Antifreeze and Coolant Recycling Collection Tank Audit

Verifies that used antifreeze and coolant collection tanks are properly labeled, stored, and maintained in compliance with OSHA, NFPA, and EPA standards. Suitable for auto parts stores, service centers, and recycling facilities.

Audit Setup and Tank Identification

• Tank location / bay number
  Record the specific location or bay number where the collection tank is situated.
• Tank capacity (gallons)
  Record the rated capacity of the used antifreeze collection tank.
• Tank material / type
  Select the tank construction material.
• Date of last service / pickup
  Record the date the tank was last serviced or emptied by the recycling vendor (e.g., GFL Environmental, Cleanaway).
• Recycling vendor name on file
  Confirm that a licensed recycling vendor (e.g., GFL Environmental or equivalent) is contracted and their contact information is posted near the tank.

Tank Labeling and Signage

• Tank is labeled 'USED ANTIFREEZE' or 'USED COOLANT' in clearly legible text
  The primary label must identify the contents as used antifreeze or used coolant. Labeling is required under OSHA 29 CFR 1910.1200(f) and EPA universal waste rules (40 CFR Part 273).
• Label includes 'HAZARDOUS WASTE' or 'UNIVERSAL WASTE' designation as applicable
  Tanks storing used antifreeze managed as universal waste must be labeled per EPA 40 CFR 273.14 (small quantity) or 273.34 (large quantity).
• Accumulation start date is marked on the tank or attached label
  The date accumulation began must be clearly marked. Small quantity handlers must ship within one year; large quantity handlers within 90 days (EPA 40 CFR 273).
• GHS/HazCom label or SDS reference is posted or attached near the tank
  A Safety Data Sheet (SDS) for used antifreeze/ethylene glycol must be accessible per OSHA 29 CFR 1910.1200(g). A GHS label or SDS reference posted at the tank satisfies this requirement.

Tank Physical Condition and Integrity

• Tank lid or cap is present, closed, and secured when not in use
  Open or unsecured tanks create spill and contamination risk. Tanks must remain closed except during filling or emptying.
• Tank shows no visible cracks, bulges, or structural deformation
  Inspect all sides and the bottom for physical damage that could compromise containment integrity.
• No active leaks, drips, or staining observed on or around the tank
  Check the base, fittings, drain valve, and fill port for evidence of leakage. Any active leak is an immediate corrective action item.
• Current fill level (% of capacity)
  Estimate the current fill level as a percentage of rated capacity. Tanks should not exceed 90% to allow for thermal expansion.
• Fittings, valves, and vent caps are in good working condition
  Check that all fittings are tight, valves operate correctly, and vent caps are not blocked or missing.

Secondary Containment and Spill Prevention

• Secondary containment (berm, drip pan, or containment pallet) is present under or around the tank
  Secondary containment must be capable of holding 110% of the tank's volume per EPA SPCC guidance and good practice for hazardous waste storage.
• Secondary containment is free of accumulated liquid, debris, or standing antifreeze
  Accumulated liquid in containment indicates a prior leak or spill that must be documented and addressed.
• Spill kit (absorbent, PPE, disposal bags) is accessible within 10 feet of the tank
  A spill response kit must be immediately accessible per OSHA 29 CFR 1910.120(q) emergency response requirements.

PPE and Employee Safety

• Chemical-resistant gloves (nitrile or equivalent) are available at the tank station
  Used antifreeze may contain heavy metals and other contaminants. Chemical-resistant gloves are required per OSHA 29 CFR 1910.138.
• Eye protection (splash goggles or face shield) is available at the tank station
  Splash risk during filling or transfer requires eye protection per OSHA 29 CFR 1910.133.
• Employees handling used antifreeze have received HazCom / Right-to-Know training
  Training records must be on file per OSHA 29 CFR 1910.1200(h). Verify training is current (within the past 12 months or upon new chemical introduction).

Recordkeeping and Vendor Compliance

• Waste pickup / manifest records are on file for the past 12 months
  Recycling pickup records and waste manifests must be retained for a minimum of 3 years per EPA 40 CFR 273.19 / 273.39.
• Recycling vendor is licensed / certified for used antifreeze handling in this jurisdiction
  Confirm the vendor (e.g., GFL Environmental, Cleanaway, or equivalent) holds current state or local permits for used antifreeze recycling.
• No mixing of used antifreeze with other waste streams (oil, solvents, etc.) is evident
  Mixing used antifreeze with other hazardous waste may reclassify it from universal waste to listed hazardous waste, triggering stricter disposal requirements under EPA 40 CFR Part 261.