Editorial Backgrounder written for AlliedSignal Inc.,
Fram Aftermarket Filter Division by Richard Stewart
Understanding Latest Federal Regulations
for Used Motor Oil and Oil Filter Disposal
The latest federal ruling that classifies used motor oil and most oil filters
as non-hazardous comes as welcome news to fleet operators and others
who generate these wastes in the normal course of operation. The decision
by the U.S. Environmental Protection Agency means the trucking industry
is no longer forced to bear the significantly higher costs associated with
hazardous waste disposal.
But even with the EPA's favorable decision, states and localities seem
more determined than ever to keep these wastes out of their landfills. As a
result, increasing numbers of fleets and maintenance shops are looking at
a variety of ways, including recycling, to solve this disposal problem.
Waste reduction, another part of the ultimate solution, is being addressed
by engine and filter manufacturers. For example, Fram filter designers at
Allied-Signal, Inc. Aftermarket Filter Division are developing high-capacity
filters and investigating other ways to reduce waste associated with vehicle
States Getting Tougher
Regardless of the EPA classification, chances are the industry will undergo
more scrutiny from state and federal regulators. State laws are becoming
tougher, and 17 of the 50 regulate the disposal of oil filters in landfills. With
the heightened concern for the environment, more and more states can be
expected to prohibit the disposal of used filters as normal waste.
States with more stringent regulations on used oil filters than the EPA
include: California, Connecticut, Florida, Illinois, Indiana, Kentucky, Maine,
Minnesota, New York, North Dakota, Oregon, Rhode Island, Tennessee,
Texas, Utah, Vermont, and Wyoming. In addition, Minnesota, Rhode
Island, and Tennessee list used oil filters as hazardous waste.
Confusion over how to dispose of oil and filters without running afoul of the
law — and risking stiff fines and cleanup costs — has resulted from a federal
regulatory process that started 14 years ago. That's when the EPA first
proposed to list used oil as hazardous waste. In time, oil filters were added
to the discussion. It was felt that oil filters must be hazardous by association.
In 1986, the EPA classified used oil as non-hazardous, but a court ruling two
years later forced it to reconsider.
Because of the stigma and costs attached to a hazardous waste classification,
the EPA was very sensitive to any potential backlash from its ruling. A
hazardous listing might discourage recycling, the regulators feared, and result in
an increase in illegal dumping of oil and filters. But eventually, after all the
comments were evaluated, new regulations were issued. And neither used motor
oil nor the majority of used oil filters are now classified as hazardous, as long as
the oil is drained from them. Prior to disposal or recycling, filters must be
hot-drained (12 hours is recommended) by one of the following methods:
• Drain after puncturing the filter dome or disabling the anti-drain-back
valve on the bottom
• Drain and crush
• Dismantle and drain
• Any other method, such as flushing with pressurized air, that removes
the used oil from the filter
Filtermakers Find Answers
An industry group, the Filter Manufacturers Council (FMC), was responsible
for producing test data in 1991 that was used by the EPA in setting its latest
standards on oil filters. The FMC testing program was headed by Anthony J.
Caronia, director of technical services of the Aftermarket Filter Division (Fram)
of Allied-Signal, Inc. It's goal was to determine if used oil filters exhibit
characteristics of hazardous waste. The FMC consulted closely with the EPA
to structure sampling, testing, and data collection methods along federal
guidelines. And the group agreed to share all of its data and findings with the EPA.
An independent research firm collected 46 used oil filters from a variety of types
of vehicles and locations around the country. The filters were hot-drained for 12
hours, and toxicity tests were conducted on them. The test used, called a TCLP
(tee-clip) for Toxicity Characteristic Leaching Procedure, detects materials that
could contaminate the groundwater through normal leaching in landfills.
Plated Filters a Problem
The research findings showed that only one type of filter exceeded any of the
federal toxicity levels. Those plated with a lead-tin alloy called terne (4 parts
lead to 1 part tin), once commonly used as a die lubricant in the manufacture of
steel filter canisters, exceeded the limits for lead (TCLP limit for lead is 5.0 mg/l).
That came as a surprise to many filtermakers, who did not suspect that a coating
on the steel itself would cause a problem. As a result, the FMC member
companies agreed to stop using terne in the manufacture of filters by the end
The EPA now lists terneplated filters as hazardous but exempts them if they are
recycled. By contrast, non-terneplated filters, after draining, can be disposed of in
a landfill if allowed by state and local regulations. State offices of the environment
or natural resources can provide the latest disposal limitations on used filters.
Terneplating of Fram filters was discontinued in 1985, when Allied-Signal
management decided to eliminate lead from its manufacturing process (electro-tin
plate replaced terne). As soon as the findings of the FMC study were released,
Allied-Signal informed all of its suppliers that it would no longer purchase anything
containing lead, citing its concern for the environment, health, and safety.
Growth of Recycling
Unlike used oil, which is commonly burned for heat or blended with diesel and
burned as fuel, used oil filters are not so easily recycled. But recently, the value of
used filters — three to five pounds of ferrous metal, burnable paper, and rubber
in a heavy-duty filter, plus some oil — has caught the attention of recyclers.
Recycling centers are listed in the Yellow Pages of the telephone directory.
In some recycling operations, the filters are melted in a kiln and the slag is
used to make steel. Other recyclers shred or disassemble the filter and separate
its component parts: metal is used in steelmaking, paper filter media is burned to
produce energy, and rubber gasket material can be used as filler in injection
mold-making, for example. The oil is collected and reclaimed, too.
Crushing used filters has become a standard practice in many garage operations
to save on storage space. Equipment is available that can compress filters into
pucks a fraction of their original size. The decision to crush them depends on
whether they end up in a smelter or in a separation-type recycling operation,
since crushed filters are more difficult to cut open.
Other Waste Strategies
Aside from recycling, new waste management strategies are being investigated
by Allied-Signal and other companies concerned about the environmental impact
of their products and manufacturing operations. Waste minimization is one
approach that can take a variety of forms. The Fram HPH6349 filter is one result
of the company's waste minimization strategies. Development of synthetic glass
media for the HPH Series led to production of a filter for Cummins engines that
increases filter capacity by 60 percent over the OE filter, while boosting efficiency
by 40 percent.
Fram engineers are also developing a replacement cartridge filter to reduce waste
and are working to eliminate the metal core in filter elements, which would yield only
a single, paper waste. A filter that can be cleaned and reused is another possibility
under study. And the company is working with a diesel engine manufacturer to
reduce the number of filters needed from three to two — cutting waste by a third.
Design for the Environment
Several years ago, Allied-Signal formed a Product Life Cycle committee to
address the environmental impact of all of its activities — from acquiring raw
materials and production, product packaging, distribution, and use, to its ultimate
fate. The goal of these efforts is to develop environmentally-friendly design and
production activities. This attitude was responsible for the company's decision
several years ago to stop using solvent paints, which can send volatile gases into
the atmosphere. Instead, powdered epoxy paint was chosen, and today no solvent
paints are used in any Allied-Signal operations.
In keeping with policies on designing for the environment, the company has
agreed to participate in a case study by the University of Michigan. The goal of
the project is the development of a manual for the EPA on how to analyze the
environmental impact of manufactured products. The study will focus on a
new-style, environment-friendly Fram cartridge filter design.
Copyright © 1998-2008 Stewart & Associates Communication Arts. All rights reserved.