State Environmental Faqs


714/744 P STREET
P.O. BOX 942732
SACRAMENTO. CA 94234-7320

(916) 322-3670


January 18, 1990

Mr. John Randall
Hi-Tech Ind.,Inc.
17029 Devonshire St. #124
Northridge, CA 91325-1679

Dear Mr. Randall:



This is in response to your letter dated November 21, 1989. The questions you have posed regarding the recycling of waste anti-freeze will be answered in the sequence in which they were asked.

Question 1:

What are the laws governing the disposal of used anti-freeze?


In the state of California, waste anti-freeze (coolant coming out of an automobile) is considered a hazardous waste and must be managed as such according to Chapter 6.5, Health and Safety Code (HfSC), and Title 22, Article 11, California Code of Regulations (CCR).

Question 2:

1. If a customer chooses to provide an "onsiten recycling service to one of his customers, would there be laws or regulations governing that Service?

2. Which laws, how about for his own use, do they differ?

3. How do they differ?


If your company were to provide this service utilizing a device which is transported to a job site to recycle a hazardous waste, the company providing the service would be exempt. This is in keeping with the H&SC Section 25143.2.

Mr. John Randall

Page 2

If the company were to buy this unit for their own recycl ing needs , according to Health and Safety Code 25143.2(c) (2) (A) (B) (C), the company may be exempt in that they would be recycling their own wastes on-site where the wastes are generated. For the purposes of recycling, there is in no practical difference. If the TTU was for treating hazardous wastes not for recycling purposes, then the TTU would need to be fully permitted.

Question 3:

How and where would our customers dispose of the used contaminated filters?


Disposal of such materials must be discussed with the Departments Waste Evaluation Unit (916) 322-4233. A determination is made as how to best dispose or treat this new waste.

Question 4:

What are the current and proj ected laws pertaining to the transportation of used anti-freeze?


Regulations for the transportation of hazardous waste is found in Title 22, Article 6.5, CCR. The generators management of hazardous waste is found in Title 22, Article 6, CCR. The Department has a Transportation Unit which may aid you in answering many of your transportation questions.

Question 5:

1. What licenses are required?

2. How are they obtained?


a. For purposes of recycling, the "service" company using a TTU, need not be permitted for this purpose. The company may want to ask the Transportation Unit regarding the transport of this unit. For the generator using this service or for their own use, no permit is required.

Mr. John Randall

Page 3

b. Contact your regional office. Contact Headquarters.
Toxic Substances Control Program
TSCP Facilities Permitting Unit Transportation Unit
Region 3/BURBANK Headquarters
1405 San Fernando Blvd. 714/744 P Street
Burbank, CA 91504 P.O. Box 942732

(818) 567-3000 Sacramento, CA 94234-7320

(916) 324-2428

Question 6:

How can we find out what Federal Laws apply?


Most information can be found in the Code of Federal Regulations (CFR) Title 40. If you need to talk to someone, call EPA's Resource Conservation and Recovery Act (RCRA) Hotline at 1-800-368-5888.

Question 7:

What are the laws for reselling recycled anti-freeze?


First, this is dependent upon if the TTU unit is considered exempt. Then, if the waste anti-freeze which has been recycled through the unit, can be used again as a product it will no longer be considered a waste and thus not subject to the hazardous waste management regulations.

If you have any questions regarding this letter, you may contact

me at (916) 322-4742.


Patrick F. Rodriguez
Alternative Technology Division
Toxic Substances Control Program
cc: Robert McCormick

Toxic Substances Control Program
714/744 P Street
P.O. Box 942732
Sacramento, CA 94224-7320