SUMMARY OF FEDERAL REQUIREMENTS

Used oil is defined 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 (40 CFR 279.1.) Most federal facilities accumulating used oil are operating as Used Oil Generators. A Used Oil Generator is any person, by site, whose act or process produces used oil or whose act first causes used oil to become subject to regulation (40 FR 279.1.)

(If the used oil contains greater than or equal to 1,000 ppm total halogens, it is presumed to be a hazardous waste) EPA’s regulatory definition of used oil is as follows: Used oil is 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 . 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:

#1 Origin

the first criteria for identifying used oil is based on the origin of the oil. Used oil must have been refined from crude oil or made from synthetic materials. Animal and vegetable oils are excluded from EPA’s definition of used oil.

#2 Use

the second criteria is based on whether and how the oil is used. Oils used as lubricants, hydraulic fluids, heat transfer fluids, buoyants, and for other similar purposes are considered used oil. Unused oil 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 solely for their solvent properties, as well as certain petroleum-derived products like antifreeze and kerosene.

#3 Contaminants

the third criteria is based on whether or not the oil is contaminated with either physical or chemical impurities. 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.

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