Montana Pollution
Prevention Program
The Montana Pollution
Prevention Program -
part of the Montana
State University
Extension Service - is a
non-regulatory
technical assistance
program dedicated to
helping small
businesses reduce
waste, increase
efficiency, and achieve
compliance with
environmental
regulations.
CONTENTS
Background . . . . . . . 1
Hazardous Waste . . . 2
- Parts Washer Solvent
- Gun Cleaning Wastes
- Lead Acid Batteries
- Shop Towels/Rags
- Used Oil
- Used Oil Filters
-Absorbents
- Used Antifreeze
- Car Prep Wastes
- Paint Booth Filters
- Paint Wastes
- Aerosol Cans
- Empty Containers
- Distillation
Wastewater . . . . . . . . 7
-Equipment Washing
- Floor Sumps
Air Pollution . . . . . . . 8
- Halogenated Solvents
- AC Systems
List of Contacts . . . 10
BACKGROUND that are not indicated.
In 1997, the Montana State Legislature passed
the Voluntary Environmental Audit Act. This In addition, voluntary best management
law provides limited immunity from civil practices are outlined for each waste stream to
penalty to companies that discover a violation help you reduce waste and liability.
during a self-audit and disclose the violation to
the Department of Environmental Quality GETTING STARTED
(DEQ). Contact the Montana Department of To get the most out of a self-audit:
Environmental Quality for details about the
Voluntary Environmental Audit Act Consider each item carefully and decide
(406) 444-0379. how it may apply to your shop.
Involve your employees when performing
The Montana Pollution Prevention (P2) a self-audit and discuss results with them.
Program developed this checklist specifically Leave nothing to memory. Write down
for body shop owners and managers to help any questions you have and make lists of
them perform a self-audit. It is an industry- items or areas you think need to be
specific supplement to a more comprehensive addressed.
guide we developed, the Montana Voluntary Regulations can be confusing. Ask
Environmental Audit and Pollution Prevention questions. A list of contacts is provided at
Guide. Even if you choose not to participate in the end of this checklist - use it!
the voluntary self-audit process with the DEQ, Keep this checklist on file and review it
this checklist can be useful in helping you and periodically.
your employees review material and
waste management practices. It The Montana Pollution Prevention
highlights waste streams Program offers free, non-regulatory
common to most Montana on-site assistance to help you
auto body repair shops and perform a self-audit. Call toll-free
it provides insight into (888) MSU-6872 for more
areas environmental information or to arrange a site
regulators tend to focus visit.
during inspections.
Many body shop owners and managers might Glossary of Acronyms
ARM - Administrative Rules of Montana
also be interested in a similar checklist we CEG - Conditionally Exempt Generator
developed for vehicle maintenance facilities. CFR - Code of Federal Regulations
Contact our program for more information. DEQ - Department of Environmental Quality
EPA - Environmental Protection Agency
HAP - Hazardous Air Pollutant
ABOUT THIS CHECKLIST HEPA - High-Efficiency Particulate Air
HVLP - High Volume, Low Pressure
The intent of this checklist is to provide a plain-
MCA - Montana Code Annotated
English overview of many of the hazardous MVAC- Motor Vehicle Air Conditioning
waste, air, and water regulations that may apply NRC - National Response Center
to auto body shops in Montana. This checklist OSHA - Occupational Safety 8 Health Admin.
P2 - Pollution Prevention
is by no means comprehensive, and is not POTW - Publicly Owned Treatment Works
intended as a substitute for knowing and RCRA - Resource Conservation & Recovery
understanding the regulations. Act
SAE - Society of Automotive Engineers
UST - Underground Storage Tank
Where appropriate these regulations are VOC- Volatile Organic Compound
referenced, but realize that there may be other
rules, policies, or laws affecting your
operations at the federal, state, or local levels
Every business that generates waste is responsible for determining: (1) whether that waste is hazardous and, if the waste is
hazardous, (2) the monthly generator status of the company.
