There has been a lot of recent activity on the subject of managing used
oil filters and some conflicting notions on how to manage them properly.
Firstly, there has been NO CHANGE in the California Code of Regulations
regarding the disposal of filters. The DTSC Regulatory Assistance Guide
Document on managing used oil filters is easy to comprehend and can be
found here:
https://www.dtsc.ca.gov/InformationResources/upload/RAG_Used-Oil–Filters
_Generators1.pdf However, enforcement of the law HAS CHANGED.
Used automotive filters that do not have a metal housing MUST be managed
separately from filters that do have metal housings. This is because
filters with metal housings are managed under a scrap metal exemption in
the hazardous waste regulations, so non-metal filters are clearly a
separate waste stream.
Metal used oil filters “must be drained of all free-flowing oil or fuel
before they are placed in storage containers. The term “free-flowing”
means a continuous stream of used oil from the filter when it is turned
over. Used oil that flows drop-by-drop is not considered to be
free-flowing.” Again, this is not anything new. This has been the rule
since the early 1990s.
Depending upon which smelting facility your hauler uses, some haulers
are making their clients crush or puncture their metal filters or pay a
higher price to have them managed as “hazardous”. This is not due to a
change in regulatory requirements. Rather, it is because their
smelting facility is unable to process filters that have even small
amounts of residual oil within the housing.
Other haulers use smelting facilities that are able to process the
filters without the generator crushing or puncturing them. The usual
draining is all that is required.
For those clients that generate a significant volume of non-metal
filters and incur higher disposal costs, MCS will be adjusting the
Hazardous Waste Recovery Fee to reflect the price increase.
Hopefully that clears up the confusion. Please feel free to contact me
if you have any further questions.
Sincerely,
Jonas Aras
Owner
ManPower Compliance Services
