The Massachusetts Department of Environmental Protection (DEP) issued a Consent Order recently against a local power generation equipment and services company for violations related primarily to the mismanagement of waste oil. The company involved faces penalties ranging from $20,000 up to $52,880, depending on compliance with the Order.
This serves as a good reminder of the importance of properly managing waste oil, which is considered a hazardous waste in Massachusetts (MA01) and must be managed as such. It’s not only generated in industrial settings, but it’s also a common waste stream in research laboratories and is often generated from the use of vacuum pumps.
The first step is to make sure your facility is properly registered with the DEP/EPA to generate and accumulate waste oil. Registration is done on the same online registration form (using a company’s MyRCRAid account) that is used to register for other hazardous waste generated.
Often research facilities are registered as Very Small Quantity Generators (VSQG) of waste oil. This allows them to generate up to 220 pounds (100 kilograms), or approximately 27 gallons of waste oil per calendar month. The same company that’s listed as a VSQG for waste oil may be registered as a Small Quantity Generator (SQG) or Large Quantity Generator (LQG) for all other hazardous waste generated.
Once registered as a generator of waste oil, the facility must make sure to collect and store it correctly. Because waste oil is hazardous, it must be labeled properly with a hazardous waste label that indicates both “Waste Oil” and “Toxic.” It should be collected in a posted Satellite Accumulation Area (SAA), and all related accumulation requirements must be met including keeping the waste container closed when not in use, dating the container when full, and moving it to the main accumulation area (MAA) within three days.
It’s important not to forget about the required postings for waste oil when it’s being stored in the MAA. Per 310 CMR 30.253 (6), a sign must posted with the words “WASTE OIL” in capital letters at least one inch high. The sign should be posted within the MAA in an area delineated for accumulation of waste oil. An additional sign can also be placed on the door of the MAA as best practice.
It should be noted that for VSQGs of waste oil, it’s not a requirement to have a “WASTE OIL” sign in Satellite Accumulation Areas as long as the waste label identifies the waste as “Waste Oil.”
For additional information on waste oil compliance, or for questions about waste oil management practices at your facility, please email us at email@example.com.
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.