Office of Small Business - Publications

Regulatory Compliance and Pollution Prevention Tips for Automotive Repair and Autobody Shops

Information presented in this publication is intended to provide a general understanding of the statutory and regulatory requirements governing automotive repair and autobody shops. This information is not intended to replace, limit or expand upon the complete statutory and regulatory requirements found in the Illinois Environmental Protection Act and Title 35 of the Illinois Administrative Code.

Why is regulatory compliance and pollution prevention important?

Because automotive repair and maintenance practices can affect more than just you and your customer, it is in your shop’s best interest to comply with regulations that are designed to protect the health and safety of you, your co-workers, your community and the environment. For instance, paints, solvents and other liquids can release hazardous substances to the air, which may result in serious health impacts for employees spray painting, stripping or fluid changing if proper health and safety practices are not followed. Compliance with applicable regulations can help you minimize these impacts and avoid potential penalties and fines.

This fact sheet provides you with an overview of the regulations that you should comply with during your daily operations. It also suggests ways that can help you comply and step "beyond the standard" to prevent further pollution, while possibly reducing costs at your shop.

What is a special waste?

Certain wastes common to auto shops are considered special wastes. Special wastes include:

• Hazardous waste
• Pollution control waste
• Industrial process waste

For more information about how to determine what is special waste including pollution control waste, see the Illinois Environmental Protection Agency (EPA) Office of Small Business fact sheet titled "Do I Have A Special Waste?" or call the Office of Small Business. This fact sheet describes hazardous wastes and industrial process wastes that are common to automotive repair and autobody shops.

What is a hazardous waste?

Hazardous waste is a type of special waste. A waste can be classified as hazardous if it (1) is listed on the Illinois EPA hazardous waste list which can be obtained from the Office of Small Business, or (2) exhibits one of the following characteristics: ignitability, toxicity, corrosivity or reactivity.

Various tests can be conducted in a lab to confirm whether a substance has hazardous characteristics, or generator’s knowledge of a waste’s contents can also tell you if a waste is hazardous or not. Contact the Office of Small Business or see your material safety data sheets (MSDS) for more information on a specific product or source. Carefully reading product labels and warnings also can be helpful.

What is an Industrial Process Waste?

An industrial process waste is any liquid, solid, semisolid, or gaseous waste generated when manufacturing a product or performing a service. Examples of industrial process waste generated at auto shops include cutting oils, paint sludges, equipment cleanings, metallic dust sweepings, used solvents from parts cleaners, and off-specification, contaminated, or recalled wholesale or retail products.

What are some common automotive repair and autobody shop waste streams?

As a generator of waste, it is your responsibility to determine what kind of wastes you generate and to make sure that you comply with the necessary waste, water, and air regulations for handling those wastes. Common auto shop waste streams may include:

• Used oil and used oil filters
• Used antifreeze
• Used solvents, paints, and coatings
• Used rags and other absorbent materials
• Used batteries
• Used tires
• Waste washwater and rinsewater

Waste Regulations

What specific waste regulations apply to managing waste streams that I generate?

Used Oil - Used oil that is contaminated with dirt, metals, waste, or other chemicals during the process (for example, running through an engine) IS NOT a hazardous waste if it is recycled on-site or off-site. However, used oil may be a hazardous waste if it is mixed after the process with hazardous materials such as gasoline or solvents. Therefore, used oil should be separated from other wastes and stored in leak-free containers labeled "Used Oil."

Because used oil is often recycled or reused, it is subject to it’s own management requirements. See the "How Do I Manage My Used Oil and Used Oil Filters?" fact sheet or contact the Office of Small Business for more information.

Used Oil Filters - Used oil filters ARE NOT a hazardous waste if they are drained properly. Oil filters should be fully drained using an approved method such as:

• puncturing the filter anti-drain back valve or filter dome and hot-draining for at least 12 hours
• hot-draining and crushing
• dismantling and hot-draining
• any other equivalent hot-draining method, which will remove all of the used oil in the filter

• You reduce the amount of waste that you have to pay to ship off-site.
• You reduce the amount of materials you will need to buy in the future!

For ideas of how you can better recycle and reuse wastes in your shop, contact the Office of Small Business. It pays to recycle!

After a filter has been properly drained it can be safely recycled with other scrap metal. Used oil drained from filters can be combined with other used oil. For more information on how to handle used oil filters, see the "How Do I Manage My Used Oil and Used Filters?" fact sheet, or contact the Office of Small Business or the Filter Manufacturers Council Regulatory Hotline at (800) 999-FILTER.

