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Run: Antifreeze and Coolant Recycling Collection Tank Audit

Audit used antifreeze and coolant collection tanks for labeling, containment, condition, PPE, and pickup records before a leak, mix-up, or compliance gap tur...

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Audit Setup and Tank Identification

Record the specific location or bay number where the collection tank is situated.
Record the rated capacity of the used antifreeze collection tank.
Select the tank construction material.
Record the date the tank was last serviced or emptied by the recycling vendor (e.g., GFL Environmental, Cleanaway).
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

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).
Tanks storing used antifreeze managed as universal waste must be labeled per EPA 40 CFR 273.14 (small quantity) or 273.34 (large quantity).
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).
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

Open or unsecured tanks create spill and contamination risk. Tanks must remain closed except during filling or emptying.
Inspect all sides and the bottom for physical damage that could compromise containment integrity.
Check the base, fittings, drain valve, and fill port for evidence of leakage. Any active leak is an immediate corrective action item.
Estimate the current fill level as a percentage of rated capacity. Tanks should not exceed 90% to allow for thermal expansion.
Check that all fittings are tight, valves operate correctly, and vent caps are not blocked or missing.

Secondary Containment and Spill Prevention

Secondary containment must be capable of holding 110% of the tank's volume per EPA SPCC guidance and good practice for hazardous waste storage.
Accumulated liquid in containment indicates a prior leak or spill that must be documented and addressed.
A spill response kit must be immediately accessible per OSHA 29 CFR 1910.120(q) emergency response requirements.

PPE and Employee Safety

Used antifreeze may contain heavy metals and other contaminants. Chemical-resistant gloves are required per OSHA 29 CFR 1910.138.
Splash risk during filling or transfer requires eye protection per OSHA 29 CFR 1910.133.
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

Recycling pickup records and waste manifests must be retained for a minimum of 3 years per EPA 40 CFR 273.19 / 273.39.
Confirm the vendor (e.g., GFL Environmental, Cleanaway, or equivalent) holds current state or local permits for used antifreeze recycling.
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.

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