Managing Used Oil: Answers to Frequent Questions for Businesses
A wide variety of businesses such as service stations, fleet maintenance facilities, and "quick lube" shops generate and handle used oil. EPA's used oil management standards--a set of "good housekeeping" requirements for used oil handlers—are detailed in Title 40 of the Code of Federal Regulations (CFR) part 279. This Web page highlights essential information that businesses can use to manage their used oil while protecting human health and the environment.
- What is Used Oil?
EPA defines used oil as any oil that has been refined from crude oil or any synthetic oil that has been used and as a result of such use is contaminated by physical or chemical impurities. Simply put, used oil is exactly what its name implies—any petroleum-based or synthetic oil that has been used.
During normal use, impurities such as dirt, metal scrapings, water, or chemicals can get mixed in with the oil, so that in time the oil no longer performs well. Eventually, this used oil must be replaced with virgin or re-refined oil to do the job at hand. EPA's used oil management standards include a three-pronged approach to determine if a substance meets the definition of used oil. To meet EPA's definition of used oil, a substance must meet each of the following three criteria:
- Origin - Used oil must have been refined from crude oil or made from synthetic materials.
- Use - Oils that are used as lubricants, hydraulic fluids, heat transfer fluids, buoyants, and for other similar purposes are considered used oil. Unused oils such as bottom clean-out waste from virgin fuel oil storage tanks or virgin fuel oil recovered from a spill, do not meet EPA's definition of used oil because these oils have never been "used." EPA's definition also excludes products used as cleaning agents or used solely for their solvent properties, as well as certain petroleum-derived products like antifreeze and kerosene.
- Contaminants - In other words, to meet EPA's definition, used oil must become contaminated as a result of being used. This aspect of EPA's definition includes residues and contaminants generated from handling, storing, and processing used oil. Physical contaminants could include metal shavings, sawdust, or dirt. Chemical contaminants could include solvents, halogens, or saltwater.
For more information on specific oils that can fall under RCRA’s definition of used oil, view our “What is Used Oil?” reference table.
- How is Used Oil Recycled?
Once oil has been used, it can be collected, recycled, and used over and over again. An estimated 380 million gallons of used oil are recycled each year. Recycled used oil can sometimes be used again for the same job or can take on a completely different task. For example, used motor oil can be re-refined and sold at the store as motor oil or processed for furnace fuel oil. Aluminum rolling oils also can be filtered on site and used over again.
Used oil can be:
- Reconditioned on site—Impurities are removed from the used oil, which is then reused. While this form of recycling might not restore the oil to its original condition, it does prolong its life.
- Inserted into a petroleum refinery—Used Oil is introduced as a feedstock into refinery production processes.
- Re-refined, which involves treating used oil to remove impurities so that it can be used as a base stock for new lubricating oil. Re-refining prolongs the life of the oil resource indefinitely. This form of recycling is the preferred option because it closes the recycling loop by reusing the oil to make the same product that it was when it started out, and therefore uses less energy and less virgin oil.
- Processed and burned for energy recovery, which involves removing water and particulates so that used oil can be burned as fuel to generate heat or to power industrial operations. This form of recycling is not as preferable as methods that reuse the material because it only enables the oil to be reused once. Nonetheless, valuable energy is provided (about the same as provided by normal heating oil).
- What Businesses Handle Used Oil?
Many types of businesses that handle used oil, including:
- Generators are businesses that handle used oil through commercial or industrial operations or from the maintenance of vehicles and equipment. Generators are the largest segment of the used oil industry. Examples of common generators are car repair shops, service stations, quick lube shops, government motor pools, grocery stores, metal working industries, and boat marinas. Farmers who produce less than an average of 25 gallons of used oil per month are excluded from generator status. Individuals who generate used oil through the maintenance of their personal vehicles and equipment are not subject to regulation under the used oil management standards.
- Collection centers and aggregation points are facilities that accept small amounts of used oil and store it until enough is collected to ship it elsewhere for recycling. Collection centers typically accept used oil from multiple sources that include both businesses and individuals. Aggregation points collect oil only from places run by the same owner or operator and from individuals.
- Transporters are companies that pick up used oil from all sources and deliver it to re-refiners, processors, or burners. Transfer facilities include any structure or area where used oil is held for longer than 24 hours, but not longer than 35 days. Examples of transfer facilities are loading docks and parking areas.
- Re-refiners and processors are facilities that blend or remove impurities from used oil so that it can be burned for energy recovery or reused. Included in this category are re-refiners who process used oil so that it can be reused in a new product such as a lubricant and recycled again and again. EPA's management standards primarily focus on this group of used oil handlers.
- Burners burn used oil for energy recovery in boilers, industrial furnaces, or in hazardous waste incinerators.
- Marketers are handlers who either (a) direct shipments of used oil to be burned as fuel in regulated devices or, (b) claim that certain EPA specifications are met for used oil to be burned for energy recovery in devices that are not regulated. They also sometimes help move shipments of used oil to burners. By definition, marketers must also fall into at least one of the above categories.
- What Regulations Should My Business Follow?
If your business handles used oil, there are certain good housekeeping practices that you must follow. EPA developed required practices, called "management standards," for businesses that handle used oil. The management standards are common sense, good business practices designed to ensure the safe handling of used oil, maximize recycling, and minimize disposal. Although EPA and the states may have specific requirements for different used oil handlers, the following requirements are common to all types of handlers. These requirements relate to storage, recordkeeping and to cleaning up leaks and spills, as follows.
Requirements for Storing Used Oil:
- Label all containers and tanks as Used Oil.
- Keep containers and tanks in good condition. Don't allow tanks to rust, leak, or deteriorate. Fix structural defects immediately.
