Waste/used crankcase oils priority substance list follow-up report: appendix c

Appendix C: Summary of Canadian and international initiatives to manage used crankcase oils

National initiatives for used crankcase oils

Provincial and territorial legislation recognizes the inherent toxicity of Used Crankcase Oils (UCO) as well as their re-use potential. Industry also recognizes the need to control releases to the environment, especially from do-it-yourself oil changers (DIYs) who may be introducing UCO to the environment when they could be returning them to a depot if it were available. DIYs are of concern for their indiscriminant disposal of UCO in landfills, in household garbage, in ditches or down sewers. The point releases are quite dispersed, but collectively they contribute pollution to the receiving environment.

The Hazardous Waste Task Group (HWTG), which involves provincial/territorial as well as federal representatives, including Environment Canada, initiated a review of control measures for UCO in 1995 (Wittwer, 2000). Results indicated that although industrial recycling of UCO through collection contractors was very successful, DIYs were still disposing of UCO into the environment, whether dumping in the garbage, down sewers or on land. The HWTG had asked Transport Canada to amend its legislation under the Transportation of Dangerous Goods Act to include tracking the movement of UCO. The HWTG also cited space heater emissions of contaminants in non-maintained equipment as a major concern for some provincial/territorial authorities.

The development in 1989 of a Canadian Council of Ministers of the Environment (CCME) Code of Practice for the Management of Used Oils called attention to the need to have a national policy to deal with used oil collection, use and disposal (CCME, 1989a,b). More recently, CCME asked Transport Canada to supplement the list of hazardous waste types by adding spent/used crankcase/motor oils to Schedule II, List II of the Transportation of Dangerous Goods Regulations. The HWTG investigated these oils and determined that lead, polycyclic aromatic hydrocarbons (PAH) and chlorinated hydrocarbons present in the waste oils are hazardous to the environment, especially in light of the volumes of used oils that are in circulation (Wittwer, 2000). Transport Canada requested, however, that Environment Canada assume the responsibility for regulating hazardous waste and hazardous recyclable material under the new Canadian Environmental Protection Act, 1999 (CEPA 1999) regulations. Transport Canada informed CCME that legally it could not expand the list of hazardous waste types under the new clear-language Transportation of Dangerous Goods Regulations.

International initiatives for used crankcase oils

Canada is a signatory to the 1989 United Nations' Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, which requires countries to track transboundary movement of their hazardous waste, including UCO. Annex VIII of the Basel Convention was developed by a multi-national working group of which Canada was an active participant. Annex VIII pertains to used oils, which includes water/oil emulsions/mixtures. Annex VIII lists those wastes that, when destined for either disposal or resource recovery (recycling), are considered hazardous waste. From this list, it is clear that the international community would consider spent or used crankcase/motor oils as hazardous and requiring pre-notification and tracking controls, in order to protect human health and the environment. The Export and Import of Hazardous Wastes Regulations (EIHWR) were the means by which Canada was able to ratify the Basel Convention and implement the conditions of the Organisation of Economic Co-operation and Development Council Decision (92)39/Final concerning the control of transboundary movements of wastes destined for recovery operations (Environment Canada, 1992). In EIHWR under CEPA 1999, Schedule III lists the wastes that require export and import notification when destined for either final disposal or recycling/recovery operations. Part III of this Schedule includes a number of entries that relate to oils, including UCO. For the purposes of the EIHWR and international movements, these oils are typically considered environmentally hazardous because they contain leachable amounts of lead, for example, >5.0 parts per million.

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