1. Determine If Wastes Are Hazardous
There are two types of hazardous wastes:
a. Characteristic Hazardous Wastes - These wastes
have one or more of the following characteristics that
distinguish them from other solid waste materials [ARM
17.54.303]:
ignitable - have a flash point less than 1400 F
(examples: mineral spirits, naphtha, xylene)
corrosive - a pH less than 2.0 or greater than 12.5
(example: caustic cleaners)
toxic -contain toxic metals or organics (examples: lead
residue in parts washers, some paints)
reactive - unstable compounds capable of violent
reactions (examples: bleaches, oxidizers)
b. Listed Wastes - These are waste specifically identified
in the hazardous waste regulations. “F-listed” hazardous
wastes are generally spent cleaning solvents containing
10% or more of at least one hazardous chemical and are
automatically considered hazardous waste when spent.
Examples of F-listed wastes are acetone, methyl ethyl
ketone, perchloroethylene, and 1,1,1-trichloroethane.
There are two methods of determining whether a waste is
hazardous:
Knowledge of Process - This method allows business
owners to apply their knowledge of the products and
processes used in the facility to determine whether or not
the wastes generated are hazardous, or, if lab testing is
needed, what type of analysis to use. When applying this
method, remember:
Even non-hazardous products can become hazardous
as wastes depending on the process.
Use each product’s material safety data sheet (MSDS)
to help identify ingredients that might cause the waste
to exhibit the characteristic of a hazardous waste or if
it contains listed wastes.
Waste Analysis - Business owners can have wastes
tested by a credible analytical lab to determine if the
wastes exhibit characteristics of hazardous wastes or
contain listed hazardous wastes. Contact the Montana P2
Program for a list of analytical labs.
2
2. Determine Generator Status
Once you have determined if your wastes are hazardous,
you can calculate how many pounds of each waste you
generate in one month. This is necessary because your
regulatory requirements depend on the total amount of
hazardous waste generation in a one-month period and the
amount of hazardous waste stored on-site. Here are two
methods to calculate the total monthly generation of a
hazardous waste:
Method 1 - Determine the density (pounds per gallon)
of the waste and multiply by the number of gallons.
Refer to Section III of your MSDS (usually called
“physical data”) to determine the product density. If
your MSDS only gives you the specific gravity instead
of density, multiply the number by 8.34 to covert to
pounds per gallon.
Method 2 - Weigh each empty container that will hold
a hazardous waste. (It is important to segregate wastes
to ensure recyclability, and prevent cross-
contamination or dangerous reactions). This is the tare
weight. After one month of filling the containers,
weigh them, subtract the tare weights, add the
hazardous waste weights to determine the amount in
pounds of waste in one month.
Now you can determine your generator classification:
Conditionally exempt generator (CEG) - Generate
less than 220 pounds of hazardous waste a month and
accumulate no more than 2,200 pounds of hazardous
waste on site. CEGs have the fewest requirements of
the three classifications.
Small generator (SG) - Generate between 220 and
2200 pounds per month of hazardous waste and never
accumulate more than 13,228 pounds of hazardous
waste at any time.
Large generator (LG) - Generate more than 2200
pounds of hazardous waste per month.
As a rule, a 55-gallon barrel filled with liquid hazardous
waste weighs about 440 pounds. So in order to be a CEG,
you must generate less than about one half of a drum per
month and accumulate no more than five 55-gallon drums
of hazardous waste. REMEMBER: this includes ALL
hazardous waste generated at the facility. Contact the
Montana DEQ with questions or for more information
about hazardous waste requirements.

Parts Washing Solvents
Parts washer solvents are not considered wastes until they
are spent - that is, when they can no longer be used for
their intended purpose - or unless they remain in a parts
washing unit that is not used for more than 90 consecutive
days [ARM.17.54.308]. Spent parts washing solvents are
often hazardous waste because they exhibit hazardous
characteristics such as corrosivity, low flash points and/or
because they contain more than 10% F-listed solvents such
as 1,1,1-trichloroethane or perchloroethylene. In addition
to health and safety concerns, these chemicals can pose a
serous threat to our environment if improperly managed.