Used Antifreeze - Antifreeze IS hazardous waste if it contains elevated levels of solvents or certain metals, particularly lead; if the pH level is greater than 12.5; or if it is mixed with a hazardous material such as gasoline or solvents. Antifreeze IS NOT considered hazardous waste if it is recycled in a closed loop system on-site.

Used Solvents - Used solvents ARE considered hazardous wastes when the flashpoint (the temperature at which the liquid will ignite) is under 140° F. Based on the solvent used, some used solvents may also be considered hazardous for the characteristic of toxicity. Used solvents, such as those from a parts washer, should be segregated from other wastes in clearly labeled, leak free, and tightly closed containers. An off site contractor should be employed to dispose of used solvents. See the "Managing and Reducing Parts Washer Wastes" fact sheet for more information on managing used solvents.

Paints and Coatings - Paints ARE considered hazardous when they (1) contain elevated levels of certain metals, such as barium, mercury, and lead, (and are therefore considered toxic) and, (2) if the flashpoint is below 140° F or (3) if they contain hazardous amounts of certain solvents. Carefully read container labels and consult MSDSs to find out the contents of the paints your shop is using.

Used Rags and Other Absorbents - Rags and towels used to wipe down dirty parts and equipment, and to clean up spills that may occur around the shop should be wrung out, separated, and stored in clearly-labeled containers. Soiled rags that have been thoroughly wrung out (meaning that not even a drop of liquid drips from the rag when wringing) can be sent out to be cleaned with other industrial laundry. Rags that are laundered ARE NOT considered hazardous or special waste. Rags should be wrung out into containers that are clearly marked with the name of the substance that was absorbed.

If the rag can not be thoroughly wrung out, the rag should be managed based on the material it was used to absorb. If the material absorbed is hazardous, the rag should be considered hazardous as well.

If your facility uses other absorbents such as kitty litter, sawdust, or a similar substance to clean up spills on site, it is important to dispose of these used absorbents properly based on the material they absorbed. For example, absorbents used to clean up a solvent spill many need to be disposed of as a used solvent. For more information, see the "How Do I Manage My Used Rags and Other Absorbents?" fact sheet.

Used Batteries - Used batteries may be hazardous. If so, they can be managed under the universal waste rules. For more information on universal waste, call the Office of Small Business. Retail battery suppliers must accept used batteries in exchange for each battery purchased. Used batteries that are waiting to be transferred to the recycling facility should be kept indoors in a noncorrosive container or on a covered platform where battery acid leaks can not reach drains. Your battery supplier may accept batteries for recycling.

Used Tires - Used tires are NOT hazardous waste. Used tires that are not suitable for resale must be sent to an IEPA-registered used tire storage/processing facility. Any vechicle transporting more than 20 used tires in Illinois must be registered with the Illinois EPA and display proper placecarding. Used tires can be recycled by being retreaded and resold, or shredded into tire chips and used for various purposes, such as burned for energy recovery, converted into crumb rubber for various recycling applications, or utilized in "high-end" civil engineering applications (road base in highway construction over weak soils, septic system leachate fields, drainage media in landfill applications, etc.) If you are not a tire retailer and you have more than 50 used tires on your property, you are considered a used tire storage site and you must register your site annually with the Illinois EPA and pay a $100 annual storage fee. If you are a tire retailer, there are several exemptions available to you related to the number of used tires in storage.

Please visit the Illinois EPA's Used Tire Program website at: http://www.epa.state.il.us/land/tires/index.html for more information or contact the Illinois EPA's Used Tire Program at 217/785-8604.

How do I manage my hazardous waste?

The regulations that affect your shop are based on how much hazardous waste you generate. The following bullets describe the three hazardous waste generator categories.

• Generate less than 220 pounds (100 kilograms) of hazardous waste per month
• Generate a total of 220 to 2,200 pounds (100 to 1,000 kilograms) of hazardous waste per month
• Generate over 2,200 pounds (1,000 kilograms) of hazardous waste per month

If you have questions concerning the amount of waste your shop produces, contact the Office of Small Business for more information.

What if I generate less than 220 pounds of hazardous waste per month?

