Compliance with the used oil management regulations has always posed challenges to generators of used oil—from understanding the applicability of the regulations to identifying any cost-saving opportunities. In a recent webinar titled Used Oil Generators: Cost-Effective Strategies to Stay Compliant with EPA Regulations, speaker David J. Scriven-Young, senior counsel of primarily environmental law, construction, and commercial litigation practices at Peckar & Abramson, provided guidance on how to unravel several of the used oil management conundrums.
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One helpful clarification was Scriven-Young’s discussion of the terms “used oil” and “waste oil,” and how the two terms are not interchangeable. “Used oil,” as defined in the used oil regulations, means 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. Such oil is presumed to be recyclable. Waste oil, on the other hand, is oil that has not been used but is not suitable for its original purpose.