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Managing post-use mineral oils

Handbook oil change

Post-use and discarded waste mineral oil is a hazardous waste and must be restrictively managed according to legislation. It cannot be burned indiscriminately but only under much specified conditions set out in the Industrial Emissions Directive.

Currently the Government in England is following Scotland and Northern Ireland and has consulted on revised guidance to effectively restrict the uses of on-site small waste oil burners that still burn untreated waste mineral oil.

In 2010 the UK introduced the revised Waste Framework Directive (rWFD) into national legisation. While all oil streams will at some time produce a waste, in general our reference to waste oil is essentially that of used lubricating oils such as engine oils and, to a lesser extent, more common fuels.

There are strict regulatory requirements for managing waste oil that reflect its hazardous nature with, for example, waste producers being required to be registered and carriers of wastes properly licensed and to use hazardous (or special) waste transfer documentation.

In pursuit of resource efficiency, it is possible through developing standards and agreement of regulators to achieve an end-of-waste status. In this way a more relaxed regulatory position can prevail and resultant processed fuels can find wider markets.

All devolved regions of the UK have adopted such a standard that defines the conditions for end-of-waste for used oils in what is generally referred to as the Quality Protocol (QP) For Processed Fuel Oil (PFO).

Its core is a technical standard that seeks to emulate certain classes of industrial fuels described in BS2869, together with certain restrictive additional parameters designed to ensure that, on combustion, the fuel will be no more harmful to man or the environment than a comparative virgin fuel.

Low crude oil values and lower market demand mean that waste oils now have a lower value too, and waste producers may now expect to have to pay for waste collections.

The picture would not be complete if mention was not made of the fact that the rWFD legislation has a requirement for waste producers to declare that they have considered the hierarchical requirements that place an option of material recycling higher than that for energy recovery.

For used lubricating oils, this asks whether the inherent basic lubrication oil fraction it contains can be recovered for reuse – a process known as re-refining. It also means that where combustion is the selected option, it needs to be justified through ‘lifecycle thinking’. Conceptually, that is energy recovery usage and not recycling, which is a fine point in law.

For all these reasons and more, those who are disposing of any form of mineral oil or wishing to seek out waste-derived fuel supplies are recommended to contact a member of the Oil Recycling Association.

The chemical recycling sector, which includes post-use solvent waste, is a highly specialised industry subject to the strict regime of the Industrial Emissions Directive.

A large number of solvents are flammable and have other hazardous properties and may be subject to other special regulations.

There are strict regulatory requirements for managing waste solvents that reflect their hazardous nature. For example, waste producers are required to be registered, carriers of wastes must be licensed and use hazardous (or special) waste transfer documentation. CRA members are also subject to major site hazard control under the Control of Major Accident and Hazards Regulations.

In 2010 the UK introduced the revised Waste Framework Directive (rWFD) into legislation and this placed a number of obligations on waste producers. While many industry user streams will at some time produce a waste, in general our reference to waste solvents is essentially that of used hydrocarbon, oxygenated or chlorinated species, for example from the pharmaceutical, coatings, printing or metal treatment industry sectors.

Recent chemicals legislation under the REACH Regulation is now in operation, covering many thousands of chemicals. It is particularly important to businesses that use substances with hazardous properties.

Solvent products are very much part of the current revised legislative practice. REACH assesses the risk of using chemicals while the Classification, Labelling and Packaging (CLP) Regulation is the mechanism by which the hazards associated with using chemicals is translated into the workplace.

While wastes are not part of REACH, fully recovered materials are, and the CRA confirms that the combination of REACH and CLP has had a marked effect on the way users and industry behave. The Health & Safety Executive is the UK competent authority for REACH/ CLP issues, and has a number of advisory publications concerning the use of chemical and solvent products.

The high cost of materials in today’s climate means that supplies of waste solvent inputs are readily sought out for recycling, so a potential polluting stream is economically and efficiently removed from the environment.

The rWFD legislation has a requirement such that when producers of waste solvent discard their wastes, they are required to declare that they have considered the hierarchical requirements that place an option of material recycling higher than that for energy recovery.

Solvent recycling is generally considered to be the best environmental option although, at times, a full recovery may be considered uneconomic and a better use may be made by putting the waste to fuel. But where combustion is the selected option, that choice needs to be justified through ‘lifecycle thinking’. Where that occurs, it is classified as energy recovery and not recycling, which is a fine point in law.

The message is clear: always seek specialist advice when undertaking the disposal of waste solvents. Those who are disposing of solvents or wishing to seek out recycled solvent supplies are commended to contact a member of the CRA.

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