While some parts washer cleaners are nonhazardous as
products, they may become hazardous as waste if they
were contaminated with hazardous materials during use
(such as metals like lead or cadmium, or F-listed hazardous
wastes such as chlorinated solvents found in some brake
cleaners). Some of the requirements for managing
hazardous parts washing solvents include:
Determine if spent solvents are hazardous either by (1)
applying knowledge of the product (say, by using the
MSDS) or (2) having them tested at a lab [ARM
17.54.420].
Never pour any liquid wastes (whether hazardous or
nonhazardous) into a dumpster: Landfills cannot
accept bulk or non-containerized liquid commercial
wastes [ARM 17.50.511].
Never pour used solvents on the ground, or into septic
systems or other systems that discharge wastewater to
subsurface soils [ARM 17.54.402] (see Wastewater
section below).
Never mix solvents with other wastes. Mixing F-listed
hazardous wastes with a non-hazardous waste makes
the whole quantity hazardous [ARM 17.54.330-333].
Keep all paperwork for at least three years [ARM
17.54.425].
If you use chlorinated solvents, such as methylene
chloride, trichloroethylene, and 1,1,1-trichloroethane in
solvent sinks, you are subject to the EPA parts cleaning
regulations [40 CFR Part 63.648] (see Air Pollution
section below).
Any person that uses 20 gallons or more of chlorinated
solvents a year must register with the DEQ. It is also
unlawful to sell or distribute 20 gallons or more of
chlorinated solvent to anyone who does not have proof
of registration [MCA 75-10-451].
If you are a SG or LG:
Hazardous waste must be stored in a container that is
compatible with the substance being stored and has no
signs of leaks or damage from rust or dents. Containers
Environmental Compliance Checklist
For Auto Body Shops
must be labeled and covered except when adding or
removing material [ARM 17.54.421].
Hazardous waste must be hauled by a permitted
hazardous waste transporter [ARM 17.54.403].
(Contact the Montana DEQ or the Montana Pollution
Prevention Program for a list ofpermitted hazardous
waste haulers.)
SGs must not accumulate more than 13,228 pounds -
about thirty 55-gallon barrels - of hazardous waste of
any type on site [ARM 17.54.421].
If you are a CEG:
You must dispose of hazardous wastes at one of the
following: (1) a legitimate recycling facility; (2) a
permitted hazardous waste treatment, storage, or
disposal facility (TSDF); or (3) a licensed Class II
solid waste facility. Wastes must be in a solid state
AND you must obtain the permission of the landfill
owner/operator [ARM 17.54.402]. (Some landfills in
Montana will not accept any commercial hazardous
wastes from CEGs).
CEGs may accumulate up to 2,200 pounds - about
five 55-gallon barrels - of any type of hazardous
waste on-site with no time limit for accumulation. But
if 2,200 pounds is exceeded, the company is then
considered a SG [ARM 17.54.402].
NOTE: Even if you contract a hazardous waste company to
lease and service your parts washer, you are ultimately
responsible for determining whether your waste is
hazardous and, if so, counting the volume changed out
during servicing toward your monthly generation status.
Voluntary Best Management Practices
Avoid F-Listed solvents.
Use the least hazardous products practical. Contact the
Montana P2 Program for information about less
hazardous products.
Treat solvents more like gold, less like water.
Extend parts washer solvent life: use filtration, close
lids, increase dram times to reduce dragout, pre-clean
with non-solvent techniques to remove heavy dirt and
grease.
Monitor solvent quality: service according to need, not
routine.
Avoid using F-listed (chlorinated) solvents. Contact the
Montana P2 Program for information about safer, less-
hazardous alternative solvents.
Store product and waste drums on spill containment
pallets, off the ground, and in a covered area to prevent
corrosion from exposure to moisture. Use spill
containment trays or dikes in case of accidental spills
or releases.
Spray Gun Cleaning Wastes
Montana Pollution Prevention Program
3 MSU Extension Service
The solvents and thinners used to clean spray guns are
typically hazardous because they are ignitable or contain F-
listed solvents.
Determine whether waste solvents and thinners are
hazardous either by applying your knowledge of the
products and processes or by testing them.
Manage hazardous spray cleaning wastes properly (see
Parts Washing Solvents section, p. 3).
Voluntary Best Management Practices
Use an air-powered mechanical or other type of
automatic gun washer. They can retain 90% of the
solvents and vapors, thereby reducing labor and
exposure to solvents.
