A Penske Full-Service Lease Reduces Automotive Fluid Disposal Risks

Regular maintenance of Class 8 vehicles requires replacing and removing fluids to keep vehicles running, but those used fluids must be disposed of correctly and documented from cradle to grave. That process can be complicated, requiring both time and money. What’s more, those that generated the waste can face penalties if fluids aren’t properly disposed.

As part of its full-service leases, Penske handles all maintenance for its customers, as well as the disposal process of used fluids, creating a seamless process for private fleets.

Disposal of Materials

All automotive fluids, including oil, antifreeze and brake fluid, are considered regulated wastes, and those that handle them are considered waste generators. It is the waste generators’ responsibility to manage the disposal of the fluids properly and track their disposal throughout the entire cycle, which includes ensuring there is a paper trail of how much was generated, how much was picked up, who picked it up, when it was picked up and where it went. What’s more, records have to be maintained on-site for three years.

Because the burden is on the generator to prove the who, what, when, where, why and how associated with waste disposal, Penske has created a team to monitor the process.

As part of its processes, Penske performs financial and environmental compliance audits of all its oil vendors that pick up automotive fluids across North America. That allows Penske to monitor how the vendors manage the automotive fluid waste once it gets into their hands. Even though the vendor has taken possession of it, the waste belongs to Penske. If a vendor mismanaged the fluids and disposed of them incorrectly, the burden is placed on the generator to ensure it is cleaned up, which could result in excessive costs and penalties.

In addition to carefully evaluating its vendors that pick up waste, Penske provides specific spill-response training to its diesel technicians, so they know how to clean up and report an issue properly.

Specific State Requirements

Some states, such as California and Massachusetts, have additional compliance requirements because they designate used oil as hazardous waste. A federal regulation took effect on July 1 requiring those disposing of hazardous waste to utilize an online manifest program and generate a manifest when waste is picked up.

Manifesting has been required for the past 30 years and historically involved a lot of paper. The e-manifest was designed to eliminate the piles and piles of paper companies were expected to generate and store, but it brought a new fee. Every time there is a pickup, the e-manifest results in a $7 charge if locations file all documentation electronically, $15 if they use all paper or $10 if they use a combination of both.

There is other automotive waste in California that is designated as hazardous, such as some filters and anti-freeze.

The Role of Recycling

To reduce its environmental impact, Penske ensures that all of the used oil and metal filters go to facilities where they can be recycled, turning them from disposed waste streams to recycled waste streams.

November 2018