- Never store used oil in anything other than tanks and storage containers. Used oil may also be stored in units that are permitted to store regulated hazardous waste. Tanks and containers storing used oil do not need to be RCRA permitted, however, as long as they are labeled and in good condition. Storage of used oil in lagoons, pits, or surface impoundments that are not permitted under RCRA is prohibited.
Requirements for Oil Leaks and Spills:
- Take steps to prevent leaks and spills. Keep machinery, equipment containers, and tanks in good working condition and be careful when transferring used oil. Have sorbent materials available on site.
- If a spill or leak occurs, stop the oil from flowing at the source. If a leak from a container or tank can't be stopped, put the oil in another holding container or tank.
- Contain spilled oil. For example, containment can be accomplished by erecting sorbent berms or by spreading a sorbent over the oil.
- Clean up the oil and recycle the used oil as you would have before it was spilled. If recycling is not possible, you first must make sure the used oil is not a hazardous waste and dispose of it appropriately. All used cleanup materials, from rags to sorbent booms, that contain free-flowing used oil also must be handled according to the used oil management standards. Remember, all leaked and spilled oil collected during cleanup must be handled as used oil. If you are a used oil handler, you should become familiar with these cleanup methods. They may also be part of a spill response action plan.
- Remove, repair, or replace the defective tank or container immediately.
- Handlers may be subject to Spill Prevention, Control and Countermeasures (SPCC) requirements (40 CFR part 112).
Standards for Record Keeping:
EPA uses 12-digit identification (ID) numbers to track used oil. Transporters that haul used oil must have a valid EPA ID number, and generators, collection centers, and aggregation points must use transporters with EPA ID numbers for shipping used oil off site. If you need an ID number, contact your EPA regional office or your state director. Generators, collection centers, aggregation points, and any handler that transports used oil in shipments of less than 55 gallons do not need an ID number, but may need a state or local permit.
Used oil transporters, processors, burners, and marketers also must record each acceptance and delivery of used oil shipments. Records can take the form of a log, invoice, or other shipping document and must be maintained for three years. Re-refiners, processors, transfer facilities, and burners must have secondary containment systems (e.g., oil-impervious dike, berm, or retaining wall and a floor) so that oil cannot reach the environment in the event of a leak or spill. EPA also encourages generators to use a secondary containment system to prevent used oil from contaminating the environment.
Burners of used oil that meet a certain set of quality standards, “the used oil specifications,” are not regulated under the used oil management standards, as long as the used oil is burned in appropriate boilers, furnaces, or incinerators.
Know and understand your state regulations governing the management of used oil might be stricter than the EPA's. Contact your state or local environmental agency to determine your best course of action.
Standards for Mixing Used Oil and Hazardous Waste:
In addition to EPA's used oil management standards, your business may be required to comply with federal and state hazardous waste regulations if your used oil becomes contaminated from mixing it with hazardous waste. Hazardous waste disposal is a lengthy, costly, and strict regulatory process. The only way to be sure your used oil does not become contaminated with hazardous waste is to store it separately from all solvents and chemicals and not to mix it with anything.
- How Should My Business Manage Used Oil Filters?
The Filter Manufacturers' Council maintains a regulatory hotline and database to encourage the proper management of used oil filters. By calling the hotline at 800 99-FILTER, you can access the proper management requirements for your particular states. The database contains:
- Overviews of federal and state regulations relevant to the management of oil filters.
- Addresses and phone numbers of the regulatory agencies governing the management of used filters in each state.
- A listing of companies, by state, that transport, process, and recycle used filters
- How Can My Service Station Avoid Costly Cleanups?
When service station dealers meet the following conditions, they are relieved from responsibility for costly cleanups and liabilities associated with off-site handling of used oil. To meet these conditions, service stations must:
- Comply with the management standards described above;
- Do not mix used oil with any hazardous substance; and
- Accept used oil from Do-it-yourselfers (DIYs) and send it for recycling.
- What are the recommended clean-up practices for used-oil handlers who have a spill on-site?
EPA recommends, but does not require, the following cleanup practices for used oil handlers:
- maximize the recovery of used oil;
- minimize the generation of used oil sorbent waste by choosing reusable sorbent materials;
- use the spent sorbent materials to produce recycled sorbent materials; and
- buy sorbent materials with recycled content.
Extraction devices (e.g., centrifuges, wringers, and compactors) can be used to recover used oil from reusable sorbent materials. Sorbent pads can be reused between two and eight times depending on the viscosity of the used oil. These technologies, while not required, can be used to reduce the number of sorbent pads ultimately sent for remanufacture, energy recovery, or disposal. The potential to reduce waste and save money (i.e., lower disposal costs for spent pads and lower per use cost of sorbent pads) by reusing and recycling sorbent pads can be substantial.
Managing Cleanup Materials
If you have used oil on rags or other sorbent materials from cleaning up a leak or spill, you should remove as much of the free-flowing oil as possible and manage the oil as you would have before it spilled. Once the free-flowing used oil has been removed from these materials, they are not considered used oil and may be managed as solid waste as long as they do not exhibit a hazardous waste characteristic. Note, however, that materials from which used oil has been removed continue to be regulated as used oil if they are to be burned for energy recovery (regardless of the degree of removal).
- What Can My Business Do to Conserve Oil?
- Minimize the amount of used oil you produce. The less used oil that is produced in the first place, the less that ultimately has to be handled. Businesses can filter, separate, and recondition used oil to prolong its usable life.
- Purchase re-refined used oil products instead of virgin oil products. Re-refined oil works just as well as virgin oil. Products that display the American Petroleum Institute (API) "starburst" meet the same high-quality specifications as virgin oil.
- Practice safe management of used oil. Don't mix used oil with anything. Always store used oil in leak-proof containers that are in secure areas safely away from workers and the environment. Send used oil to a re-refiner whenever possible.