Use low-VOC cleaning solvents.
Use automatic gun cleaning units. They reduce
evaporative losses, cut worker exposure to solvents,
and save technicians time on cleaning. Recaptured
solvent can be filtered, distilled and reused.
If cleaning guns manually, spray into an enclosed
backdrop to capture atomized solvents.
NEVER spray cleaning solvent in spray booth - this
can make booth filters and arresters ignitable.
Use on-site distillation to recycle and reuse thinner and
solvents. Contact the Montana P2 Program for
information about distillation units.
Clean equipment immediately before waste builds up
and hardens.
Lead Acid Car Batteries
Used car batteries usually contain lead and acid that may
make them hazardous waste when spent. However, lead-
acid batteries that are properly reclaimed (returned to the
supplier or recycled) are exempt from hazardous waste
rules and do not need to be counted toward monthly
hazardous waste generation status [ARM 17.54.309].
If you don’t return lead-acid car batteries to suppliers,
or send them to a recycling facility, then you must
determine whether they are hazardous and manage
them accordingly. Most Montana landfills will NOT
accept used lead-acid batteries from CEGs.
Voluntary Best Management Practices
Store used car batteries off the ground, upright in a
secured, covered location designed to prevent leaks and
temperature extremes.
Keep shipping receipts to demonstrate that you have
recycled.
Do not stack batteries as they may crack.
Always wear safety goggles and gloves when servicing
batteries.
If you drop a battery, neutralize any spilled acid with
baking soda or lime.
Shop Towels/Rags
Environmental Compliance Checklist
For Auto Body Shops
Reusable, cloth shop towels are not considered hazardous
waste if they are destined for laundering. However, this
policy applies only to “unsaturated” shop towels that are
used and managed properly. A shop towel is considered
“saturated” if it contains free liquid as determined by the
paint filter liquid test [EPA SW-846]. In this test, a shop
towel is placed in a paint filter; if any portion of the
material passes through and drips from the filter within a
five-minute test period, the material contains free liquid. If
a shop towel is saturated with hazardous solvents or inks, it
must be managed as hazardous waste. To ensure that
reusable, launderable shop towels do not become
hazardous waste:
Do not generate saturated shop towels. Doing so may
subject shop towels to hazardous waste regulations.
Also, laundry facilities have the right to refuse
collection of shop towels if they are saturated.
NEVER dispose of hazardous wastes by pouring them
onto shop towels.
Disposable rags are hazardous waste if they contain
any F-Listed hazardous wastes [ARM 17.54.330-333],
or if they exhibit the characteristics of a hazardous
waste [ARM 17.54.320].
Saturated shop towels are considered “liquid” waste.
Liquid wastes of all types are prohibited from landfills
[ARM 17.54.502(28)]
Voluntary Best Management Practices
Avoid disposable shop rags - the shop towel policy
only applies to reusable, launderable shop towels.
Avoid generating saturated shop towels! Purge excess
solvent from shop towels by mechanical wringing or by
hand (be sure to use appropriate personal protective
clothing). Reuse captured solvent if possible.
Avoid F-Listed solvents (such as perchloroethylene,
and toluene). Besides health and safety concerns, these
chemicals can adversely affect the ability of the
launderer to safely and effectively process shop towels
for reuse.
Reduce the amount of solvent you use on shop towels.
For your own protection against liability, keep records
to verify how and where shop towels are disposed of or
recycled.
Keep shop towel containers covered to reduce
evaporation, and clearly labeled “used shop towels.”
Used Oil
Used oil regulations in Montana were adopted from the
federal regulations, codified in the Used Oil Standards, 40
CFR Part 279. Under these standards, used oil is exempt
from hazardous waste regulations if it is destined for
“beneficial use” such as recycling, reuse, or burned on-site
for energy recovery. The standards are meant to encourage
recycling and prevent mismanagement of used oil. They
prohibit practices that have posed the greatest risks to
human health and the environment in the past, and require
Montana Pollution Prevention Program
4 MSU Extension Service
 such as “used antifreeze” or “waste antifreeze.”
