Fact Sheet #5: Used Oil Management
Fact Sheet #6: Absorbents
Fact Sheet #7: Accepting Used Oil from the Public
Fact Sheet #8 Antifreeze Disposal and Recycling
Fact Sheet #5: Used Oil Management
It is imperative you check with your state program or state used oil coordinator before making any business decisions regarding the management and disposal of used oil. Under the federal rules, used oil is not considered hazardous if managed in a prescribed method. However, about 30% of the states have designated used oil as a hazardous waste or a special waste and must be managed in that manner. There may be additional state and local regulations that require a shop owner to do more than the federal regulations.
The Used Oil Management Program covers all automotive service and repair shops, regardless of the amount generated.
Managing Used Oil
- Stored used oil must be stored in compliance with existing underground storage tank or aboveground storage tank standards or in containers.
- Spills and releases must be immediately stopped and cleaned up. Measures smut be put in place to prevent future releases. Spill materials used to clean up oil spills must be properly disposed.
- Keep collection drums covered and labeled, in good condition and secure from vandals and in compliance with local fire codes. Inspect frequently for leaks, corrosion and spillage.
- Label drums, tanks, and piping with the words "Used Oil" or follow your state or local labeling and storage requirements.
- Consider converting used oil underground storage tanks to aboveground storage tanks.
Mixing Used Oil
It is in your best interest not to mix used oil with other materials without consulting your oil recycling company or state waste management office, Generally, you can mix the following oil-based fluids with used engine oil:
- transmission oil
- synthetic oils
- petroleum-based, nonhazardous lubricating fluids
- hydraulic fluids
- hydraulic, cutting, gear and cooling oils
Never mix gasoline, wastewater, a listed hazardous waste, an unknown waste, halogenated solvents or antifreeze with used oil.
Transportation
Used oil that is moved off-site must be picked up by transporters that have an EPA identification number. If the shop wants to move used oil off-site, it is permitted to move one 55 gallon drum of used oil per day to an approved collection center, i.e., licensed, registered, or permitted by the state/county/municipal government. If the shop owner transports any more than that, the shop must meet appropriate DOT and the EPA requirements. While the shop owner is not required to keep any formal records, it is best that a log be kept of who, how much, when and where the used oil was sent.
All used oils should be sent for re-refining or burnt for energy recovery or for any other EPA or state approved method. If the shop is located in a temperate climate, you may want to consider using the used oil as a primary or supplemental heating source for your shop. Make sure the oil burner meets the Btu/hr and venting requirements. Other state and local requirements may apply.
The used oil requirements are not burdensome. Common sense and good management practices are what is required to comply.
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Fact Sheet #6: Absorbents
Absorbent are materials used in the containment and absorption of spilled used oil or other liquid hazardous materials. Material as simple as kitty litter to specialized foam batting can be used to absorb used oil spills and solvents, and priced accordingly. Here are some suggested activities:
- Store the used absorbent material in a covered and labeled container.
- If possible, use a laundry service for cloth towels and reuse.
- It may be possible to send the used oil absorbent to your municipal land fill so long as there is not excess moisture in bottom of the container and you are a conditionally exempt small quantity generator (CESQG). CHECK FIRST!
- Use a hydrophobic mop and bucket to clean up the used oil spill and pour into your USED OIL container. Make sure the used oil has not been contaminated with any other material.
- Be prepared before a spill. Purchase a pre-made spill kit(s) and place in readily accessible areas of your shop. Make your own spill kit.
- Consider using used oil absorbents in other ways-fuel blended off-site, recycled or reused.
- REMEMBER, avoid mixing used oil absorbents with other absorbents which you have used to clean up gasoline, battery acid, antifreeze spills, etc.
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Fact #7: Accepting Used Oil from the Public
Accepting used oil from the public is a two-edged sword for the auto shop owner. On one hand, the owner wants to offer a community service by collecting used oil and making sure it is properly disposed (sometimes voluntary, sometimes state-mandated) yet the shop could be potentially liable to enforcement action if the used oil is not truly used oil. As a shop owner, it is imperative that you contact your state's used oil coordinator to get the facts on your responsibilities as well as liabilities.
From the federal perspective, automotive service and repair shops which meet the "service station" definition are exempt from Superfund liability for used oil shipments so long as the shop complies with the Used Oil Management Standard and is willing to accept used oil from do-it-yourselfers (DIYs). Here are some guidelines to consider:
- If you accept DIY oil, consider installing a separate used oil container to avoid possible contamination with your shop's Used Oil container.
- Visually inspect DIY oil. Reject the oil if the odor or sight of the oil indicates there may be more to the used oil than is appropriate.
- Ask the DIY to sign a log book attesting to the fact that the used oil is in fact used oil.
- Provide written material about the used oil program. You may create this yourself, if your trade association or franchise provides it as a service or the state used oil coordinator may be able to provide you with a pamphlet.
- Promote your service to the local community!
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Fact Sheet #8: Antifreeze Disposal and Recycling
Antifreeze management is currently in a state of regulatory flux with the EPA. The Agency has been petitioned by various organizations to allow automotive shops to manage antifreeze like the Used Oil Management Program. Until the Agency makes a final determination, antifreeze is an automotive fluid like any other removed from a vehicle. If it exhibits a characteristic or is listed (federally it is not, but several states have listed it), antifreeze must be managed and disposed of as a hazardous waste.
From the federal perspective, antifreeze is allowed to be discharged to the local wastewater treatment plant. HOWEVER, check with your local wastewater treatment plant or municipal authority to determine if it is acceptable to them! Many municipalities prohibit the discharge of antifreeze to their wastewater treatment plant.
Used antifreeze can be recycled and as a shop owner, you are encouraged to review the economics of recycling versus treatment and disposal. For the purposes of this fact sheet, used antifreeze will be considered a hazardous waste. Once removed from the radiator, the fluid must be placed in an acceptable container, labeled "Hazardous Waste" and the date that antifreeze was first placed in the container.
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Source: US EPA Office of Enforcement and Compliance Assurance
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Last Update - 26-Jun-98