Used Oil vs. Waste Oil

The life of your oil-based lubricant does not end when it is time for a change. In fact, after draining a used lubricant, the oil will begin a new lifecycle thanks to advancements in recycling and recovery technology. 800 million of the 1.3 billion gallons of waste oil produced in the United States is recycled every year. To increase the amount of recyclable oil, manufacturers must collect and disposed of used and waste oil in safe, sustainable, and environmentally way. To achieve this, it is essential to follow best practices for used and waste oil management. However, there are key differences between “used oil” and “waste oil.”

Used Oil Defined

“Used oil” and “waste oil” are often used interchangeably, but the EPA defines them differently. The EPA defines used oil as:

“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.”

This does not include any vegetable or animal-based oils. Simply, this is any petroleum or synthetic oil that has been used in operations and have reached the end of its service life.

Waste Oil Defined

Waste oil is much broader in its definition. Waste oil is “oil that has been contaminated with substances that may or may not be hazardous.” A lot of waste oil has not been used and was contaminated before use. A common example is a loose drum cap leaked and the oil mixed with water, rendering it unsuitable for use in lubrication.

Waste oil is considered a hazardous waste. In terms of regulations and compliance, that makes it a completely different product than “used oil.” That brings more liabilities and procedures needed to ensure it is handled properly. Additionally, used oil with certain additive mixtures and water can be classified as waste oil. Off-spec oils with exceeding amounts of arsenic (5 ppm), cadmium (2 ppm), chromium (10 ppm), lead (100 ppm) and halogens (> 4000 ppm) and a flash point above 100 F will also qualify as waste oil.

Best Practices for Storage and Removal

Even though the contents of waste oil may be similar to used oil, it is still classified as waste oil due to the method in which contamination occurred. Used oil is a by-product of doing business, thus allowable to be stored onsite. One mandatory practice for used oil is labelling the storage tanks correctly. Used oil tanks, drums, totes, containers, etc. must be labelled “Used Oil” in order to be in compliance with environment regulations.

By ensuring not cross-contamination, clearly label containers for waste oil and used oil. This prevents potentially spoiling non-hazardous used oil. Waste oil and used oil may be contain similar content mixes, but whether it is used makes all the difference. If an open or leaking drum is contaminated, it is considered waste oil as the contaminant is not known and not incurred during the course of operations.

One way to avoid accumulation of waste oil is ensuring storage best practices are maintained and the integrity of your drums and totes is maintained. If you store your oil near chemicals and solvents, potentially hazardous contamination can occur and proper waste oil procedures must take place. To save on handling costs of waste oil, consider a lubricant storage program and dedicate space for lubricants away from already-hazardous materials.

Learning from your Used Oil

Before dumping your used oil, it is advised to take a sample of the used oil and used oil filters. You can test the used oil and learn a lot about contamination and oil life. This can be a key part of your oil analysis program and help extend your service life and improve lubrication-related decision making and handling.

Key Takeaways

Proper planning and storage of unused lubricant will reduce the accumulation and likelihood of waste oil. Clearly labelling “Used Oil” and “Waste Oil” tanks will keep your facility in compliance and ensure used oil is not contaminated with hazardous materials. By using certified haulers, like Gemini Disposal Services, and recyclers more oil can be recycled and reduce harmful environmental activity like drilling and pipelines. For example, 1 gallon of used motor oil can provide the same 2.5 quarts of lubricating oil as 42 gallons of crude oil.

How to Dispose of Aerosol Cans

The Environmental Protection Agency (EPA) believes that the management of hazardous waste aerosol cans can be best implemented through a universal waste approach where handlers operate within a streamlined management system with regulatory oversight. On December 9, 2019, the EPA finalized the rule to add Aerosol Cans to the federal list of Universal Wastes. This final rule will impact the labeling and marking, accumulation time limits, employee training, responses to releases, export requirements, and, for large quantity handlers of universal waste, notification and tracking.

What is the definition of Aerosol Can?

As of February, 2020, the EPA defines an aerosol as a non-refillable receptacle containing a gas compressed, liquefied or dissolved under pressure, the sole purpose of which is to expel a liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas. Because the DOT language is more inclusive than the proposed language, it better matches the intent of the proposal to apply to all types of aerosol cans, including cans that dispense product in the form of paste or powder, and would not require states that have already added aerosol cans to their universal waste program to change their regulations.

