Used Oil FAQs

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This Used Oil FAQ is designed to answer frequently asked questions and violations encountered during inspections.

	What is used oil?
	Who is regulated?
	Is used oil from households regulated?
	Is used oil considered a hazardous waste?
	Is waste from cleaning up a used oil spill considered hazardous waste?
	What are some common Used Oil violations found during inspections?
	What needs to happen in the event of a spill?
	What is a spill kit and what should be included in a spill kit?

What is used oil?

Used oil is defined as any petroleum product refined from crude oil or any synthetic oil that has been used and has been contaminated as a result of that use. Used oil is free-flowing liquid as standard temperature and pressure and has a flash point greater than 100 degrees (F).

The term "used oil" does not include fuels or solvents, but may include:

vehicle crankcase oils, transmission fluids and power steering fluids;
hydraulic, compressor and straight cutting oils;
tramp oil and oil drained from evaporators.

For additional information concerning the proper management of Used Oil, see the Used Oil Factsheet.

Who is regulated?

All commercial or industrial businesses that generate used oil must adhere to the Used Oil Management Standards of Subchapter 8 of the Vermont Hazardous Waste Management Regulations (VHWMR).

Is used oil from households regulated?

Homeowners (such as individuals performing repair work on their own vehicles) or “Do-it-yourselfers” that generate used oil are not regulated under the VHWMR. However, Do-it-yourselfers may not dispose of their used oil in the trash, in landfills, on the ground, or to sewers or waterways. Instead, Do-It-Yourselfers should contact their local solid waste district or municipality to find out what disposal options are available. In addition, some service stations, auto parts stores and quick-change lube centers will accept used oil from household Do-It-Yourselfers. More information can be found here regarding used oil and other Household Hazardous Waste.

Is used oil considered a hazardous waste?

Used Oil that is reused, processed or burned for energy recovery is not regulated as Hazardous Waste in Vermont. Used oil is regulated under the ‘stand-alone’ Used Oil Management Standards included in Subchapter 8 of the VHWMR. However materials contaminated with used oil may be a Vermont listed waste (VT02) (see next question below). See Subchapter 7-805 of the VHWMR for used oil determination.

Is waste from cleaning up a used oil spill considered hazardous waste?

If waste derived from cleaning up a used oil spill contains greater than 5% by weight (i.e. personal protective equipment, absorbent pads, or granulated absorbent material) it is regulated as a Vermont listed hazardous waste under the VT02 listing (see VHWMR section 7-211).

What are some common Used Oil violations found during inspections?

Some of the violations commonly associated with the management of used oil are described below. Pictures are provided to show examples of the violations and corresponding compliant situations.

Improper Storage:

Used oil may be stored in containers or tanks. If stored in containers, containers must be in good condition and made of or lined with material that is compatible with the used oil. Containers must be stored on an impervious surface (like whole, un-fragmented concrete or asphalt) and within a structure that sheds rain and snow.

Proper Storage Examples: (on an impervious surface, inside a structure that sheds rain and snow)

Improper Storage Examples:

Containers must be in good condition and kept closed when not adding or removing used oil. The following pictures depict “open containers” violations found during inspections:

Open containers:

Helpful Tip: Containers with open-ended funnels are still considered open containers. Most online industrial supply stores have funnels with lids that close and, if necessary, can be locked. Acceptable funnels must screw into the bung opening and have a lid that latches closed.

Examples of Improper Storage resulting in potential violations:

In both instances, drums are considered stored outside, not in a structure that sheds rain or snow and not on an impervious surface.

Improper (or lack of) Marking and/or Labeling

Any container that holds used oil must be marked or labeled with the words "Used Oil". Proper labeling may be accomplished in a variety of ways; you do not need to purchase pre-printed labels (see below).

Labels

Stencils

Handwritten

Failure to evaluate used oil prior to burning:

Total Halogens Field Screning: Used oil generators that burn their own oil on-site, or that burn off-site generated used oil received in shipments of less than or equal to 55 gallons, in small fuel burning equipment, must initially test the used oil from each source for total halogens. If there is reason to believe that any of the remaining Table 1 specifications would not be met by a volume of used oil, the used oil burner must test the used oil of any suspected constituents or properties. For more information regarding testing see test method SW-846, Edition III.

Field screening used oil for total halogens:

TABLE 1 - USED OIL FUEL SPECIFICATIONS

Constituent/Property	Allowable Level
Aresenic	5 ppm maximum
Cadmium	2 ppm maximum
Chromium	10 ppm maximum
Lead	100 ppm maximum
Flash Point	100 degrees F minimum
Total Halogens	1000 ppm maximum*
Polychlorinated biphenyls (PCBs)	<2 ppm maximum
Net Heat of Combustion	8000 BTU/lb minimum

*Used oil containing more than 1,000 ppm total halogens is presumed to be a hazardous waste as specified under Section 7-805(f).

Note: "ppm" means "parts per million" by weight on a water free basis.

	Helpful Tip: Never accept used oil for burning from unknown sources without first verifying that the used oil meets the Table 1 specifications and documenting the following information, which must be maintained for three years.
	Date Collected	Quantity of Used Oil	Name and/or Business of where it came from	Source/Process that generated used oil	Test Results (if first time accepting used oil from this source or process has changed)

Failure to notify of collecting used oil for burning

Collecting used oil for burning requires the burner of used oil to notify the Waste Management and Prevention Division using the Vermont Hazardous Waste Handler Site Identification Form. The Site ID form along with instructions can be found here. For further information regarding burning used oil, see the Burning Used Oil Factsheet.

The Vermont Department of Environmental Conservation Air Program also has certain requirements regarding burners with greater than 500,000 kW output (or a combined output of greater than 500,000 kW if you have multiple burners) and will need to be notified. Information regarding the Air Program can be found here.

What needs to happen in the event of a spill?

In the event of a spill, a used oil handler is required to perform the following cleanup steps:

Stop the release
Contain the released used oil
Clean up and manage properly the released used oil and other materials so that they no longer present a hazard to human health or the environment
If necessary, repair or replace any leaking used oil storage containers or tanks prior to returning to service

What is a spill kit and what should be included in a spill kit?

A spill kit is a collection of items to be used in the event of a spill, leak or other discharge of used oil to contain the released used oil. Spill kits are developed so that a prompt response and clean-up may be performed. Spill kits for used oil are typically composed of protective clothing or Personal Protective Equipment (PPE), sorbent material, a shovel or other devise to move sorbent material and a container to collect and store the clean-up material. Spill kits should be kept close-by to storage areas. For further information about spill kits see: Spill Kit FAQs

Helpful Tip: Clean up materials, including but not limited to sorbent materials and PPE, may be subject to regulation as hazardous waste if it meets the criteria for the VT02 hazardous waste code listed under 7-211 or if they exhibit a hazardous characteristic.