Montana Pollution Prevention Program. that are not indicated.

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1 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 Hazardous Waste 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 Equipment Washing - Floor Sumps Air Pollution Halogenated Solvents - AC Systems List of Contacts BACKGROUND In 1997, the Montana State Legislature passed the Voluntary Environmental Audit Act. This law provides limited immunity from civil penalty to companies that discover a violation during a self-audit and disclose the violation to the Department of Environmental Quality (DEQ). Contact the Montana Department of Environmental Quality for details about the Voluntary Environmental Audit Act (406) The Montana Pollution Prevention (P2) Program developed this checklist specifically for body shop owners and managers to help them perform a self-audit. It is an industryspecific supplement to a more comprehensive guide we developed, the Montana Voluntary Environmental Audit and Pollution Prevention Guide. Even if you choose not to participate in the voluntary self-audit process with the DEQ, this checklist can be useful in helping you and your employees review material and waste management practices. It highlights waste streams common to most Montana auto body repair shops and it provides insight into areas environmental regulators tend to focus during inspections. Many body shop owners and managers might also be interested in a similar checklist we developed for vehicle maintenance facilities. Contact our program for more information. ABOUT THIS CHECKLIST The intent of this checklist is to provide a plain- English overview of many of the hazardous waste, air, and water regulations that may apply to auto body shops in Montana. This checklist is by no means comprehensive, and is not intended as a substitute for knowing and understanding the regulations. Where appropriate these regulations are referenced, but realize that there may be other rules, policies, or laws affecting your operations at the federal, state, or local levels that are not indicated. In addition, voluntary best management practices are outlined for each waste stream to help you reduce waste and liability. GETTING STARTED To get the most out of a self-audit: Consider each item carefully and decide how it may apply to your shop. Involve your employees when performing a self-audit and discuss results with them. Leave nothing to memory. Write down any questions you have and make lists of items or areas you think need to be addressed. Regulations can be confusing. Ask questions. A list of contacts is provided at the end of this checklist - use it! Keep this checklist on file and review it periodically. The Montana Pollution Prevention Program offers free, non-regulatory on-site assistance to help you perform a self-audit. Call toll-free (888) MSU-6872 for more information or to arrange a site visit. Glossary of Acronyms ARM - Administrative Rules of Montana CEG - Conditionally Exempt Generator CFR - Code of Federal Regulations DEQ - Department of Environmental Quality EPA - Environmental Protection Agency HAP - Hazardous Air Pollutant HEPA - High-Efficiency Particulate Air HVLP - High Volume, Low Pressure MCA - Montana Code Annotated MVAC- Motor Vehicle Air Conditioning NRC - National Response Center OSHA - Occupational Safety 8 Health Admin. P2 - Pollution Prevention POTW - Publicly Owned Treatment Works RCRA - Resource Conservation & Recovery Act SAE - Society of Automotive Engineers UST - Underground Storage Tank VOC- Volatile Organic Compound

2 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 ]: ignitable - have a flash point less than 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. 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 crosscontamination 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. 2

3 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 ]. 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 ]. Never pour any liquid wastes (whether hazardous or nonhazardous) into a dumpster: Landfills cannot accept bulk or non-containerized liquid commercial wastes [ARM ]. Never pour used solvents on the ground, or into septic systems or other systems that discharge wastewater to subsurface soils [ARM ] (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 ]. Keep all paperwork for at least three years [ARM ]. 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 ] (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 ]. 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 must be labeled and covered except when adding or removing material [ARM ]. Hazardous waste must be hauled by a permitted hazardous waste transporter [ARM ]. (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 ]. 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 ]. (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 ]. 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. 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, lesshazardous 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 Environmental Compliance Checklist For Auto Body Shops 3 Montana Pollution Prevention Program MSU Extension Service

4 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). 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, leadacid 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 ]. 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. 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 4 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 ], or if they exhibit the characteristics of a hazardous waste [ARM ]. Saturated shop towels are considered liquid waste. Liquid wastes of all types are prohibited from landfills [ARM (28)] 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 MSU Extension Service

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6 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. 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 metalbased 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. 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 6 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). 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 overmixing 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 nonempty 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 nonhazardous waste). Many landfills will not accept any Montana Pollution Prevention Program MSU Extension Service

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8 regulations. Contact the EPA-Helena Office at (406) 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 system Who regulates them? Applicable regulations City Sewer POTW ARM 17.30, et seq. Class V Well (septic system or any drainfield) EPA- Helena Office 40 CFR Parts 144 and 146 Storm drain State DEQ, ARM ; 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 ]. 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 8 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. 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 MSU Extension Service

9 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. 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 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 Recover/recycle equipment must meet SAE standard J 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 9 Montana Pollution Prevention Program MSU Extension Service

10 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.