Lion will be closed on Friday, July 3. For online training support, please contact support@lion.com.
Search
Search

Question of the Week: Mixing Used Oil & Hazardous Waste

Posted on 9/28/2011 by James Griffin

Q. If I have some used oil and mix it with hazardous waste, can I still manage it as used oil? Or is the whole mixture now a hazardous waste?
 
A. The answer is, it depends. Some mixtures of hazardous waste and used oil must be managed as hazardous waste, but other mixtures can be managed under the alternative, less restrictive rules for used oil.
 
Used Oil
Used oil, including crankcase oil, transmission fluid, hydraulic fluid, machining oil, and lubricating oils, can be managed under the Used Oil regulations codified at 40 CFR Part 279, even if that oil has a hazardous waste characteristic.
 
Used Oil Mixed With “Listed” Wastes
A mixture of used oil and a hazardous waste that is listed in 40 CFR Part 261, Subpart D, a waste with an F-, K-, P-, or U-code, must be managed as a listed hazardous waste. Remember that a mixture of a hazardous waste and ANY solid waste is a listed waste. [40 CFR 261.3(a)(2)(ii)]
 
Used Oil Mixed With “Characteristic” Waste
When you mix used oil with a characteristically hazardous waste, a waste with a D-code or one listed only due to ignitability, corrosivity, reactivity, or toxicity, then the resulting mixture may or may not be a hazardous waste.
 
  1. If you have a mixture of used oil and a characteristically hazardous waste and the mixture has a characteristic, then you must manage it as hazardous waste.
  2. If you have a mixture of used oil and a characteristically hazardous waste and the mixture does not have any characteristics, then you may manage it as used oil.
  3. If you have a mixture of used oil and an ignitable hazardous waste (a waste that is hazardous solely because it exhibits the ignitibility characteristic) and the resulting mixture is NOT ignitable, then you may manage it as used oil whether or not other characteristics are present in the final mixture.
Rebuttable Presumption
One more thing to note is that if your used oil contains more than 1,000 ppm total halogens, the EPA presumes that all those halogens got there because you mixed in some hazardous waste. This means that the EPA doesn’t have to prove you did indeed mix used oil and hazardous waste. Instead, you have to prove to them that you didn’t.
 

Tags: hazardous, RCRA, waste

Find a Post

Recent Posts

Compliance Topics

Compliance Archives

Lion - Quotes

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

I chose Lion's online webinar because it is simple, effective, and easily accessible.

Jeremy Bost

Environmental Health & Safety Technician

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.

Jeffrey Tierno

Hazmat Shipping Professional

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

Download Our Latest Whitepaper

Spot and correct 4 of the most common universal waste errors before they result in a notice of violation during a Federal or state inspection.

Download
Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.