Maintenance Technology June 2017 - 39

LUBRICATION STRATEGIES

the view of many jurisdictions, such oil
is a hazardous waste. Used oil, crosscontaminated with chlorinated products
or other chemical products, must
be treated as a hazardous liquid and
disposed of accordingly. Once again,
it's imperative for facility personnel to
check with their local authorities to
understand the legislative definitions
and requirements.

Management tips
Collecting used and waste oil on site is
a natural occurrence in any industrial
plant and allowable in all jurisdictions. There are, however, regulations
regarding its labelling, storage, spillage,
and disposal.
The photo on p. 38 reflects a typical
outdoor storage area for the collection of used and waste oils in a plant.
Although it shows a designated area,
it exposes a very poor-and expensive-oil-management approach that
contravenes most of today's regulations
in the following ways:
1. Used- or waste-oil tanks must be
clearly labelled and accessible. The
tanks in the photo are grated pits that
would be classified as confined spaces
and not allowed in many jurisdictions.
Only one of these two restricted-access
pit tanks is labelled as "Waste Oil," a fact
that's partially obscured by the barrels.
Given the proximity of the two pits
to each other, poor access to the rear
one, and their uncontrolled exposure
to outside elements, most regulatory
agencies would probably classify oil
pumped from both of those tanks
as hazardous waste, requiring costly
disposal procedures.

Recommendations
S Decommission the pits.
S Install two above-ground steel tanks
in accordance with regulations,
designating each separately for used
oil and waste oil. For correct tank
sizing, work with your oil-disposal
company to ascertain its minimum
and maximum haulage capability.
S Clearly label each tank in accordance
with local regulations.
JUNE 2017

S Move tanks into a controlled indoor
space or cover the area to protect
from outside elements.
S All tanks are to be bunded (placing
the tank inside a leak proof bermed
concrete, asphalt, or steel/plastic
catch-basin control area. The bund
must equal or exceed the volume of
the largest tank in that bunded area.
S Padlock tanks shut when not in use.
2. Dedicated oil-transfer containers
must be used to control cross-contamination. In the photo example the
company has a variety of different-sized
open pails containing non-descript oils
and what appears to be a white chemical
product. Once again, all of those fluids
are exposed to the elements and to each
another. That automatically makes all
of them hazardous waste. The only way
to be sure used oil does not become
contaminated with hazardous waste
is to never mix it with anything else
and store used oil separately from all

solvents, chemicals, and other incompatible products.

Recommendations
S List all oil and non-oil products
used in the plant and work with
your oil-disposal partner to decide
which products are to be treated as
recyclable used oil, waste oil, and
hazardous materials (chemicals and
non-oils).
S Use closed, dedicated containers
for used oil, waste oils, and other
products stored in the same area.
S Log any bulk transfer of oils into
the tanks.
S Record all products being held in
the area on a manifest and log their
release to the disposal company.
S Retain all records in a accordance
with the company's record-retention
schedule.
3. Spill controls are mandatory.
Although the photo on p. 38 also shows

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MAINTENANCETECHNOLOGY.COM | 39
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Table of Contents for the Digital Edition of Maintenance Technology June 2017
