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Federal, State, and Local laws all across America and most other countries around the world now require that the oil be removed from all oil filter elements before disposing of the elements. This includes industrial filter elements as well as automotive filters. The filter elements are classified as hazardous material (waste) per Federal EPA law 40 CFR 261.3 (a) (2) (iv) and 40 CFR 262.11 c (2) because of the oil sludge which has accumulated within the filter element. There are three types of media in a contaminated filter element. (1) Free Oil - that can be poured out of the element by turning the element upside down. (2) Entrapped oil - located between the element and oil filter housing, which is held in place by an anti-backflow valve in the filter element, (3) Sludge - the filter takes contamination out of the oil stream and stores it in the filter element.
This sludge has the consistency of peanut butter. The only way to remove it is to force the sludge out with a oil filter crusher. All engines' oil filters have anti-black flow valves built into the filter element. The purpose of the anti-backflow valve is to prevent the oil in the engine from returning to the crankcase. So when you start your engine in the morning or after it has been shut down, the oil will remain in the engine and is instantly available for lubrication. However, the anti-backflow valve does prevent any draining of entrapped oil and sludge. Hydraulic filter elements follow the same valve process in most filter elements. Draining the filter element alone will only remove a portion of free oil that has not been trapped by the anti-backflow valve. The rest will remain in the oil filter element along with all of the entrapped oil sludge. If you were confronted by the EPA, could you prove you drained the element and removed all or most of the contamination from the oil filter element? You may risk facing an EPA fine of hundreds of thousands of dollars. Having the ability to crush filter elements to the size of a hockey puck would be sufficient proof for the EPA.
Crushing the oil filter elements converts and re-classifies the filter elements from hazardous waste classification to solid waste classification, or just plain garbage. At this point the filter element may be sold to a scrap iron dealer for cash, or sent to a standard solid waste landfill. The EPA law does not require all of the oil to be removed from the filter element for re-classification to solid waste, but does require most of the oil or about 95% of the oil and sludge be removed. Many companies are contracting with others to have the filter elements hauled off and disposed. This is very costly considering the charges are from a few hundred dollars a barrel to several thousand dollars a barrel. Most customers think this lets them off the hook as far as liability is concerned... not so...It is a serious mistake , since the liability always remains with the primary generator according to the EPA. Companies who think they are escaping liability by contracting with some recycling company to haul their filters away will find that they are the ones who will have to pay huge fines and superfund penalties. Some recycling companies have insurance and will quickly reveal this to their customers. But, be aware that the insurance covers only the recycling company...not you the customer. The primary generator is where the liability really lies. You are not covered...no matter what the recycler says. The best insurance is to use oil filter crusher equipment on your premises, and convert the hazardous waste filter elements to solid waste (standard garbage) before you have them hauled off. Therefore, if there is a spill or improper disposal of the elements, you would be off the hook as far as hazardous waste is concerned and your liability would be zero. Additionally, using a filter crusher reduces the volume of the waste, saving more money, and reducing environmental impact. Two types of filter crusher units are available on the market. One produces approximately 25 tons of crushing force to convert elements to a hockey puck size, removing 93% to 97% of the oil and sludge. The second type is a filter denter, that uses nothing more than 100 PSI of air pressure and produces a partial crush or a dent on the filter element. The denter will not remove the required amount of oil from the filter element. The reason for the tonnage required to completely crush elements is because of a steel stem in the center of the oil filter element.
This steel stem is the main support for the filter, and the tube through which oil travels. The steel tube, plus side supports, require tremendous force to crush. Many air operated crusher (denters) require 125 PSI to 150 PSI. Most standard air compressors will only produce up to 120 PSI. By the time air goes through air lines to an air operated crusher, the pressure will usually drop to about 80 PSI.
The best filter crusher is usually hydraulically operated and generates up to 10,000 PSI and when acting on a cylinder producing 50,000 lb, or 25 tons of crushing force. According to the American Filter Manufactures Council, approximately 400 million filter elements are sold in the United States alone annually. Filters contain 80% steel with the remaining percentages consisting of paper filter media, rubber parts, and adhesives according to the American Petroleum Institute. Also the American Petroleum Institute study shows that residual oil generally remains in the filter as a result of the anti-drain back valve, oil saturation in the filtration media, and through molecular bonding to the metal. The institute further states that crushing filters should remove around 90 percent of the used oil - the greater the compression force of the filter crusher, the greater the yield of used oil. The following summary was extracted from a letter written by the U.S. environmental Protection Agency, Region 1, J.F. Kennedy Federal building, Boston, Massachusetts.
To summarize EPA's determination in the matter of the used oil filters, the liability of correctly identifying the nature of a waste. Used oil filters are a solid waste. If the used oil filter is drained and crushed to remove as much of the oil as possible, the oil is managed according to the standards set forth in the Federal Law 40 CFR, Part 266. The crushed cartridges are sent to be legitimately recycled as scrap metal.
Testing the filters for characteristics of hazardous waste is not necessary. Although referencing a legitimate study on used oil filters may supplement a generators knowledge about the waste, EPA cautions relying on this as a sole basis for determination.
The caution mentioned by the EPA is that draining alone will not satisfy federal law. The EPA warning generators of used oil filters not to rely on mis-information from uniformed sources. Consequences for liability are too great.
A crushed filter with approximately 50,000 lbs of force applied, is simple evidence that most of the oil is out of the filter element, and that the filter can be reclassified as non-hazardous solid waste. The key to limiting your liability is to crush the filters on your premises. The MC700 filter crusher is a single crusher, manually loaded, producing 50,000 lbs or 25 tons of crushing force. It has an air drive hydraulic booster system, an uses no electrical components. The air driven hydraulics allows the customer the ability to crush not only oil filters, but other fuel filters and gasoline filters without fear of combustion. The crusher uses safety interlocks so the system stops if the door is opened. The AU1500 Filter Crusher has an automatic feed system. It uses two decks that hold up to 10 filter elements at a time, each deck, depending on the size. The decks each have an automatic feed system so that when one filter is being crushed the other deck automatically loads another filter into the filter crusher. This equipment will crush a filter element every 6 seconds. Two tanks receive use oil from the filter elements. The Bulldog Filter Crusher is designed for large quantities of filter elements. This machine shreds and crushes 8 to 10 drums of filters per hour. 55 gallon drums are loaded onto a drum dumper and the load is dumped onto a sort table where anything other than filter elements are culled out and discarded. The cleated conveyor lifts the filter elements up an incline to the top of a large crusher/shredder box and drops them into the filter crusher. The filter elements are crushed and shredded, and the oil is collected in a sump at the bottom of the Bulldog Crusher. The crushed and shredded filters are then dropped onto an output conveyor and carried away to a customers scrap iron trailer. A compactor called "Hercules" will bale scrap iron from the filters into a block form for easy handling.
Filter Crusher equipment is in your future. The laws are already out and being enforced. Don't let the EPA make an example of you with their huge fines and penalties. Crush filter elements on your premises with a filter crusher and end your Hazardous Waste Liability by converting the filter elements to harmless solid waste and easy disposal.
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