When Should You Worry?
There are probably thousands of local, state and federal environmental laws that affect truck shops, so every maintenance operation — no matter how small — needs to worry about compliance. If you're not sure what issues affect your operation, here's a quick list of major concerns.
• Toxic wastes. You're responsible for the safe disposal of any toxic or hazardous wastes you generate in your business. That generally includes any substance that is ignitable, corrosive or toxic. Small generators (usually less than 25 gallons of toxic waste a month) may be exempt from the strictest regulations, but you still need to make sure that hazardous waste is properly handled.
• Waste water. A special permit or treatment may be required in order to discharge water from normal housekeeping operations into a municipal system or a septic system. Fluids, spent solvents and cleaning materials often must be collected and disposed of separately.
• Wash water. Because of oil, grease, sediment and other potential harmful materials, vehicle washing is federally regulated. Pretreatment and special permits are usually required.
• Storm water runoff. Permits are required for many facilities that fuel, wash or maintain trucks. However, there is a no-exposure provision for those that take special precautions — such as covering operations — to limit runoff exposure.
• Fuel storage. Underground storage tanks must comply with minimum requirements for lead detection, corrosion protection and spill/overfill protection. Spill Prevention, Control and Countermeasure (SPCC) plans are required for facilities that store more than 1,320 gallons.
• Used oil. States require used oil and used oil filters to be properly managed and disposed of. Some allow filters to be discarded in landfills, others require recycling. Used oil can be sent to a collection center or recycled in-house.
• Coolant. Disposal of used antifreeze into sewer or septic systems is generally banned without pretreatment. In some states it must be recycled or disposed of as a hazardous waste.
• Batteries. Federal and state regulations generally prohibit disposal of lead-acid batteries in landfills or other municipal facilities. They must be delivered to an authorized recycling facility or to the retailer or wholesaler for recycling.
• Parts cleaning. Solvents can't be discharged in sinks or shop drains, and should be wrung out of rags or towels before laundering.
• Refrigerants. Technicians working with refrigerants must be trained according to EPA rules. Refrigerants can't be vented into the atmosphere. Refrigerants must be properly removed or recovered before disposing of old equipment.
• Vehicle painting. Paints and solvents are classified as hazardous by EPA and must be disposed of through proper waste management facilities. Solvents and rags should be stored in closed containers. Emissions from painting operations are regulated in most areas.
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