Consider an antifreeze recycling unit. Contact the
Montana P2 Program for product information.
If you cannot justify the expense of a unit, consider
partnering with other shops in the community to share
one.
Store used antifreeze in its own container, segregated
from other wastes.
Car Prep and Body Work Wastes
Masking tape, overspray paper are generally not considered
hazardous waste once the paint has cured on these wastes.
However, paint stripping and sanding operations may
generate hazardous waste if the paint has a high metals
content (this is very common in older vehicles and military
vehicles), and/or if any solvents used in stripping are
hazardous (they often contain F-listed solvents such as
methylene chloride). These types of wastes may become a
hazardous waste and therefore would have to be counted
toward monthly quantity and managed properly.
Apply knowledge or test body work wastes to determine
whether they are hazardous waste. Remember that such
wastes as bead blasting media might be hazardous as
well if contaminated by heavy metals from the paint.
Do not mix hazardous filler dust with wash waters,
paint waste, or sludge - this could render the entire
quantity hazardous.
Voluntary Best Management Practices
Use the least amount of masking tape and paper
practical.
Choose paints that do not contain heavy metals.
When working on older cars, assume the paint is metal-
based and keep all work and wastes segregated from
other operations. Use high-quality HEPA filter dust
masks to reduce exposure to metals dust. Carefully
collect and segregate this dust and waste to avoid
contaminating other waste streams.
Where practical, reduce prep wastes and labor by using
spray on, peel-off booth compound.
Paint Booth Filters
Paint booth filters may or may not be hazardous, depending
on how often they are changed, if they are dry, and if they
contain paint with heavy metals such as chromium, nickel
or lead.
Apply knowledge or test booth filters to determine
whether they are hazardous.
Hazardous filters must be weighed counted toward your
monthly generator quantity and managed properly
according to your generation status. CEGs must have
the landfill operator’s permission to dispose of
hazardous filters in a landfill. Filters MUST be dry.
Voluntary Best Management Practices
NEVER pull out filters wet. This can create ignitability
potential - allow them to dry in place as much as
Environmental Compliance Checklist
For Auto Body Shops
possible (say, over the weekend).
NEVER spray gun cleaner solvents or thinners in the
booth, again because of ignitability concerns.
Paint and Coating Waste
Off-spec or waste paint may be hazardous because of
toxicity from heavy metals or ignitability from solvent
additives. Water-based paints can be less hazardous and
may help reduce volatile organic compounds (VOC)
emissions. It also facilitates the use of water as a possible
substitute for solvents in cleaning equipment. But be aware
that even water-based paint waste may be hazardous when
spent. Paint is not hazardous if it is dry.
Determine whether liquid waste paint hazardous.
Never dispose of liquid hazardous paint waste down
any storm drain, septic system or dry well.
Manage liquid hazardous paint properly (see Parts
Washing Solvent Wastes section, p.3).
Voluntary Best Management Practices
Dry paint is not hazardous, so keep waste paint
segregated from other wastes to avoid generating
unnecessary volumes of hazardous waste.
Consider a computerized paint mixing system to reduce
the amount of off-spec paint and disposal costs.
Use water-based coating where practical and stay
informed about new developments in water-based top
coats.
Use smaller paint cups when applicable to avoid over-
mixing paint and reducing the need to clean.
Do not get in the habit of mixing a standard amount.
Mix the smallest quantity possible.
Don’t buy more paint products than you need. The less
paint on the shelf, the less potential waste.
Aerosol Cans
Many spray cans contain F-listed hazardous wastes, such
as 1,1,1-trichloroethane. Mixing F-listed hazardous waste
with a non-hazardous waste (for instance, spraying aerosol
product into parts washer) makes the whole quantity
hazardous.
Any “empty” aerosol can may be put in the garbage. An
aerosol can is considered “empty” only if it contains no
discernible product. Body shops sometimes generate “non-
empty” aerosol cans that must be disposed of (this is
common if a tip breaks or the can otherwise becomes
inoperable).
Determine whether contents of non-empty aerosol cans
are hazardous either by knowledge (i.e., by using the
MSDS) or by testing.
Non-empty cans containing hazardous substances are
hazardous waste and must be properly managed.
