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#4583868 - 11/24/17 05:39 PM FYI: EPA on "Waste Oil"
bunnspecial Offline


Registered: 11/23/15
Posts: 739
Loc: US
Unfortunately, I don't have a reference for this, but I'll potentially have a citation in hand in a few weeks...

We had an EPA inspection at work a few weeks ago, and among other things the inspector told us that we were not permitted to mark containers containing used oil as "Waste Oil." The containers must me marked "Used Oil."

At my work, this was in regard to vacuum pump oil, but per the inspector it's generally applicable to any kind of oil including motor oil. Apparently he also "got" the physical plant vehicle maintenance shop on this.

For those of you who deal with things at home, mark your containers however you want. This is mostly a heads up to commercial shops.

Of course, that's just one inspector and he was fishing for violations. Also, I should add that this isn't legal advice but just a "heads up" on something that bit me a few weeks ago.
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2010 Lincoln MKZ-Mobil 1 5W-30
1970 MG MGB Roadster-Valvoline VR-1 20W-50

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#4583898 - 11/24/17 06:11 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
Errtt Offline


Registered: 11/14/10
Posts: 2806
Loc: California
I generally mark ours as "Used Oil - Recyclable"

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#4583905 - 11/24/17 06:20 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
Donald Offline


Registered: 03/21/04
Posts: 20472
Loc: Upstate NY
If it's in a kitty litter container it's used or waste oil.
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#4583911 - 11/24/17 06:33 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
Donald Offline


Registered: 03/21/04
Posts: 20472
Loc: Upstate NY
If it's in a kitty litter container it's used or waste oil.
_________________________
2015 Subaru Forester 2.5 engine/CVT
2015 Ford F250 w/Powerstroke
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#4583915 - 11/24/17 06:41 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
OneEyeJack Offline


Registered: 09/14/10
Posts: 7480
Loc: S California
The EPA cited a shop here because the label "Used oil" was on tape that could be removed. It appears that if one is doing a job for which they are not qualified steps like this are the best compromise. Why would one waste the power to enforce even if there's nothing wrong? They were actually given a deadline to correct this violation and that implies that there will be a follow-up investigation.

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#4583931 - 11/24/17 07:06 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
DoubleWasp Offline


Registered: 05/21/12
Posts: 5236
Loc: Fort Lauderdale, FL
Know this situation full and well. When I bought this business, I was told by previous owner to purchase pre-marked and approved containers from a specific supplier. Those specific containers are always passed over by the inspectors.

But if you think it has not crossed my mind that this may be some form of corruption to feed the supplier, you would be wrong.

I'd not be surprised to find a relative of some politician owns the company.

The amount of code regarding repair facilities here is impressive. Our used oil barrels have to be specific type, and we have to have a specific type of pan under them. We cannot keep used oil in any container that is not backed up by this pan.

Same goes for our coolant and used oil filters. Do it right, or these suckers will descend on you in a heartbeat.

It never stops, though. We continually get questions about "what's in the water" coming out of a boat being run on the muffs. My response of "if it's safe enough to go in the lakes and oceans people boat in, it's safe enough here" got me some dirty looks from inspectors.
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#4583981 - 11/24/17 07:53 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
BobsArmory Offline


Registered: 03/28/10
Posts: 1320
Loc: Michigan
There is a new label that you can use on any container that you wish to use. I'll try to remember to post a photo of it when I get to work Monday.
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#4584010 - 11/24/17 08:39 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
bunnspecial Offline


Registered: 11/23/15
Posts: 739
Loc: US
FWIW, we have probably 200 waste containers or better in my building at work. Most are lab waste, and the number of labs are why we have so many containers. Virtually every lab has at least four containers-acid waste, base waste, halogenated solvents, and non-halogenated solvents. There are also specialized containers for specific purposes-i.e. heavy metals, aqua regia, solids, etc.

We have a centralized department that handles waste for everyone, not just our department, although we are their biggest "customer" and I work very closely with the coordinator. They supply pre-marked containers, but empty solvent bottles and the like often get pressed into service as overflow or special purpose containers. It's normally fine to deface the label on the container and then either mark in sharpie or put on a label that says "Hazardous Waste" and then the nature of the contents. We also generally mark anything that's applicable-flammable, corrosive, toxic, oxidizer, etc.

