Monday, August 1, 2011

Interlux Waterfront Challenge Sea Scout Project & the E.P.A.

Below is a copy of an email from Ohio EPA giving us guidance and useful information on crushing used oil filters.

From: Jeff Mayhugh, Supervisor
Hazardous Waste Compliance and Inspection Assistance
Division of Materials and Waste Management

As I promised here are some links to guidance and information that should help you in determining the applicable used oil management standards for crushing used oil filters at marinas.

If the boat owner uses the crushing device to remove used oil from the filter, they are not considered to be a used oil processor.   See paragraph (B)(b)(iv) of the following rule    If the crusher is centrally located at a marina for use by boat owners who are doing their own maintenance the marina owner/operator would be considered to be a used oil collection facility and must comply with the following rule:   This means the marina would have to register with the Ohio EPA and comply with the used oil generator standards for management of the used oil.  See the following rules:

If the marina owner/operator crushes used oil filters that they generate while performing maintenance services for boat owners, they would be subject to the used oil generator requirements.

Metal from either of these scenarios that is sent for recycling is not regulated as hazardous waste.  Any used oil generated from either scenarios must be managed as used oil in accordance with the applicable requirements in the following chapter of the Ohio Administrative Code

You might also be interested in the information at the following  link:

 Per Mr. Jeff Mayhugh, the scrap metal dealer will  be the one who determines the point at which a crushed oil filter can be considered scrap steel. There should be no free oil draining from the filter.

States are banning used oil filters from landfills, for example Wisconsin effective January 1, 2011 has done so. 

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