characteristic Leaching Procedure (TCLP) test or presume you’ve got hazardous waste.
Parts washers
Does your state have a continued use program? Do you have a smart/safe washer? These are key questions to ask because they can help you figure out whether and how much waste is being generated. For instance, in the case of a smart/safe washer where there isn’t a lot of waste, perhaps just the filter would be considered hazardous depending on your process.
Here’s another example, too. Let’s say you have any type of parts washer and you spray it apart with brake cleaner that contains toluene (a hazardous substance). If you then put that in the parts washer, the brake cleaner contaminants could wash off and make your entire waste stream hazardous.
Another thing to watch out for is hot parts washers. These may contain some oily sludge, which could be considered a hazardous waste, too.
Paints and thinners
Waterborne wastes typically aren’t considered hazardous, but solvent-containing wastes are. Even if you have a solvent recycler, the sludge that comes out of that which is commonly referred to as a “hockey puck” could be considered hazardous. The main takeaway is that given the process of recycling paint hazardous waste is always going to be generated from the solvent recycler.
Used oil, filters, coolants, and gasoline
These include used automatic transmission fluid, oil, synthetics, and filters, antifreeze, and contaminated gasoline, which are recyclable. So, rather than having them hauled off as hazardous waste, which is expensive and unnecessary, just make sure you have documentation on hand that you are properly recycling them.
Lead-containing wheel weights
These are more uncommon these days, but if you’re not using alloy wheel weights, which stick on, be mindful that wheel weights with lead must be recycled (for example, for scrap metal) or disposed of as hazardous waste.
Tires
Many states have strict regulations on how many tires can be stored, where, and how they may be stored. For instance, you’ll need to consider how to properly cover the tires so mosquitos don’t breed in them, etc. The good news on tires is that generally they can be recycled.
Brake dust
Due to metal in the rotors, brake dust can be hazardous. Some states consider dust from the lathe as being potentially hazardous depending on the rotor’s content. As a best practice, be sure to collect the dust in a bin and look to recycle it as scrap metal.
The bottom line: Conduct an individualized analysis when answering the question of what to do with each and every waste stream.
And, if you conclude what you have is hazardous, keep the hazardous waste manifest for at least 3 years. That’s because if a Superfund cleanup emerges and you don’t have disposal receipts, your facility might have to cover some of the cleanup costs.
If you have questions about how to make sure you are properly deciding what to do with a particular waste stream, reach out to KPA.
