Handle with Care

Every contractor who owns and maintains equipment must deal with the challenge of handling used oil and oil filters. Care must be taken during oil changes to prevent spills, and of course there are the issues of transport, storage and disposal.

Regulations on proper storage, handling and disposal can vary from state to state. "Contractors should check with the appropriate state agency that regulates used oil handling," says Aaron Sage, COO, Sage Oil Vac, a manufacturer of on-site lube equipment. This information can be found at www.epa.gov/epahome/state.htm. "They may need to be registered as a used oil handler if they are handling more than 55 gal. of used oil to and from the jobsite."

Many contractors that maintain equipment will be classified as used oil "generators" by the U.S. Environmental Protection Agency (EPA). This is important, since there are certain rules generators must follow. Unless your shipments are less than 55 gal., you may need to use transporters with valid 12-digit EPA ID numbers for shipping used oil off site. But then you may still need a state or local permit.

There is also the issue of whether the oil will be classified as a hazardous waste. According to the American Petroleum Institute, the federal government does not consider used oil destined for recycling as hazardous waste. However, there are three states (California, Massachusetts and Rhode Island) that have classified it as such. These states require special handling for used oil.

Fortunately, there are firms specializing in hauling away used oil and filters. "Hopefully, [construction] companies are contracting with local transporters and collectors to recycle their used oil and oil filters," says Jeremy Denton, executive director, Filter Manufacturers Council.

"We recommend using an environmental service provider, rather than just a transportation provider, because such a company will have the proper permits, equipment, insurance, trained experience and a range of services to handle not only the oil pick up and transport, but any contingencies or other problems or liabilities that may arise," says David Threlkeld, director of product management, Oil Services, Safety-Kleen. "At a minimum, references should be requested and preferably a check of permits, equipment, insurance and personnel should be conducted. Any qualified service provider should have such information readily available."

The goal is to minimize your liability exposure. "A service provider should have liability insurance sufficient to cover the most extreme incident that could arise involving your oil," says Threlkeld. "The bottom line is a company's peace of mind - are you comfortable that you will be covered regardless of what type of incident arises?"

Make sure the company you contract meets or exceeds accepted standards. "An additional credential that adds another layer of 'comfort' is ISO certification," says Threlkeld. "A company that meets ISO certification requirements has, in essence, already been vetted and found to have in place systems and programs that will ensure service integrity."

Add value to waste

No matter how you choose to get used oil to a recycler, make sure it remains uncontaminated by other fluids and the outside environment. "It is very important to have clean and uncontaminated used oil," says Sage. "This used oil is worth much more to the recycler because it is a cleaner product."

It is also worthwhile if the used oil recycler can pick up a large amount at one time. "We have seen some recyclers pay the generator of the used oil $0.50/ gal. to pick up 500 gal. of used oil or more," Sage points out.

Also consider the efficiency of your oil handling practices. "Contractors should consider how many steps and how much time is involved in their current process - from the time they get the used oil and filter from the equipment to the proper disposal site," says Sage. "How many times are they handling it? Are there inefficiencies in this? Could they allow their filters to hot drain right from the time they take them off?"

Spill prevention

"When handling used oils and filters, safety is a primary concern for both workers and the environment," says Threlkeld. "The safest way to handle and store used oils and filters is to have the proper equipment, storage containers and training specific to your application. For example, Safety-Kleen has a wide variety of products, containers and services that it makes available to its customers, and it works with its customers to customize a program that meets their specific needs."

By using equipment, containers and procedures that are designed for these specific uses, companies can minimize the likelihood of spills and leaks and reduce the liabilities that can arise from such events. Many companies choose to use a professional industrial waste management expert that is specifically equipped, experienced and permitted for managing such waste streams from initial collection through transportation and recycling or proper disposal.

According to Sage, prevention of oil spills is the ultimate goal. "Outfitting your equipment fleet with quick disconnects for fluid exchanges will greatly reduce the chance of a costly spill," he states.

Oil evacuation systems have many other advantages. "In most cases, Oil Vac customers realize a 50% reduction or more in time spent performing oil changes," says Sage. "This reduction is realized by the elimination of 'dropping the plug and catching in a pan', and also the elimination of transferring the bucket or pan of used oil."

Almost no oil is left in the engine when a vacuum is used vs. traditional gravity drains. "Vacuum systems are very efficient," Sage asserts. "They can vacuum hot used motor oil at rates up to 7 gpm. The powerful vacuum removes more of the oil and possible contaminants from the pan than pumps or gravity drain."

