Used Oil Management FAQs

Anyone who works with used oil knows how important it is to handle the resource carefully and dispose of it safely. The RCRA used oil management standards provide the guidelines you need, though it is important to note that requirements vary by state and your state’s rules may be stricter than those of the RCRA. In addition, these regulations assume that the oil will be recycled and that used oil containing more than 1,000 parts per million of total halogens is hazardous waste (and thus, must adhere to requirements for the disposal of hazardous waste). To learn more about used oil management, read through the FAQs below.

Used Oil Management

Used Oil Management FAQs

What exactly is used oil?

Oil refined from crude oil or any synthetic oil that, through use, has become contaminated by chemical or physical impurities is considered to be used oil. This includes automotive lubricating oils, industrial oils, and hydraulic oils that have been used and contaminated. Under the EPA’s regulations, if used oil is destined for recycling, it is not considered hazardous waste.

I have a small quantity generator. Is it exempt from used oil management regulations?

No, the federal guidelines do not contain exemptions for any class of generators based on used oil generation rate. Accordingly, all used oil generators (including yours!) are subject to the same standards. Your generator is only exempt if it is listed in 40 CFR 279.20(a) (1) through (4).

How long can I accumulate and store used oil at a facility?

Federal regulations do not limit the time period during which you can accumulate or store used oil. However, some states have stricter requirements regarding the amount of oil stored at one time and/or the accumulation time limit, so be sure to check your state’s guidelines.

Can I use a funnel system as a closure for a drum used to collect oil?

Federal regulations don’t include provisions regarding container funnels, and they don’t specify whether the container must be closed. They also don’t require your used oil containers to meet the requirements for hazardous waste containers. However, if the container of used oil is managed as hazardous waste (or if it contains over 1000 ppm total halogens and is considered hazardous waste by the EPA), it must meet federal requirements for hazardous waste containers. These requirements do require containers to be closed during storage. Although they don’t mention funnels directly, the EPA has said that drums with open funnels are a common mistake. So while you can use a funnel system with a drum, it must be managed correctly and should be kept shut as much as possible.

Do I need to test used oil before it leaves my facility?

Yes, you do. By testing the oil, you can inform the driver that the oil is non-hazardous. And if the oil contains high levels of halogens, it is considered hazardous waste and must be transported by a company licensed to transport hazardous waste.


Do you work with used oil? Whether you’re a generator, a collector, a re-refiner, or a burner, you may wish to employ the services of Environmental Works, a full-service environmental consulting and contracting firm. Our talented team conducts RCRA facility inspections and can assist with hazardous waste and RCRA training. We also offer hazardous waste reporting, tracking reporting, inspections, and used oil pickups and manifests in VTM. Finally, EWI also offers assistance with SPCC Plans and compliance inspection for aboveground tanks (ASTs), and we can coordinate used oil pickups and recycling for our clients.

To learn more about our services, please give us a call at 417-890-9500 or contact us online.