Machine Coolant Federal Regulations 

(Note:  We have corrected the government list to comply with standard chemical notation where we felt it was necessary.  We have included both.) 

We are not attorneys.  We believe this to be a good compliance plan but we do not take any responsibility for its use, misuse or anything else.  The laws change frequently.  Consult an attorney or other expert.  You can also refer back to our Machine Coolant Index for a MSDS and related articles on Machine Coolant. 

Example:  Carbide Grinding Operations

Disposing of carbide sludge, swarf and filters  

What follows is based on U.S, and Canadian laws.  Individual states, provinces, cities, etc. may have their own regulations.   We believe that this information will apply in 98% of all cases but we cannot guarantee it 100% in any individual area. 

Not Hazardous Waste 

If you collect your waste coolant, swarf, etc put it in barrels or other containers labeled: 

Carbide Grinding Coolant

Held for Recycling 

In most places material held for recycling is not a hazardous waste since it is not waste at all.  The sign can be made from a sheet of plain 8 1/2 x 11 paper using a magic marker and scotch taped to the container.   We use peel & stick sheets we run through the printer. 

Sell as much as you can. 

Sell the collected swarf where you sell scrap carbide.  Empty the bag filter out and let the collected swarf dry.  The scrap dealer is primarily interested in the cobalt.  There is not a whole lot of money in it but it is generally easier and cheaper than paying to have it hauled away. 

Classify the filter properly

The filter is full of carbide, diamond, cobalt binder, oil and grease.  Typically it is legal to call it an oil filter.  If it is an oil filter, (which it is since it does filter oil) you can dispose of it as service stations dispose of oil filters from an automobile.  Often this is a matter of letting it drain, crushing the filter and then throwing it in the trash. 

Recycle the coolant

Quite often having the coolant recycled can save a lot of money.  A good filter system will keep the coolant clean to where it needs to be replaced once a year.  Have the old coolant recycled and use it for make up coolant over the course of a year. 

Hazardous waste

Congress defined "hazardous waste" in the Resource Conservation and Recovery Act (RCRA) as a solid waste, or combination of solid wastes which, because of its quantity, concentration, or physical, chemical, or infectious characteristics may:

1.  Cause or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible illness;

2.   Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed; 

Hazardous wastes are defined in terms of properties of a solid waste. It should be stressed that a solid waste need not be a solid; it can also be a liquid, semisolid, or a contained gaseous material. To correctly manage wastes, facilities must first determine if wastes generated by their operations are hazardous or non hazardous. A solid waste is hazardous if it meets one of three conditions:

1.  Exhibits one or more characteristics (ignitability, corrosivity, reactivity, or toxicity) of a hazardous waste.

2.  Has been identified and listed as a hazardous waste by the Environmental Protection Agency (EPA).

3.  The waste consists of a mixture containing a hazardous waste and a nonhazardous solid waste. 

Characteristic Wastes

Characteristic hazardous wastes exhibit one or more of the following four characteristics: 

1.  Ignitability

A solid waste exhibits the characteristic of ignitability if a representative sample of the waste has any of the following properties:

      a. Liquid with a flash point less than 140' F (60' C

      b. Non liquid and is capable, under normal conditions, of spontaneous and sustained combustion;

     c.  Ignitable compressed gas per Department of Transportation (DOT) regulations; or

     d. Oxidizer Per DOT regulations. 

EPA included ignitability as a characteristic of wastes that could cause fires during transport, storage, or disposal. Examples of ignitable wastes include many waste solvents such as mineral spirits or naphtha. Ignitable hazardous wastes have the EPA hazardous waste number DOO I. 

2.  Corrosivity

A solid waste exhibits the characteristic of corrosivity if a representative sample of the waste has any of the following properties:

     a.  Liquid with a pH less than or equal to 2 or greater than or equal to 12.5; or

     b.  Liquid and corrodes steel at a rate greater than 1/4 inch per year at a test temperature of 130' F 

EPA selected pH as an indicator of corrosivity because wastes with high or low pH can directly affect human health, the environment, react dangerously with other wastes, or cause toxic contaminants to migrate from certain wastes. Examples of corrosive wastes include acidic wastes and spent pickling liquor (used to clean steel during manufacture). Corrosive hazardous wastes have the EPA hazardous waste number D002. 

3.  Reactivity

A solid waste exhibits the characteristic of reactivity if a representative sample of the waste has any of the following properties:

     a.  Normally unstable and readily undergoes violent change without detonating;

     b.  Reacts violently with water;

     c.  Forms a potentially explosive mixture with water;

     d.  Generates toxic gases, vapors, or fumes when mixed with water

     e.  Contains cyanide or sulfide and generates toxic gases, vapors, or fumes at a pH between 2 and 12.5

     f.  Listed by the DOT as a forbidden explosive or as a Class A explosive or a Class B explosive 

Reactivity is a characteristic that identifies unstable wastes that can pose a problem, such as an explosion, at any stage of the waste management cycle. An example of a reactive waste is used cyanide solution. Reactive wastes have the EPA hazardous waste number D003. 

4.  Toxicity

A solid waste exhibits the characteristic of toxicity if, by using designated test methods, the liquid waste or extract from a representative sample contains any of the following contaminants at concentrations equal to or greater than the corresponding regulatory limit. A specific laboratory analytical procedure, identified as the Toxicity Characteristic Leaching Procedure (TCLP), is used to determine the toxicity of a waste. A waste that exhibits the characteristic of toxicity has an EPA hazardous waste number that corresponds to the toxic contaminant(s), which cause it to be hazardous. 

Many small businesses such as machine shops generate fluids that may contain heavy metals. Heavy metals refers to metals such as arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver. These metals are hazardous due to their toxic effects on human health and the environment. Metalworking fluids and other wastes that may contain these metals are potential hazardous wastes and must undergo TCLP analyses in order to make a hazardous/nonhazardous determination. 

The EPA has specifically listed over 400 wastes, which are considered hazardous because they exhibit a hazardous waste characteristic or contain toxic constituents that are harmful to human health and the environment. These include wastes generated from manufacturing processes and discarded commercial chemical products. Examples of some common listed hazardous wastes include toluene, methyl ethyl ketone, methylene chloride and xylene.

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