Obtain permission from landfill operator before
disposing of non-empty cans (even if it is a non-
hazardous waste). Many landfills will not accept any
Montana Pollution Prevention Program
6 MSU Extension Service
regulations. Contact the EPA-Helena Office at (406) 441-
1140 for assistance with Class V wells.
Municipal Sewers
Most commercial drains are connected to the city sewer
(also called the publicly owned treatment works [POTW])
where it is treated prior to discharge into the environment.
However, the treatment capacity of POTWs is limited and
is generally not designed to treat hazardous discharges such
as solvents, toxic metals, or ignitable wastes. Discharge of
commercial waste to municipal sewers is regulated by the
POTWs at the local level. Six Montana wastewater
treatment facilities have implemented “pre-treatment”
programs to more closely monitor and regulate commercial
discharge into sewers. All POTWs have the authority to
issue permits and enforce discharge limits. Companies that
discharge commercial wastewater to sewers should contact
their local POTW to ensure compliance [ARM 17.30, et
seq].
Table 1. Water Quality: Who Regulates What in Montana?
Wastewater Who regulates Applicable
system them? regulations
City Sewer POTW ARM 17.30,
et seq.
Class V Well EPA- Helena 40 CFR Parts
(septic system or Office 144 and 146
any drainfield)
Storm drain State DEQ, ARM 17.30.7;
Water Protection 40 CFR Part
Bureau 144.
NOTE: Discharges of hazardous waste to this type of system are considered unlawful
disposal of hazardous waste and are regulated by DEQ Air & Waste Management
Bureau [MCA 75-10-402].
Equipment Washing
Shops that discharge significant amounts of wastewater
may need a discharge permit from the DEQ, and in some
cases may be required to utilize water recirculation systems
to reduce wastewater generation. If you are connected to a
Class V well, your washwater discharge is strictly
regulated by the EPA, and must meet drinking quality
standards. Contact the Montana Pollution Prevention
Program for information about wastewater treatment and
recirculating techniques and systems.
Floor sumps/Grate-covered channels
Many shops have floor channels that collect water from the
shop. These sumps and channels are generally shoveled out
periodically. The sludge generated during this process must
be characterized prior to disposal to determine whether or
not it is hazardous. (Recall that characterization may be
made based on generator knowledge or by testing).
Hazardous sludge must be counted toward your monthly
Environmental Compliance Checklist
For Auto Body Shops
generation status. If sludge is non-hazardous, sludge must
be dry prior to disposal in a landfill; some landfills (such as
Billings) require companies to test their sump sludge
before they will accept it. Contact landfill operator for
permission.
Voluntary Best Management Practices
Try to run a dry shop. Don’t use the hose as a broom.
Keep all hazardous wastes out of sumps, floor drains
and storm drains. This usually means taking extra
precautions to ensure that shop wastes NEVER reach
the floor so they don’t get washed down the drain.
Prevent spills. Use spill containment basins around all
machines and around all solvent and hazardous waste
storage containers. Spill containment trays should be
capable of holding at least 110% of the container
capacity, and should be coated with sealer.
Use spigots and pumps and funnels to dispense new
solvent and funnels when transferring wastes to storage
containers to avoid spills.
Carefully inspect all product containers for damage,
leaks or corrosion before accepting from vendors.
Inspect equipment regularly for leaks, paying careful
attention to gaskets, hose couplings, and pumps.
Never store chemicals on high shelves.
Any materials stored outside, including drums, trash,
tires, and parts should be protected from snow and rain
under a tarp or a roof and should be kept off the ground.
Dumpsters must be kept closed to the ensure water will
not enter; landfills cannot accept any liquid.
Untreated concrete is permeable and will not prevent
chlorinated solvents from leaching into the ground.
Avoid chlorinated solvents. If you must use them,
consider coating floors with epoxy sealant.
Air quality is one of the biggest concerns of industrial
regulation today. EPA establishes standards for air quality,
and individual states are responsible for meeting those
standards. The Department of Environmental Quality
(DEQ) Air and Waste Management Bureau oversees air
requirements in Montana. Of primary concern to air quality
are volatile organic compounds (VOC), which are highly
evaporative compounds that can cause health problems and
contribute to the formation of smog; and hazardous air
pollutants (HAPS) which can cause severe health problems
in humans.