Most automotive repair and autobody shops generate less than 220 lbs. per month of hazardous waste. If you generate less than 220 lbs. per month, the following requirements apply to you:

• Identify all hazardous waste that you generate.
• Hire a licensed special waste hauler to transport your hazardous waste to a facility permitted to receive hazardous waste. To obtain a list of Illinois-licensed special waste haulers and permitted facilities, call the Office of Small Business.
• Do not accumulate more than 1,000 kilograms (2,200 pounds) of hazardous waste on your property at any time.
• Store all hazardous waste in containers such as drums.

What if I generate 220 pounds or more of hazardous waste per month?

If your shop generates 220 to 2,200 lbs. per month of hazardous waste certain regulations apply specifically to you. You must:

• Obtain an EPA Identification Number indicating waste generator status
• Store hazardous waste on site for less than 180 days
• Affix all hazardous waste storage containers with "Hazardous Waste" labels and accumulation start dates
• Maintain hazardous waste containers in good condition without cracks, bulges, dents, or leaks; containers must be compatible with waste (corrosive wastes should not be in steel containers unless they are lined with corrosion-resistant material);
• Inspect hazardous waste accumulation areas on a weekly basis
• Store less than 55 gallons of hazardous waste in each accumulation area, located at or near the site of the waste generation; and
• Maintain at least two feet of aisle space in accumulation areas to allow for easy access of personnel and equipment.

You must also prepare your shop for emergency situations:

• Designate an emergency coordinator
• Place fire extinguishers and eyewash stations at appropriate locations around the shop
• Establish an internal communication or alarm system
• Post emergency numbers next to the telephone
• Regularly test and maintain safety equipment
• Routinely train employees on proper waste handling emergency response procedures
• It is recommended that you store all hazardous waste containers in an area which is sufficiently impervious to contain leaks and sloped to drain spills away from drum unless the drums are elevated or otherwise protected from contact with accumulated liquids (for example, stored on a pallet.)

If you generate more than 2,200 lbs. per month of hazardous waste, see the "How Do I Manage my Hazardous Waste?" for information about regulations that apply to you or call the Office of Small Business.

Water Regulations

How is my shop’s wastewater regulated?

Wastewater is often generated by operations such as the rinsing of parts, and the washing down of engines or dirty tools. If water becomes mixed with oil, antifreeze, solvents, or other liquids , it is important that it be properly treated and contained prior to discharge.

A National Pollutant Discharge Elimination permit from Illinois EPA is required for business owners that discharge their power washing wastewater directly into a water body. If wastewater is discharged to a sanitary sewer system, the business owners must apply for a state construction permit and may also need to apply for a state operating permit. Contact the Office of Small Business for more information on Illinois EPA water permits. If your shop is discharging large quantities of wastewater into the municipal sewage system, you may be required to get a permit from your local wastewater treatment plant.

Know Where Your Wastewater Discharges!

What if a spill occurs?

A number of regulations are designed to protect you and your co-workers before such a situation occurs. If a spill occurs, immediately take action to contain the spill. To prepare for emergency situations, make sure that the following actions have been taken.

When cleaning up spills in your shop or in the surrounding area, remember to first use the dry clean-up methods such as dry mops, rags, or absorbents. Using water to address a spill may create contaminated wastewater and makes the spill harder to contain. For small spills, use a rag or an absorbent that can be properly disposed of. The steps below offer a helpful guide to how to react in the case of a larger spill.

• Contain the spill and remove any potential hazards in the area
• Use a dry mop or broom, squeegee and dust-pan, or vacuum to clean up the bulk of the spill
• Use a rag or other absorbent to clean up the remaining liquid
• Notice whether the spilled liquid has entered any floor drains in your facility or the surrounding area
• Remember to store the recovered liquids in separate and clearly marked containers so that they can be properly disposed of
• If you suspect that the spilled liquid has entered a drain or was not otherwise fully contained, immediately contact the Illinois EPA at (800) 782-7860 and report that a release has occurred.

Air Regulations

How does my shop contribute to air pollution?

Activities common to automotive repair and autobody shops that can impact the air surrounding your shop include the following:

• Using solvents to clean dirty and used parts
• Spray painting and paint stripping
• Grinding and buffing
• Maintaining air conditioning systems
• Storing and dispensing gasoline

Automotive repair and autobody shops are subject to a number of air pollution regulations, and may be required to obtain permits depending on the type of activities conducted, the amount of materials used, and the location of the shop.

What specific regulations and procedures should I know to keep my air pollution below legal limits and my workplace safe?

