HAZARDOUS WASTE DISPOSAL THE HIDDEN COMPLIANCE RISK AT YOUR DEALERSHIP Every day, materials leave your dealership: used absorbents, sludge from floor drains, sanding dust, paint booth filters, spent solvents, aerosol cans, etc. 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, “not knowing” 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’s been handled for years. The risk isn’t intentional wrongdoing. It’s assumption. 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 The Rules Dealerships Can’t Afford to Ignore BY ZACH PUCILLO CSP, CHMM, REGULATORY DIRECTOR, KPA 16
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