Brouhaha Over Paper or Metal – Management of Used Oil & Fuel Filters (CA ONLY), July 2016

BACKGROUND:  Used Oil Filters may exhibit hazardous characteristics and hence are 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. Used oil filters must not be disposed in trash cans or at nonhazardous waste landfills.  Legislation was enacted in 2004 (AB 2254, Aghazarian) that allowed spent fuel filters from automobiles be added to spent oil filters for disposal.

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Refrigerant Recycling Requirements For Motor Vehicles Under Clean Air Act (CAA), October 2006

Background:  Since July 1992, regulations promulgated under the CAA require that motor vehicle air conditioning refrigerant be recycled.  Last week, auto dealers in San Francisco area were penalized for violations arising under this act.  We must note that these CAA regulations are federal regulations and are applicable to all auto dealers in the US and not to San Francisco dealers alone.  To achieve compliance under this regulation, dealers must act as follows:

  • Clean Air Act Section 609 Technician Certification Program:  All employees working on A/C systems must be trained and tested by a program approved by EPA on how to properly recover and recycle refrigerant (such as Freon 12, HFC-134(a) or any other approved by EPA approved refrigerant).
  • Clean Air Act Section 609 Approved Equipment:  Must utilize EPA approved recycling equipment and mail a completed USEPA Refrigerant or Recycling Device Acquisition  Certification Form to EPA.

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Hazardous Waste Manifest Changes, August 2006

Background:  Present US law requires that most hazardous waste be transported from hazardous waste generators (dealerships) to permitted recycling, treatment, storage, or disposal facilities (TSDF) by registered hazardous waste transporters, and that each shipment be accompanied by a hazardous waste manifest. The manifest is the document that provides information for “cradle-to-grave” tracking of the hazardous waste.

The good new is that the dealers in California and other states do not have to manifest used oil, used coolant, used oil filters or any of the Universal Wastes.  The only waste that is regularly manifested to disposal from dealerships’ is their clarifier sludge.  As of July 2000, manifests were no longer required in California for parts cleaning solvent (both water based and petroleum based) even though certain haulers continue to manifest the parts washer waste.

Every state had a different manifest and believe me; they were as different as they could be.  California had a six-page manifest with blue, white and yellow colors.  Texas, Arizona and Alabama each had them in different colors and formats.  In summary, keeping track of manifests was a state-to-state mission and confusing at best.  Now the Feds have marched in with a new manifest applicable to one and all in every state.

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Fluorescent Lamps & Used Batteries Recycling, January 2006

On February 8, 2006, regulations that require recycling of mercury containing fluorescent lamps, batteries, (non-automotive type) and other mercury containing materials will be prohibited from disposal as ordinary trash and required to be recycled.  Some of the Universal Wastes that require recycling is as follows:

  • Fluorescent Lamps
  • Mercury Containing Switches, Novelties & other products
  • Batteries (non-automotive kind)
  • Non-Empty Aerosols
  • Cathode Ray Tube

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