Under the RCRA used oil regulations at 40 CFR 279, a used oil generator is “any person, by site, who produces used oil or causes used oil to become subject to regulation.” Generators include all persons who produce used oil through commercial or industrial operations and vehicle services.
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Because the used oil standards have no exemption for generators based on used oil generation rate, generators that are conditionally exempt small quantity generators (CESQGs) in terms of hazardous waste generation are subject to the used oil regulations if they generate used oil.
Although used oil generators must comply with many used oil regulations, the most relevant, and somewhat confusing, concern storage of used oil.