Current Regulations

On March 16, 2018 the Environmental Protection Agency (EPA) proposed adding aerosol cans to the federal universal waste list. This proposal recognized that the inclusion of this waste stream as a universal waste could better ensure that aerosol cans are managed appropriately from cradle to grave. Aerosol cans are widely used for dispensing a broad range of products including paints, solvents, pesticides, food and personal care products.

The Consumer Specialty Products Association (CSPA) estimates that 3.8 billion aerosol cans were filled in the United States in 2015 for use by commercial and industrial facilities along with households. Aerosol cans may be dangerous if mismanaged, particularly when exposed to excessive heat, which may result in increased internal pressure and eventually could cause the container to burst and release its contents. If the propellant or product is ignitable, this could result in a rapidly burning vapor “fireball.” Even if the propellant is not ignitable there are dangers from a bursting aerosol can as parts of the aerosol can could become a projectile. After the proposed rule-making was announced the EPA took public comment on the proposed standards. The docket number for this rule-making is EPA-HQ-QLEM-2017-0463.

The Environmental Protection Agency (EPA) has added hazardous waste aerosol cans to the universal waste program under the Federal Resource Conservation and Recovery Act (RCRA) regulations. The aim of this rule is to benefit the establishments generating and managing hazardous waste aerosol cans. These establishments include retail stores and others that discard hazardous waste aerosol cans. The rule will ease the regulatory burdens on these establishments and promote the collection and recycling of these cans and encourage the development of municipal and commercial programs to reduce the amount of aerosol cans from going to municipal solid waste landfills or combustors. This final ruling will impact the following areas for all handlers: Generator Status Universal Waste Aerosols do not count towards Generator Status.

Guidelines and Best Practices

The final rule requires aerosol cans to be labeled as “Universal Waste—Aerosol Can(s),” “Waste Aerosol Can(s),” or “Used Aerosol Can(s).”

  • The final rule allows for generators to store aerosol cans for up to one-year.
  • Employees must be trained on handling and how to safely puncture and drain universal waste aerosol cans – if applicable to facility.
  • Aerosol cans will now be exported as Universal Waste.
  • Notification and Tracking will only be impacted for large quantity universal waste handlers. Handlers must make a notification before beginning to puncture the aerosol cans.
  • Under the universal waste rule, a handler of universal waste can send the universal waste to another handler, where it can be consolidated into a larger shipment for transport to a destination facility.
  • Universal waste destination facilities are subject to all currently applicable requirements for hazardous waste treatment, storage, and disposal facilities (TSDFs) and must receive a RCRA permit for such activities.
  • This will make it more economical to send hazardous waste aerosol cans for recycling for recovery of metal materials. This final action is estimated to result in an annual cost savings of $5.3 million to $47.8 million.
  • The EPA is requiring leaking or damaged aerosol cans that show evidence of leakage to be packaged in a separate closed container, overpacked with absorbents or immediately punctured and drained in accordance with the aerosol can Universal waste requirements.

Gemini Disposal Services can help you disposal of your aerosol cans and/or universal waste in a safe and economic matter. If you need to dispose of your aerosol cans, request a quote and we will work with you to properly manage your universal waste.

A Guide to Food Grade Lubricants

In the food and beverage industry, health, safety, and quality are of the utmost importance. The ever-evolving standards of food and beverage safety make it important to ensure your plant is deploying the proper lubricants and cleaners. Not only do you have to meet performance standards, you also have to monitor leakage to ensure that final products are not getting contaminated. We will examine the evolving standards of food-grade lubricants and cleaners as well as the challenges in finding the right products to meet both health and performance standards.

