Every day, materials leave your dealership. Used absorbents. Sludge from floor drains. Sanding dust. Paint booth filters. Spent solvents. Aerosol cans. They go into a drum, a tote or a dumpster — and operations move on. But here’s the uncomfortable question: Do you know, with documentation to prove it, whether any of that waste is legally considered hazardous? Because under federal EPA regulations, “I don’t know” is not a defense. Most Dealers Aren’t Trying to Cut Corners Dealership leaders are focused on customers, technicians, inventory and profitability. Waste disposal often feels routine — handled the same way it has for years. The risk isn’t intentional wrongdoing; it’s assumptions. Many common dealership waste streams can qualify as hazardous under federal law. And unless a proper hazardous waste determination has been completed and documented, simply throwing that material in the trash may be considered illegal disposal. Regulators don’t ask whether the waste looked hazardous; they ask for your documentation. The Waste Streams That Create Risk You don’t need a large operation to generate potentially hazardous waste. Common dealership waste streams include: • Certain fuels, oils and shop chemicals • Used absorbents and spill cleanup materials • Aerosol cans • Sludge from floor drains or oil/water separators • Shop rags • Lithium-ion batteries Hazardous Waste Disposal Rules Dealerships Can’t Afford to Ignore By Zach Pucillo, EHS Compliance Manager, KPA 19 ILLINOIS AUTOMOBILE DEALER NEWS
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