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| Overview: | To classify used
oil filters as non-hazardous solid waste for disposal purposes or for metal
recycling, filters are crushed or otherwise voided. 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 federal 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 40 Code of Federal Regulations (CFR) Section 261.4(b)(13), "Exclusions" states non-terne plated used oil filters are excluded from regulation as a hazardous waste provided they are not mixed with any of the wastes listed in Subpart D, "Lists of Hazardous Wastes." Specifically, three criteria for the filters must be met: 1) the filters must not be terne plated; 2) must not be mixed with other listed hazardous waste; and 3) must be gravity hot-drained. These criteria are further explained as follows. Non-Terne Plated
Mixture Rule Gravity Hot-Draining
The EPA defines hot draining in the Federal Register, Volume 57, Page 21523 (57 FR 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. |
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| Compliance Benefit: | According to 40 CFR
261.4(b)(13) non-terne-plated used oil filters that are not mixed with
other wastes are not considered to be hazardous and therefore 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. By decreasing the quantity of hazardous waste generated monthly,
facilities can reduce their generator status and correspondingly reduce their
regulatory burden (e.g., recordkeeping, reporting, inspections, transportation,
accumulation time, emergency prevention and preparedness, emergency response)
under RCRA, 40 CFR 262. This also helps facilities to
meet the requirements of waste reduction under RCRA, 40 CFR 262; the Pollution
Prevention Act (42 USC 13101-13109); and Executive Order (EO) 13148, Greening
the Government Through Leadership in Environmental Management. Facilities should
note that some states may have stricter requirements for the management of used
oil filters.
The compliance benefits listed here are only meant to be used as general guidelines 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. |
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| Materials Compatibility: | Oil filters should be segregated from hazardous wastes so that they will not be considered hazardous waste under the "Mixture Rule". |
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| Safety and Health: | Care must be taken when handling oil filters. Skin absorption is a concern when handling oil-containing metals. Proper personal protection equipment is recommended. Consult your local industrial health specialist, your local health and safety personnel, and the appropriate MSDS prior to implementing this technology. |
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| Benefits: |
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| Disadvantages: |
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| Economic Analysis: | 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:
Table 1. Annual Operating Cost Comparison for Diversion and Disposal of Oil Filters by Crushing with Steel Recycling
Economic Analysis Summary:
Click Here to view an Active Spreadsheet for
this Economic Analysis and Enter Your Own Values. |
| NSN/MSDS: |
*There are multiple MSDSs for most NSNs. The MSDS (if shown above) is only meant to serve as an example. To return from the MSDS, click the Back arrow on the Tool Bar.
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| Approving Authority: | Appropriate authority for making process changes
should always be sought and obtained prior to procuring or implementing any of the technologies
identified herein. Authorized state hazardous waste agencies should be contacted to
determine specific requirements for oil filter crushing. |
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| Points of Contact: | For more information |
| Vendors: |
This is not meant to be a complete list, as there may be
other suppliers of this type of equipment. |
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Autop of North America P.O. Box 150146 Nashville, TN 37215 Phone: (615) 255-7434 FAX: (615) 255-7439 Contact: Mr. Jim Rau E-mail: jprleasing@aol.com |
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| Related Links: |
Oil Filter Crusher – Navy Environmental Quality Initiative (EQI)
Oil Filter Crusher – Pollution Prevention Equipment Program (PPEP) Book |
| Sources: |
Mr. Ronald Jahns, Dallas REO, December 1999. Mr. Dale Fox, San Francisco REO, November 1999. Mr. Michael Viggiano, Naval Facilities Engineering Service Center, February 1999. Mr. Pano Kordonis, FASTT Team, January 1999. |
| Supplemental: |
Picture of Oil Filter Crusher - Environmental Quality Initiative
Picture of Oil Filter Crushers - P2 Equipment Program
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