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What About Used Oil Manifests?

Waste
by Kelly Lagana
"Enviro.BLR.com subscribers can submit questions to BLR subject matter experts as part of their subscription. We often get questions on different used oil issues. Here’s an FAQ on manifests for used oil transporters."

We pick up used oil in the following states from a variety of generators in a number of states. What are our requirements for providing a manifest to the customers in those states that we pick up the used oil from?

Under the federal rules, a hazardous waste manifest does not need to accompany each shipment of used oil. Used oil transporters, burners, processors/re-refiners, and marketers, however, are required to keep records of all used oil shipped off-site documenting the acceptance and delivery of each used oil shipment (40 CFR 279.56, 40 CFR 279.74, 40 CFR 279.65, and 40 CFR 279.46).


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These records may take the form of a log, invoice, manifest bill of lading, or other shipping document. The tracking record, however, does not need to physically accompany each used oil shipment. For example, a used oil marketer may send an invoice incorporating all necessary information to the used oil recipient ahead of the used oil shipment instead of including the invoice with the used oil shipment. Note, however, that used oil that meets the definition of a hazardous material under the DOT hazardous materials regulations (40 CFR 279.100 to 185) may be subject to additional tracking requirements.

The states referred to in the question (IN, KY, MD, MI, NY, OH, PA, TENN, VA, and WV) do not require the use of a hazardous waste manifest in connection with a shipment of used oil, with one exception.


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Michigan requires that the hazardous waste manifest be used also in Michigan for transporting liquid industrial waste (MCL 324.12109). As defined by Michigan, “liquid industrial waste” is not a hazardous waste but a liquid waste that results from industrial, commercial, or governmental activity, or any other activity or enterprise and has been determined to be liquid by Method 9095 (paint filter liquids test) as described in the U.S. EPA publication No. SW-846. The liquid waste must also be discarded (MCL 324.12101(l)). By definition, liquid industrial waste includes used oil (as well as other materials).

Used oil handlers in Michigan must comply, therefore, with the applicable Michigan rules for both liquid industrial wastes and used oil. The state has specific requirements concerning the use and distribution of manifest copies in connection with shipments of liquid industrial waste (MCL 324.12103(1) and MCL 324.12112(1)).

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