There are currently no specific air quality regulations that
directly impact the autobody repair industry. However, the
Montana DEQ is currently considering a regulation that
Montana Pollution Prevention Program
8 MSU Extension Service
would require all auto body shops to have a spray booth,
limit their VOCs and keep close records of spray
operations. Forward-thinking body shops are taking steps
now to reduce their VOC and HAP emissions. For
example, HVLP spray guns can reduce the amount of
overspray, and using less low-VOC paints, sealers, and top
coats, and reducing solvent use can reduce air emissions.
Contact the Montana P2 Program for information about
reducing emissions at your facility.
Spray Booths
Article 45 of the 1994 Uniform Fire Code establishes
requirements for auto body repair shops for the
construction, use, and maintenance of spray booths. Nearly
every shop that does spraying will be required to install a
spray booth. Contact the state Fire Marshal’s Office and
your local fire department for specific requirements that
may apply to the use and maintenance of a commercial
spray booth.
Halogenated Parts Washing Solvents
In December 1994, the EPA issued national regulations to
control air emissions from solvent cleaning machines that
use chlorinated solvents.
The rules require facilities to submit a special EPA
notification report and they mandate the following work
practices:
Keep parts washer lids closed at all times except
when cleaning
Collect and store all waste solvent in closed
containers.
Reduce pooling of solvent on and in parts.
Do not fill cleaning machine above till line.
Spills must be wiped up immediately. The wipe rags
must be stored in covered containers.
When cover is open, room drafts must be controlled.
Do not clean absorbent materials.
Voluntary Best Management Practices
Switch to less hazardous solvents. Contact the Montana
Pollution Prevention Program for information about
alternative products and equipment.
Motor Vehicle Air Conditioning
Refrigerants from motor vehicle air conditioners (MVACs)
Environmental Compliance Checklist
For Auto Body Shops
such as CFC- 12 (also called Freon or R- 12) are among the
largest sources of chlorofluorocarbons (CFCs) in the
United States. The EPA issued rules in the Code of Federal
Regulations (40 CFR 82.82) to implement Section 608 of
the Clean Air Act Amendments of 1990. The rules affect
release and disposal of R-12, maintenance and repair
procedures of refrigeration equipment, and recordkeeping
and sale of R-12 refrigerants.
Venting R-12 refrigerant to the atmosphere is strictly
prohibited under the EPA rules.
Technicians must follow carefully the mandated
procedures for servicing MVAC systems.
Technicians that perform a service with the potential to
release refrigerant must be trained and certified by an
EPA-approved Section 609 program.
Certification statements for Montana companies must
be on file at the U.S. EPA regional office in Denver.
Are R-12 refrigerant distribution requirements upheld?
The sale of R- 12 (regardless of container size) can
ONLY be made to (1) a certified technician, OR (2)
someone purchasing the refrigerant for resale.
Records of all refrigerant sales must be maintained for
at least three years, including the name of purchaser,
date of sale, and quantity purchased. Each pound
purchased must be accounted for. Names of certified
technicians on site must also be maintained.
Recycling and/or recovery equipment cannot be
modified after purchase.
NEVER mix R-12 and R-134a refrigerants!
All CFC recovery and/or recycling equipment must be
EPA-approved. To be approved by EPA, equipment
must meet the Society of Automotive Engineers (SAE)
standards for approval and be properly labeled.
Recover-only equipment must meet SAE standard
J-2209. Recover/recycle equipment must meet SAE
standard J- 1991.
Montana Pollution Prevention Program
9 MSU Extension Service
Montana State University, U.S. Department of Agriculture and Counties Cooperating. MSU is an equal opportunity/
affirmative action institution. The programs of the MSU Extension Service are available to all people regardless of
race, creed, color, sex, disability, or national origin. Issued in furtherance of cooperative extension work in agriculture
and home economics, acts of May 8 and June 30, 1914, in cooperation with the U.S. Department of Agriculture, David
Bryant, Director of Extension, MSU, Bozeman.