BACKGROUND:  Used oil filters may exhibit hazardous characteristics and are hence, classified as hazardous waste in California. To encourage recycling of used oil filters, California DTSC adopted reduced handling requirements for drained used oil filters that are sent for recycling as scrap metal. We wrote about that in July 2016 stating that you should drain the filter properly.  Now the DTSC (Cal/EPA) has started to classify all used oil filters, with a flapper valve that prevents oil from being drained out, as hazardous waste. 

DRAINING: How much is enough? Used oil and fuel filters must be drained of all free-flowing oil or fuel before they are placed in storage containers. The term “free-flowing” means a continuous stream of used oil from the filter when it is turned over. Used oil that flows drop-by-drop is not considered to be free-flowing. Filters that are equipped with a flapper valve or other device that blocks the drainage must be opened or the filter case punctured (or crushed) to allow the residual used oil or fuel to drain freely. The used oil filters with residual oil removed can be recycled as scrap metal: the cheapest option.

COSTS: The costs, safety, and effort factor vary for each of the options and we discuss them here as follows:

• Puncture: The technicians can use a rock-pick (pointed tip) hammer to puncture the used oil filter.  The effort is nominal with minimal safety concerns.  The punched oil filter can stay on the drain tray for a few hours until there is no continuous stream of oil coming out.  The filter then goes to the used oil drum for disposal for $50.  Incremental labor costs $0.
• Crusher: Cost of a new crusher can run from $1500 to $1800.  Effective labor costs for a porter to run the crusher can run up to $20/hour.  The total labor cost can vary depending upon the volume of filters.  Safety factors are repetitive trauma, sharp edges from filters and general mechanical hazards from using moving machinery.
• No Puncture & No Crusher: Used oil filters can all be placed in drums for disposal as a hazardous waste at a cost of $200/drum.

Note 1: Fuel filters must not be punched or crushed.  Actually punching or crushing them creates a fire hazard.  The fuel filters (after draining) can be placed in the metal used oil filter drum.

Note 2: Paper cartridge type of used oil filters must be disposed of as a hazardous waste for $200/drum.

Note 3: Dealers can recover all expenses related to hazardous waste disposal under a hazardous waste cost recovery program. Direct hazardous waste disposal expenses can include those paid to the hauler, hardware costs (tanks, pumps, etc.), management expenses related to hazardous waste storage, and fees/taxes paid to the government.

TRAINING:

1. Train your employees on the fact that the paper and metal cartridge filters need to go into separate drums.
2. The metal oil filters need to be crushed or punctured before disposal as recycled metal.

Ref: See CCR Title 22 Section 66266.130, Health & Safety Code 25250.22 and https://www.dtsc.ca.gov/InformationResources/upload/RAG_Used-Oil-Filters_Generators1.pdf.

DOWNLOAD:  August 2016 Newsletter