Introduction & Background

The US Environmental Protection Agency (USEPA) addresses hazardous waste management through the Resource Conservation and Recovery Act (RCRA), first introduced in 1976. RCRA regulates hazardous waste generation, storage, treatment, and disposal. For a waste to be considered hazardous, the material must first be a solid waste and then must meet criteria as a “characteristic” waste or as a “listed” waste. Vehicle maintenance activities may generate hazardous waste that would be subject to the RCRA requirements.



Maintenance Shops



Trucking & Automotive






Various Services

Statement of Problem

Vehicle maintenance shops may generate hazardous waste and would like to be able to reduce or eliminate it.

Strategy & Solution

The following are key areas for the maintenance facility manager to review:

Waste Assesment

Identifying wastes produced by work processes. The first step identifies existing (documented) and previously undocumented waste streams. Typically, potential hazardous waste sources at a vehicle maintenance shop include:

  • Used anti-freeze
  • Oily waste sump sludge
  • Parts cleaning tank sludge
  • Used solvents
  • Used caustic parts washing solution
  • Used oil, transmission fluids, lubricants

Source Modification/Elimination

Reducing the source or cause of the hazardous waste is a powerful technique that can be used to significantly decrease and even eliminate hazardous waste generation. Some proven source reduction methods include:

  • Avoiding Contamination
  • Source Elimination
  • Best Practices
  • Waste Characterization

Housekeeping Guidelines

After waste assessment and source reduction, it usually becomes necessary to implement corrective action to ensure hazardous waste reduction efforts remain in place. The corrective action usually entails minimal to moderate changes to the vehicle maintenance shop’s existing operational procedures. Frequently, these changes require that wastes be segregated to prevent cross-contamination. Additionally, it is a best practice to implement an inspection program and to provide secondary spill containment. These two measures alone can greatly reduce the possibility of spills and leaks.


To be most effective, the changes should be documented in writing and implemented as procedures. After implementation, employees should be trained on the changes to existing procedures and practices. Key employees, including those involved in container inspection, may require additional training. In most cases, it is recommended that environmental training be performed yearly. New employees should be trained within 30 days of starting on the job.


A deliberate and thorough approach to reducing hazardous waste is the most proactive approach for managing hazardous waste. This approach reduces the burden of managing hazardous waste at vehicle maintenance shops and allows management to more effectively utilize their precious resources.