From USDA to NSF

The original designations created by the USDA sought to organize food-grade lubricants into three categories. The current standards are listed below for each category:

  • H1 lubricants are used in food-processing environments where there is the possibility of incidental food contact. These lubricants are tasteless, odorless and inert. H1 lubricants are safe for human consumption in small amounts, under 10 parts per million (ppm). They are most often used in for machinery such as conveyors and mixers. Applications of these lubricants include: blending, cutting, bottling, brewing and many more.
  • H2 lubricants are used on equipment and parts where there is no possibility of incidental food contact, such as forklifts. Even though there is no contact, H2 lubricants must adhere to strict toxicology standards. H2 lubricants may not contain trace elements of: carcinogens, mutagens, teratogens, mineral acids or heavy metals.
  • H3 soluble oils are used to prevent rust on hooks, trolleys, and similar equipment. These products are typically made of edible oils such as: corn oil, sunflower oil or soybean oil. H3 lubricants are inherently biodegradable and comply with 21 CFR Section 172.860 and 172.878. They also comply with 21 CFR 182 and 184 in regards to GRAS substances.
  • 3H release agents are used on surfaces with direct contact to prevent food from adhering during processing. These lubricants can be used to aid in processes where contact is unavoidable, such as removing baked goods from a mold.
  • HT1 are heat transfer fluids used in primary and secondary heating and cooling systems in food processing facilities. These must comply with 21 CFR 178.3570 and 21 CFR 172.

The USDA served as an authority for approval and compliance. Manufacturers had to prove all components were allowable substances under 21 CFR 178.3570. The USDA stopped issuing registrations on September 30, 1998. Since then, many organizations have adopted and modified these standards.

After 1998, The German Institute for Standardization (DIN) submitted a standard to the International Organization for Standardization (ISO). Eventually the ISO adopted ISO 21469, which pertains to lubricant manufacturing, and ISO 22000, which pertains to food safety systems. However, the most recognized standards are those put forth by the National Sanitation Foundation (NSF).

As a successor to the USDA, the NSF has updated the USDA standards to improve health and safety for consumers. The current NSF standards are similar to the old USDA standards, using the H1, H2, and H3 designations. Additionally, the NSF created the HX-1 standard for ingredients. These HX-1 ingredients are pre-screened and meet requirements for finished H1 lubricants. The NSF has established itself as the recognized international standard and operates in over 80 countries around the world.

Selecting your Food-Grade Product

In the food & beverage industry, health and safety is by far the most important concern. One contamination, recall, or illness outbreak can do irreparable damage to a company’s brand and business. Therefore, it is imperative to consider selecting products that go beyond required standards. Opting to use H1 lubricants is an excellent example of meeting compliance and protecting your brand. This eliminates the possibility of using an H2 lubricant when an H1 is required. H1 lubricants can act as insurance to your brand’s equity and will reduce liability in the event of equipment or plant issues.

Performance is key when selecting a lubricant, but achieving peak performance may be more difficult with food-grade lubricants. H1 products tended to fall short compared to their H2 counterparts. This was due to the limited number of H1-registered additives compared to H2-registered additives (including zinc-based components).Food & Beverage

New NSF HX-1 additive packages have dramatically improved the performance of H1 lubricants while also meeting the rigorous standards set forth by NSF H1 lubricants. For grease thickeners, aluminum sterate, aluminum complex, organo clay, polyurea and calcium sulfonate meet H1 standards (lithium thickened greases do not). You can now use an H1 lubricant and achieve the high performance demanded from your business. It simplifies the selection process by allowing you to use H1 lubricants throughout your plant.

These additives are now paired with synthetic base oils such as polyalphaolefins (PAOs), polyalkylene glycols (PAGs), and esters. These base oils along with HX-1 additives can deliver premium performance while protecting the integrity of your brand. Selecting a product also depends on your specific processes and it is important to consider unique contaminants that may affect product performance.

Other considerations may include dietary standards. It is important to ensure your lubricant meets any Kosher or Halal requirements. Failing to do so may result in products not suitable for those whose follow Kosher or Halal diets. This results in a smaller customer base and will affect bottom lines. It could damage brand integrity if a product is marketed as Kosher or Halal and is later found to fall short of these requirements.

Takeaways

Although no government is responsible for food-grade lubricant standards, the NSF has established itself as a leader in food-grade lubricant regulations. Operating as a nonprofit in over 80 countries, the NSF ensures that your food-grade lubricants meet their rigorous standards. Modern advancements in additive technology and base oil technology have led to lubricants that are NSF compliant and meet the highest performance standards. There is no need to sacrifice safety for quality anymore.

Twin Specialties offers a wide-range of food-grade products including lubricants and cleaners. We offer products from Castrol, CRC, Lubriplate, and many more to meet your food and beverage manufacturing needs. Contact us to learn more or get a quote.