Classification of used oil filters as non-hazardous solid waste for disposal purposes or for metal recycling can often be accomplished by crushing or otherwise voiding the filters of oil. Crushing and draining used oil filters to manage as non-hazardous solid waste reduces hazardous waste disposal costs. Waste managers must contact recycling facilities to ensure drainage techniques and handling methods are compatible with the recycling facility's requirements. Waste managers must also contact their state to verify what requirements may apply beyond the following Environmental Protection Agency (EPA) requirements. Several states have more stringent requirements and do not allow the disposal of oil filters in landfills.

The EPA used oil filter regulation, published in Title 40the Code of Federal Regulations (CFR), 40 CFR 261.4(b)(13), "Exclusions" states non-terne plated used oil filters are excludeds oil filters from regulation as a hazardous waste regulations provided they are not mixed with any of the wastes listed in Subpart D, "Lists of Hazardous Wastes." Specifically, that three criteria for the filters must be are met: 1) the filters must not be terne plated; 2) must not be mixed with listedother hazardous waste; and 3) must be gravity hot-drained. These criteria are further explained as follows.

Non-Terne Plated
Terne is an alloy of tin and lead formerly used to cover the interior of oil filters. The lead content may cause terne-plated filters to become toxic.

Mixture Rule
According to 40 CFR 261.3 "definition of hazardous waste," a solid waste is exempted from regulation as a hazardous waste if it is excluded under 40 CFR 261.4(b). The exclusion in 40 CFR 261.4(b) applies only to hot-drained, non-terne plated used oil filters, that have not been mixed with wastes that are listed in Subpart D of 40 CFR 261.

Gravity Hot-Draining
Non-terne plated used oil filters are exempted from regulation as a hazardous waste provided they have been gravity hot-drained using one of the following methods:

• Puncturing the filter anti-drain back valve or the filter dome end and hot-draining;
• Hot-draining and crushing;
• Dismantling and hot-draining; or
• Any other equivalent hot-draining method that will remove used oil.

The EPA defines hot draining in 57 Federal Register 21523 as draining the oil filter near engine operating temperature and above room temperature. The EPA also recommends a minimum hot-drain time of 12 hours. The preamble also states, "if an oil filter is picked up by hand or lifted by machinery and used oil immediately drips or runs from the filter, the filter should not be considered to be drained." Some states require a greater amount of oil to be removed from the filters before recycling.

Oil filters are currently collected for recycling at Naval Station San Diego. The filters are crushed using a commercial filter crusher. All free-flowing oil is removed and collected during the crushing process. The used filters are gathered until a minimum of 5,000 pounds is accumulated. The collected filters are shipped to a local steel mill, where they are used as feed stock in the company's steel mill operations.

An oil filter crushing operation has also been established at the Puget Sound Naval Shipyard. This operation has been very successful in minimizing the hazardous waste disposal costs associated with oil filters.

According to 40 CFR 261.4(b)(13) non-terne plated used oil filters that are not mixed with other wastes are not subject to the hazardous waste regulations in 40 CFR 260 - 265 if the filters have been drained using one of several methods including hot-draining and crushing.

The compliance benefits listed here are only meant to be used as a general guideline and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g. the amount of workload involved.

Care must be taken when handling oil filters. Skin absorption is a concern when handling oil-containing metals. Proper personal protection equipment (PPE) is recommended. Consult your local industrial health specialist, your local health and safety personnel, and the appropriate MSDS prior to implementing this technology.

• Eliminates the cost and liability associated with hazardous waste disposal
• Minimizes the volume of waste disposed
• Produces steel products through recycling of the filters

• Specific criteria must be met before oil filters can be classified as non-hazardous
• Some states may not allow disposal of oil filters

According to the Pollution Prevention Equipment Program, the cost for oil filter crushers range from $700 to $5,000, depending on the crusher size needed and particular specifications. Depending on the endpoint of the crushed filters (recycled or disposed as solid waste) the economics also vary. However, in either situation, a cost savings should be realized due to the reduction of hazardous waste disposal fees and future liability.

Assumptions:

• 2,000 oil filters recycled per year
• Approximately one ounce of oil generated per crushed filter
• 100 hours annual labor for operating system, storage, paperwork, and arranging delivery
• 80 hours of annual labor for managing storage and disposal of uncrushed filters
• Labor rate: $30/hr.
• Disposal weight: approximately one pound per filter
• Hazardous waste disposal cost: $2/lb. (includes transport)
• Recycling transport: $40/yr.
• Hazardous waste transport: $100/yr.
• No profit from steel recycling
• Oil disposal cost: $0.75/gal.
• Oil filter crusher maintenance cost: $200/yr.

Annual Operating Cost Comparison for Diversion and Disposal of Oil Filters by Crushing with Steel Recycling

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Approval is controlled locally and should be implemented only after engineering approval has been granted. Major claimant approval is not required. Authorized state hazardous waste agencies should be contacted to determine specific requirements for oil filter crushing.

Air Force approval is controlled locally and should be implemented only after coordination with the installation environmental function. The installation environmental management activities should ensure local, state and Federal regulations are followed.