Is the company a licensed and permitted waste transporter? (Ask to see the permit and insurance.)

Have they been inspected by EPA or the State? (Ask for a copy of the inspection report.)

Can a customer visit the facility? (Make an appointment.)

Do they have references? (Ask for a copy.)

Does the company understand the EPA rules and requirements? (Ask to see any EPA citations.)

Used metal removal fluids will be generally categorized as non-hazardous waste because whether they are straight oils, soluble oils, semi-synthetics or synthetics, they will usually end up being recycled. Waste is considered either characteristic waste (such as whether it is ignitable, corrosive, reactive, or toxic) or a listed hazardous waste. Used oil that is recycled and is also a hazardous waste solely because it exhibits a hazardous waste characteristic is not subject to the federal hazardous waste requirements under RCRA. Used oil is any used oil that is reused, following its original use, for any purpose that includes, but is not limited to, oil that is refined, reclaimed, burned for energy recovery, or reprocessed.

MRF fluid waste must be characterized. A representative sample of the waste MRF must be collected and sent to the recycling facility. The receiving facility must be told whether the shop has any reason to believe that fuels or solvents have been in contact with the used MRF. Either they or a laboratory will then do a chemical analysis of the waste (typically, this will include a Toxic Characteristic Leaching Procedure (TCLP) for metals, volatiles, and semi-volatiles; total organic halides; PCB; flash point; and pH). This analysis will, among other things, confirm that the waste MRF is non-hazardous and enable the issuance of a disposal or recycling approval from the receiving facility. Generally, there are documents that have to be prepared for each individual receiving facility; however, the sampling and analysis do not have to be repeated every time the waste is shipped (usually, it is done either on some periodic basis or if there is some change in your process or fluid use). Be aware that in some states, used oil (regardless of its content or destination) is considered a hazardous waste, and that in some other states, non-hazardous oils must be shipped using a manifest. It is crucial to know individual states’ requirements for the management of used oils. The waste facility that you select should also be thoroughly knowledgeable in these matters, and should be willing to assist shops as needed.