During vehicle and equipment maintenance and repair activities, considerable amounts of used engine oil are generated. The University of Michigan (U-M) has a program for recycling as much used engine oil as possible. This reduces the total amount of waste generated, both hazardous and non-hazardous. There is also a substantial savings on labor, compliance, and paperwork costs associated with typical waste disposal procedures.


Applicable Regulations
40 CFR Part 279.

40 CFR Part 261, Subpart D.

State of Michigan Act 451 Part 121.


Overview of Procedure
Used engine oil is generated during the normal periodic preventive maintenance services conducted on fleet vehicles owned by the U-M. While a considerable amount of non-recyclable waste is created by way of soiled rags, the majority of the used oil is collected for recycling. Materials contaminated with used oil, but cleared of the used oil to such an extent that free flowing oil is not observed, are not subject to Part 279 unless they are burned for energy recovery.


Waste Minimization Procedure
Two 500-gallon used oil tanks have been installed to collect used oil generated during vehicle and equipment maintenance and repair activities. The used oil is captured in open containers when it is drained from the engine, and transferred to one of several collection point basins located around the maintenance garages. The basins are drained through a vacuum line system and transported to one of the large storage tanks. The vacuum collection system used to transfer the used oil to the storage tanks helps minimize spills. The used oil is then pumped out of the tanks into a tanker truck and transported off-site for recycling by a local vender.


Known Limitations
Used engine oil contaminated with fuel or other non-oil engine fluids cannot be recycled and must be disposed of as waste. Oil soaked rags and other miscellaneous materials that are contaminated with oil during the maintenance or repair operation must be disposed of as waste.

In addition, used oil containing more than 1,000 parts per million total halogens is presumed to be a hazardous waste because it has been mixed with a halogenated hazardous waste listed in Subpart D of Part 261.


Safety & Health Precautions/Personal Protective Equipment
Follow all applicable safety and health protocols and regulations as established by your institution.


Generation of waste oil is minimized. Recycling reduces waste disposal cost and the paperwork associated with it.


None known.


Project Related Costs
Approximate annual cost of recycling used oil: $400.

Approximate annual cost if used oil was disposed of as Act 451 Part 121 Regulated Material: $12,000.