Below are a number of materials common to automotive repair and autobody shops that can be sources of air pollution. Proper handling can reduce the amount of air pollution while keeping the workplace safe for employees.

Halogenated Solvents - It is important to note whether or not your facility is using halogenated solvents for parts cleaning. Halogenated solvents are defined as solvents that contain greater than a 5% concentration of (1) methylene chloride, (2) perchloroethylene, (3) trichloroethylene, (4) 1,1,1-trichloroethane, (5) chloroform, or (6) carbon tetrachloride (this information can be found on the MSDS.) If halogenated solvents are used in your shop, you must complete and submit a notification report to the Illinois EPA. Also, solvent storage containers should be closed securely to prevent air emissions from escaping the container. For more information on parts washer solvents, see the "Managing and Reducing Parts Washer Wastes" fact sheet.

Chlorofluorocarbons (CFCs) - Many motor vehicle air conditioners (MVACs) contain refrigerants with CFCs, which are believed to damage the layer of protective gases around the earth (ozone layer) if released to the air. Regulations have been designed to limit the use of CFCs in many industrial processes.

MVAC technicians and others engaged in fluid exchanging activities should be trained by an EPA-approved Section 609 program in order to work safely with air conditioning units. Training certificates should be on kept on file in your shop.

Refrigerant recycling and recovery equipment must be approved by the Illinois EPA and must meet the standards of the Society of Automotive Engineers.

Gasoline - If your shop dispenses gasoline you may, depending on your location, be subject to certain requirements.

Gasoline dispensing operations located in either the Chicago or Metro-East ozone non-attainment areas or in Boone, Peoria, Tazewell, Rock Island, or Winnebago Counties and which exceed certain gasoline throughput levels must comply with the Stage I vapor recovery requirements.

These measures involve the minimization and capture of gasoline vapors generated when fuel is transferred from the delivery truck to the storage tank.

If your station is located in the Chicago ozone non-attainment area and you sell over 10,000 gallons of gasoline per month, all gasoline pumps must be equipped with Stage II vapor recovery equipment. This equipment captures the gasoline vapors displace from vehicle fuel tanks during refueling. Stations must register with the Illinois EPA. For more information on Stage I and Stage II requirements and equipment specifications, contact the Office of Small Business.

Ozone Non-Attainment Areas in Illinois

Chicago

• Cook County
• Dupage County
• McHenry County
• Kane County
• Lake County
• Will County
• Aux Sable and Goose Lake Townships in Grundy County
• Oswego Township in Kendall County

Metro-East St. Louis

• Madison County
• Monroe County
• St. Clair County

Paints and Thinners - Paints and thinners should be stored in clearly-labeled, airtight containers that are tightly closed when not in use. While most shops do not release the amount of VOCs that make a permit necessary, any shop with painting operations that uses over 5,000 gallons of paint per year is required to obtain an air permit.

Autobody refinishing operations located in the Chicago and Metro-East St. Louis ozone non-attainment areas must register with the Illinois EPA and must comply with additional requirements. Shops in these areas must use paints and cleaning products meeting certain VOC content limits. The use of high-efficiency paint applicator guns and automatic gun cleaning devices is also required.

Particulates - Shops engaged in grinding, welding, and sandblasting activities may produce a large amount of fugitive particulate matter (metal filings, dust, etc.). Work areas should be equipped with ventilation and filtration systems, placed directly at the source of dust, that collect and remove airborne particulates and remove fumes from welding operations. Make sure to replace filters when needed. Sweep the shop for particles and dust not collected in the filtration system before engaging in any washing or rinsing activities. Metal filings and paint chips created when sanding and grinding can negatively impact water quality if allowed to enter the environment.

How Do I Obtain More Information?

For additional information on how you can keep up with regulations and requirements that effect YOU, call the Illinois EPA Office of Small Business Helpline toll-free at (888) EPA-1996 or the DCCA Small Business Environmental Assistance Helpline at (800) 252-3998. All calls are considered confidential and the caller can remain anonymous.

Related Information

• Conditionally Exempt Small Quantity Generator (CESQG) Information
• CESQG Certificate of Exemption ( PDF 6K file, 1 page)
• Do I Have A Special Waste?
• Managing and Reducing Parts Washer Wastes
• How Do I Manage My Used Rags and Other Absorbents?
• How Do I Manage My Hazardous Waste?