Ensuring Sustainability: A Comprehensive Guide to Used Oil Management Under CPCB’s EPR Framework

January 15, 2025 by
EcoNexa Solutions Private Limited, EcoNexa Admin
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The Central Pollution Control Board (CPCB), under the Ministry of Environment, Forest, and Climate Change, has published detailed "Guidelines for Collection, Handling, Transportation, and Storage of Used Oil" to streamline the sustainable management of used oil in India. This document comes in the wake of the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023, which introduced Extended Producer Responsibility (EPR) for used oil management. These rules will take effect from April 1, 2024, creating a robust framework to tackle the environmental and safety challenges associated with used oil.

Why Do We Need These Guidelines?

Used oil, categorized as hazardous waste under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, poses significant risks to the environment and human health. Improper disposal can contaminate water, soil, and air, leading to long-term ecological and health issues.

The CPCB’s guidelines aim to ensure:

  • Environmentally Sound Used Oil Management: Promoting safe collection, transportation, and recycling of used oil.
  • Compliance with Environmental Regulations: Aligning with existing laws and international best practices for hazardous waste management.
  • Circular Economy for Oil Products: Encouraging re-refining and reintroduction of recycled oil into the market, reducing dependency on virgin oil production.

Key Highlights of the Guidelines

1. Background

EPR requires producers and importers of base and lubrication oils to take responsibility for managing the end-of-life oil products. This includes procuring EPR certificates from registered recyclers through a centralized portal developed by CPCB. The portal also facilitates registration, certification, and reporting to ensure compliance and transparency.

2. Objective

The guidelines provide a standardized framework for handling, storing, and transporting used oil safely while complying with regulatory requirements. It aims to minimize environmental impact and promote a circular economy for industrial and automotive oils.

3. Role and Responsibilities of Collection Agents

Collection agents play a vital role in retrieving used oil from unorganized and bulk generators and ensuring its proper management. Key responsibilities include:

  • Safe Collection: Aggregating used oil from industrial, commercial, and automotive facilities with proper documentation.
  • Transport Compliance: Using registered, GPS-enabled vehicles equipped for safe handling.
  • Proper Storage Facilities: Following strict protocols to prevent spillage, contamination, and fire risks.

4. Categorization of Collection Agents

Collection agents are classified into two categories based on their operations:

  • CA-1 (Level 1): Engaged in collection and transportation without storage facilities. They operate within 75-150 km of registered recyclers or higher-tier collection agents (CA-2).
  • CA-2 (Level 2): Equipped with storage facilities and a fleet of vehicles, CA-2 agents handle collection, storage, and transportation on a larger scale. They also maintain connections with CA-1 agents and recyclers.

5. Regulatory Requirements

Compliance with the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 is mandatory. This includes:

  • Consent and Authorization:
    • CA-2 agents must obtain consent to establish and operate storage facilities.
    • All collection agents must register on the CPCB’s EPR and National Hazardous Waste Tracking System (NHWTS).
  • Records and Reporting:
    • Maintain detailed records of collected, stored, and transferred used oil.
    • File quarterly and annual returns via the EPR portal.
  • Packaging and Labeling Requirements:
    • Use robust, corrosion-resistant containers.
    • Ensure clear labeling with hazardous waste warnings, origin details, and emergency contacts, as per Form 8 of HOWM Rules, 2016.

6. Handling of Used Oil

Handling used oil requires specialized equipment and practices to prevent spillage and ensure worker safety:

  • Specialized Equipment: Facilities must include forklifts, overhead cranes, transfer pumps, and spill kits.
  • Safety Measures: Emergency showers, eyewash stations, and personal protective equipment (PPE) for workers are mandatory.
  • Spillage Prevention: Containment systems and proper housekeeping protocols must be implemented.

7. Transportation of Used Oil

Transportation is a critical aspect of used oil management. Key requirements include:

  • Vehicle Standards:
    • Use GPS-enabled, leak-proof vehicles labeled for hazardous materials.
    • Equip vehicles with first-aid kits, spill control equipment, and fire extinguishers.
  • Driver and Documentation Requirements:
    • Drivers must have valid licenses and at least five years of experience in transporting hazardous materials.
    • Maintain proper documentation, including manifests, for transparency and traceability.

8. Storage of Used Oil

Storage facilities must adhere to stringent safety and environmental standards:

  • Infrastructure Design:
    • Designate separate tanks for different types of used oil, such as transformer oil and engine oil.
    • Include bund walls, spill collection systems, and flameproof electrical fittings.
  • Fire and Safety Measures:
    • Install fire detection and firefighting systems.
    • Clearly label drums with details of content type, quantity, and date of storage.
  • Storage Duration:
    • Used oil must not be stored for more than 90 days by CA-2 agents.

9. Manifest System for Traceability

The movement of used oil must follow the CPCB’s manifest system to ensure traceability and accountability. The process involves:

  • Preparing seven copies of the manifest in specific color codes.
  • Distributing copies to SPCBs, transporters, and receivers for detailed monitoring.

Ensuring Compliance and Sustainability

The CPCB’s guidelines aim to establish a sustainable and compliant system for used oil management. By promoting recycling and re-refining, the initiative reduces environmental pollution and supports the principles of a circular economy for oils and lubricants.

Conclusion

Effective implementation of these guidelines is essential for a greener and cleaner future. Stakeholders, including producers, recyclers, collection agents, and local authorities, must work collaboratively to achieve the objectives of the EPR framework.

India’s proactive approach sets a benchmark for sustainable hazardous waste management and ensures environmental safety while contributing to economic growth through resource recovery.

Stay Compliant, Stay Sustainable!

For more details, you can access the official CPCB guidelines here.

https://cpcb.nic.in/openpdffile.php?id=TGF0ZXN0RmlsZS80MzJfMTczNjQxNzAyNF9tZWRpYXBob3RvNTk5LnBkZg==


EcoNexa Solutions Private Limited, EcoNexa Admin January 15, 2025
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