The "waste oil" vs. "used oil" thing was something that caught even the waste coordinator off guard and like I said came about as the inspector really seemed to be fishing for violations.
_________________________
2010 Lincoln MKZ-Mobil 1 5W-30
1970 MG MGB Roadster-Valvoline VR-1 20W-50

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#4584097 - 11/24/17 10:36 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
A_Harman Offline


Registered: 10/01/10
Posts: 6921
Loc: Michigan
To me, it just seems like semantics trying to distinguish between "used" and "waste" oil. Maybe you could politely ask the EPA inspector to show you the regulation that explains the difference? I've always used the terms interchangeably, but perhaps the EPA has explicit definitions. They've probably sat around and thought that stuff up. Perhaps they think that "waste" oil is stuff you intend to pour down a storm drain.
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#4584123 - 11/24/17 11:55 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
Shannow Online   content


Registered: 12/12/02
Posts: 39930
Loc: 'Stralia
I understand it...it's sort of semantics but I'll give a practical application on the verbiage.

Power Station produces lots of fly ash...it can be used in concrete and the like "beneficially re-used" just like used oil can. If we call it a "waste stream", then our downstream suppliers are receiving "waste", and need a specific licences. If it's waste, it attracts a waste levy.

It's official title (not ours, theirs) is Coal Combustion Product (CCP)...and we store it in a repository. It's legit, as we have had customers want a specific product in high volumes, and we've been able to dig it back up to supply them....eventually, these sites WILL be mined for materials.

A guy started a business on our site producing blocks, made largely out of ash, but also needing other low costs silicates like blast furnace slag...can do it with sodium silicate, but that's REALLY expensive...when our site was receiving "waste", it risked reclassifying the whole place and re-licencing

Legally, a word can make a big difference...to you and I it seems silly, but it can make a difference.

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#4584126 - 11/25/17 12:12 AM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
A_Harman Offline


Registered: 10/01/10
Posts: 6921
Loc: Michigan
This sort of illustrates why lawyers and engineers are mortal enemies.
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1985 Z51 Corvette track car
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#4584130 - 11/25/17 12:17 AM Re: FYI: EPA on "Waste Oil" [Re: A_Harman]
Shannow Online   content


Registered: 12/12/02
Posts: 39930
Loc: 'Stralia
Originally Posted By: A_Harman
This sort of illustrates why lawyers and engineers are mortal enemies.


I'm hearing you...

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#4584134 - 11/25/17 12:40 AM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
raytseng Offline


Registered: 12/11/08
Posts: 2343
Loc: CA
inspector was doing you a favor.

waste oil is hazardous waste so has to be handled differently.
if you labelled everything waste oil then you'd have to take care of it all as hazardous.

he could've easily written you up by saying you labelled correctly but then violated all the regulations of handling waste oil. letting you relabel is a super generous warning. itd be like you claimed a ton of incorrect deductions on your taxes "by accident" and they let you just amend it without penalty versus really letting you have it.

https://www.google.com/amp/s/www.rmagreen.com/rma-blog/bid/53516/Used-Oil-vs-Waste-Oil%3fhs_amp=true


if you think who cares, well then you also should not care if they put conv instead of syn or 5w20 instead of 5w30 or all the other oil hairs that get split here.

if one is pedantic enough to hang out and post on an oil site and argue why one oil is different from another, you should be able to appreciate the semantic differences of waste vs used.


Edited by raytseng (11/25/17 12:51 AM)

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#4584381 - 11/25/17 10:37 AM Re: FYI: EPA on "Waste Oil" [Re: raytseng]
bunnspecial Offline


Registered: 11/23/15
Posts: 739
Loc: US
Originally Posted By: raytseng
inspector was doing you a favor.

waste oil is hazardous waste so has to be handled differently.
if you labelled everything waste oil then you'd have to take care of it all as hazardous.


The problem I see in my specific situation is we deal with(literal) tons of legitimately hazardous waste, including stuff that makes even the nastiest motor oil look safe enough to take a bath in.

Had it been labeled "waste oil", for example, the waste coordinator would have treated it appropriately and disposed of it in accordance with the regulations for "waste oil."

The problem comes in the fact that we can't-apparently-label it anything other than "used oil" regardless of what is in it. In the case of vacuum pump oil, it's usually loaded with solvents and who knows what else.
_________________________
2010 Lincoln MKZ-Mobil 1 5W-30
1970 MG MGB Roadster-Valvoline VR-1 20W-50

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#4584451 - 11/25/17 12:10 PM Re: FYI: EPA on "Waste Oil" [Re: bunnspecial]
doitmyself Offline


Registered: 06/03/02
Posts: 6231
Loc: MI
bunnspecial, that sounds like a misinterpretation of the regulations. I work at a large institution with 100's of labs. Used vehicle oil is specified to be labeled as "Used oil". Other lab oils are labeled appropriately as waste oil if they contain hazardous waste.

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