Used Oil at Auto Dealerships: What EPA Actually Requires

1.Know What EPA Means by "Used Oil"

EPA defines used oil as petroleum-based or synthetic oil that has been used and, as a result of that use, has become contaminated by physical or chemical impurities.

In a dealership, that commonly includes used engine oil, transmission fluid, hydraulic oil and similar lubricating oils. Antifreeze and products used primarily as solvents are not automatically "used oil" under this definition.

That distinction matters because the easiest way to complicate used oil management is to start putting other wastes into the same tank.

2.Label the Tank "Used Oil"

EPA requires containers and tanks used to store used oil to be labeled with the words Used Oil.

Not "Waste Oil." Not "Oil." Not a handwritten abbreviation that made sense to somebody three years ago.

"Used Oil" is simple, specific and easy to verify during an inspection.

3.Keep Containers and Tanks in Good Condition

Used oil containers and tanks must be in good condition. EPA specifically warns against allowing tanks or containers to rust, leak or deteriorate.

If a structural defect develops, it needs to be addressed. A tank that "only leaks a little" is still a leaking tank.

This is one of those areas where a five-minute walk through the service department can tell management a lot. Look at the tank itself, but also look at the floor beneath it, the piping, the fill connection and the path the oil takes when technicians transfer it.

4.Do Not Mix Used Oil With Whatever Happens to Be Handy

This is one of the most important rules in the entire article.

EPA warns businesses not to mix used oil with hazardous waste. Mixing solvents or other hazardous wastes into used oil can change how the entire mixture must be regulated and can turn a straightforward recycling stream into a much more expensive hazardous waste problem.

The safest operating rule for most dealership service departments is simple: if it is not used oil, do not put it in the used oil tank.

That rule also needs to make sense to the technician standing beside the tank, not just the person who wrote the environmental policy.

5.Know What to Do When There Is a Spill

When used oil leaks or spills, EPA expects handlers to stop the release at the source, contain the oil, clean it up and properly manage the recovered oil and cleanup materials.

If the tank or container is defective, it should be repaired, replaced or removed from service.

Dealerships should also have sorbent materials readily available. The middle of a spill is a poor time to discover that the last bag of absorbent was used two months ago and nobody reordered it.

6.Use the Right Transporter

EPA generally requires used oil that is shipped off site to be handled by a transporter with an EPA identification number.

There are limited federal exceptions for small self-transported quantities. A generator can transport up to 55 gallons at a time under certain conditions, including using a vehicle owned by the generator or an employee and taking the oil to an approved collection center or an aggregation point owned or operated by the same generator.

For most dealerships, the practical answer is much simpler: know who your used oil vendor is and make sure the vendor is properly authorized to transport the material.

7.Do Not Forget the Oil Filters

Under federal rules, certain non-terne-plated used oil filters can be excluded from hazardous waste regulation when they are properly hot-drained.

EPA identifies several acceptable methods, including puncturing and hot-draining, crushing and hot-draining, dismantling and hot-draining, or another method that removes the used oil.

The oil that drains from those filters should be managed with the dealership's used oil.

State requirements can be more restrictive, so this is one area where the dealership should make sure its local procedure matches the rules in the state where the facility operates.

8.Understand When SPCC May Enter the Picture

Used oil management and SPCC are separate regulatory programs, but they can overlap.

EPA's Spill Prevention, Control, and Countermeasure rule can apply when a non-transportation-related facility stores, uses or consumes oil, could reasonably discharge oil to navigable waters or adjoining shorelines, and has more than 1,320 gallons of aggregate aboveground oil storage capacity.

The key word is capacity. EPA looks at the storage capacity of eligible containers, not how full they happen to be on inspection day. Containers smaller than 55 gallons generally are not counted toward the federal aboveground threshold.

And remember, this is not simply a used oil calculation. New oil, hydraulic oil, gasoline in qualifying aboveground storage, diesel and other oils may count too.

9.Federal Rules Are the Floor, Not Always the Ceiling

EPA makes an important point in its own used oil guidance: state regulations may be more stringent than the federal requirements.

That matters for dealership groups operating in multiple states. A procedure that works at one store may not automatically satisfy every requirement at another.

The federal rules give us the baseline. The state program determines whether anything additional is required.

The Bigger Picture

Used oil compliance is not complicated because the rules are unusually difficult. It becomes complicated when basic housekeeping breaks down.

The tank is not labeled. Someone pours solvent into it. A leak goes unnoticed. Nobody knows who the transporter is. The dealership adds another oil tank and never rechecks its SPCC applicability.

None of those things requires a complicated environmental program to prevent.

Start with the tank. Read the label. Look underneath it. Look at what employees are pouring into it. Find out who picks it up. Then look at the rest of the oil storage on the property.

A few minutes spent looking now can prevent a much more expensive conversation later.