You've probably heard of halogens in relation to used oil - if the halogens are too high in your used oil, many recyclers will not accept it, and it could potentially be hazardous waste. But where are the halogens coming from, and what are the environmental, health, safety, and waste management implications?
Many products found in the shop, like washer solvents, degreasers, brake cleaners and carburetor cleaners, may contain chlorinated solvents. To check a product for chlorinated compounds, check out the list of ingredients on the container or on the safety data sheet (SDS). If an ingredient contains “chloro” somewhere in its name, it is a chlorinated chemical. Red flag!
Used oil containing more than 1,000 ppm of total halogens (for example: fluorine, chlorine, or bromine) is presumed hazardous, unless the used oil generator or handler can demonstrate that the used oil was not mixed with listed hazardous waste [40 CFR 279.10(b)(ii)]. This presumption is known as the “rebuttable presumption.” To rebut it, a used oil generator/handler must prove that used oil with more than 1,000 ppm total halogens does not contain listed hazardous waste. This documented rebuttable must be provided to the permitted recycling facility, and it should be kept on-file in case of a regulatory inspection or review.
The following used oils are exempt from the rebuttable presumption:
• Metal-working oils contaminated with chlorinated paraffins, if the used oils are to be returned to the generator for use as a lubricant, cutting oil, or coolant; [40 CFR 279.10(b)(1)(ii)(A)]
• Used oil from households or a CESQG facility; [40 CFR 279.10(b)(3)]
• Used oil contaminated with chlorofluorocarbons removed from refrigeration units when the CFCs are destined for reclamation. [40 CFR 279.10(b)(1)(ii)(B)]
Used oil containing 4,000 ppm total halogens is a hazardous waste subject to regulation, regardless of the source.
When your used oil hauler company comes to pick up a shipment of used oil, they may run a field halogens test on the oil to check to check if halogens are present in excess of 1,000 parts per million (ppm). Or they may take a sample of the load at the recycling facility. If halogen levels exceed 1,000 ppm, that spells trouble for the generator. The load will probably be rejected until further notice or until the rebuttable presumption can be demonstrated. But even then, a lot of used oil recyclers will still not accept the load.
It's critical to know what products and chemicals are being used throughout your processes, from start to finish. Regular, ubiquitous use of toxic chemicals, like chlorinated solvents, can have serious environmental and health impacts, along with important waste management regulatory implications.
