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568 Waste Management Practices: Municipal, Hazardous, and Industrial
for Evaluating Solid Waste (SW-846) (U.S. EPA, 1986) for total halogen content. If concentrations
of individual halogenated constituents are found to be insignificant, the used oil is not considered
hazardous waste. If, however, more than 1000 ppm of halogenated compounds are measured, the
used oil is considered hazardous waste and must be handled under RCRA Subtitle C (standards
for management of hazardous waste). Analytical reports are to be maintained by the transporter
for 3 years.
The transporter is required to maintain records for shipments of used oil for 3 years. Transfer
facilities are required to keep the same storage, labeling, and release response specifications as gen-
erators. In addition, tanks and storage containers must be equipped with impermeable secondary con-
tainment. This includes an impermeable floor and may include dikes, soil berms, or retaining walls.
19.7.5 DOT REQUIREMENTS
The Hazardous Materials Transportation Act (HMTA) regulates the transportation of used oil. The
DOT has established its own definition of a “hazardous material;” DOT considers used oil a haz-
ardous material if it is a combustible liquid (flash point of 38 to 75°C [100 to 200°F]) or a flam-
mable liquid (flash point of 38°C [100°F] or less). Persons transporting used oil that meets the
definition of a hazardous material in 49 CFR Part 171.8 must comply with DOT requirements in 49
CFR Parts 171 through 180.
In the event of a discharge of used oil during transportation, the transporter must take immedi-
ate action to protect human health and the environment (e.g., notify local authorities, and dike the
discharge area). A state or federal official may authorize the removal of the used oil by transporters
who do not have EPA identification numbers.
19.7.6 USED OIL RECYCLING
Approximately 560 million L (150 million gal) of used oil are recycled on-site in the United States
by generators each year. The basis of the decision to focus the Used Oil Management Standards on
recycling was to protect public health and the environment, for conserving energy resources, and
for economic benefits. For example, re-refining used oil consumes one- third of the energy of refin-
ing crude oil to lubricant quality. In addition, about 3.8 L (1 gal) of used oil processed for fuel con-
tains about 147,700 kJ (140,000 Btu) of energy. A discussion of used oil recycling technologies
appears below.
Generation and handling are subject to the managements standards until the used oil is shipped
away for disposal. Used oil recyclers must comply with the following requirements:
● Tanks and storage containers must be equipped with impermeable secondary containment.
This includes an impermeable floor and may include dikes, soil berms, or retaining walls.
● Used oil mixed with listed hazardous waste is to be treated as hazardous waste.
● Used oil mixed with characteristic hazardous waste is under hazardous waste regulations
if the mixture fails one of the four characteristic tests.
● Used oil with more than 1000 mg/kg total halogens is designated a hazardous waste,
because EPA concludes that such oil has been mixed with listed hazardous waste.
● Metalworking oils or fluids containing chlorinated paraffins processed to reclaim metal-
working oils or fluids are exempt.
● Used oils containing chlorofluorocarbons (CFCs) removed from refrigerators where the
CFCs are reclaimed, are exempt.
● People who change their own oil and farmers generating less than 95 L (25 gal) per
month are not regulated by the same requirements (40 CFR Part 279.53).
Used oil processors and re-refiners must have an EPA identification number and must develop
practices that reduce the risk of fire, explosion, or any kind of release. Communications, emergency,