By using the evacuation system along with quick-connect fittings and hoses, you minimize your risks. "Our solution is to outfit the construction fleet with quick-connect fittings or hoses that allow the evacuation system to be directly connected to the engine pan for 100% enclosed evacuation," says Sage. "Many machinery manufacturers are starting to put auxiliary drains and existing quick-connect options on new equipment, further easing the process of quick connecting for enclosed evacuation of used oils and fluids."

In the advent you do spill used oil or a storage container would leak, you need to have an action plan in place. "Safety-Kleen offers a full array of spill containment and absorbents, as well as training for employees in preventing and managing spills," says Threlkeld. "In the event of a significant or difficult spill, we also offer full-scale emergency response on a 24-hour basis."

Recycle used filters

Recycling goes beyond the oil itself. Used oil filters can also be recycled.

"What we have seen so far, and what I continue to hear from the collectors and processors, is that the steel is the most valuable component of the used oil filter," says Denton. "There are a number of ways to recycle a used oil filter. Crushing is one way, shredding is another and cubing is still another. What we have found is most all of them are effective."

In most cases, a used oil filter is not considered a hazardous waste as long as it is hot drained. But this is not the case in every state. The Filter Manufacturers Council offers a 'recycle your filter' page on its web site (www.filtercouncil.org), which allows you to select the state and view its regulations. A few states now have landfill bans, and have taken things a little farther than the EPA recommendations.

The web site can also help you locate an oil and filter management company. "Find your state, and we have a link to filter management companies that will service your state and your site," says Denton. He encourages as many people as possible to use this resource. "The Filter Manufacturers Council has always done as much as we can with states to develop a recycling infrastructure - working with states, as well as collectors and processors. That will allow construction fleets to get their product to the grave in an environmentally friendly manner."

One key element is understanding how to properly hot drain an oil filter. According to the Filter Manufacturers Council, you should remove the filter from the engine while warm, then immediately drain the free-flowing oil. Next, puncture the filter dome and invert the filter to drain into the appropriate container at a temperature above 60° F for at least 12 hours.

Sage Oil Vac offers a product that can simplify draining of filters. The Filter Stinger is used to pierce a used oil filter, then vacuum out the oil. "The Filter Stinger and the Used Filter Receptacle cut down on many spills, because the used oil is vacuumed from the filter before it is spun off," Sage explains. This also decreases the burn hazards to the technicians, since they are not handling the hot oil.

Used Oil Management Standards

The EPA has developed management standards for businesses that handle used oil. These include:

  • 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.
  • Don't 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 Resource Conservation and Recovery Act (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.
  • 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 and surrounding area.
  • Clean up the oil and recycle the used oil as you would have before it was spilled. If recycling is not possible, you must first make sure the oil is not a hazardous waste and dispose of it appropriately. All used cleanup materials that contain free-flowing used oil must also 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.

While most of the EPA standards fall under the category of "common sense," you should really take a close look at how you store used oil and ensure there are plans in place to contain any leaks before they create a major contamination problem. "A contractor should consider putting double containment around the stationary used oil and/or fresh oil bulk tanks," says Aaron Sage, Sage Oil Vac.

Handling used oil and filters is just another aspect of owning and maintaining an equipment fleet. It's in your best interest to understand your local regulations in regards to proper handling and disposal, and to take the appropriate steps to minimize your liability exposure.

hazardous waste as long as it is hot drained. But this is not the case in every state. The Filter Manufacturers Council offers a "recycle your filter" page on its web site (www.filtercouncil.org), which allows you to select the state and view its regulations. A few states now have landfill bans, and have taken things a little farther than the EPA recommendations.

 

The web site can also help you locate an oil and filter management company. "Find your state, and we have a link to filter management companies that will service your state and your site," says Denton. He encourages as many people as possible to use this resource. "The Filter Manufacturers Council has always done as much as we can with states to develop a recycling infrastructure - working with states, as well as collectors and processors. That will allow construction fleets to get their product to the grave in an environmentally friendly manner."

One key element is understanding how to properly hot drain an oil filter. According to the Filter Manufacturers Council, you should remove the filter from the engine while warm, then immediately drain the free-flowing oil. Next, puncture the filter dome and invert the filter to drain into the appropriate container at a temperature above 60° F for at least 12 hours.

Sage Oil Vac offers a product that can simplify draining of filters. The Filter Stinger is used to pierce a used oil filter, then vacuum out the oil. "The Filter Stinger and the Used Filter Receptacle cut down on many spills, because the used oil is vacuumed from the filter before it is spun off," Sage explains. This also decreases the burn hazards to the technicians, since they are not handling the hot oil.

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