Used Oil Handler Activities
A generator’s used oil activities may subject the generator to the responsibilities of one or more other used oil handler categories. These requirements would be in addition to those required of generators. Other handler categories and the activities that would subject the generator to these additional requirements are:
Transporters. Generators who transport used oil (except for self-transportation to collection centers or to aggregation points as discussed in this section) must comply with the transporter requirements are the following:
Processors/Rerefiners. Generators who process or rerefine used oil will be deemed to be processors/rerefiners. However, generators who engage in the following activities will not be deemed to be processors, provided that the used oil is generated on-site and is not being sent off-site to a burner of specification or off-specification used oil fuel:
—Filtering, cleaning, or otherwise reconditioning used oil before returning it for reuse by the generator,
—Separating used oil from wastewater to make wastewater acceptable for discharge or reuse,
—Using mist collectors to remove droplets of used oil from workplace air,
—Removing used oil from materials contaminated with used oil, and
—Reconditioning used oil before burning in a space heater.
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Burners. Generators who burn off-specification used oil for energy recovery, except under the on-site space heater provisions, must to follow the requirements for burners.
Marketers. Generators who direct shipments of off-specification used oil from their facility to a used oil burner, or first claim that the used oil to be burned is specification used oil, must comply with rules for marketers.
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Used Oil Filters
Used oil filters do not have to be managed as hazardous waste provided the oil is drained from them, the filter is not mixed with a listed hazardous waste, and the filter is not plated with terne (an alloy of tin and lead). These "nonterne" used oil filters must be properly drained in order to fit into the exemption. To qualify for this exemption, EPA requires that filters be "gravity hot-drained" by one of the following methods:
- Puncturing the filter antidrain back valve or the filter dome end and hot-draining,
- Hot-draining and crushing, or
- Dismantling and hot-draining.
Any other equivalent hot-draining method that will remove the used oil
"Hot drained" means that the used oil filter is drained near engine-operating temperature. To adequately remove the majority of the oil, EPA recommends draining the filter for 12 hours.
Note: It is often difficult to differentiate between terne and nonterne filters. The generator of a used oil filter may have to contact the manufacturer to find out if the filter is terne or nonterne. Note also that some states have different draining standards and that some states regulate used oil filters as a hazardous waste.