Can Washwaster be considered Used Oil? Do not confuse oily washwater with used oil. Used oil may be called oily washwater under the Clean Water Act, but not all oily washwater is used oil as defined by the Resource Conservation and Recovery Act (RCRA). Oily washwater is subject to the hazardous waste rules, but used oil is only subject to the used oil requirements; it is not subject to the hazardous waste generator, transporter, or treatment storage and disposal facility (TSD) standards when it is recycled. When used oil is removed from a part by washing with a solvent (including water and a surfactant or detergent), the act of washing generates a new waste that is subject to a hazardous waste characterization. The used oil loses its identity in the washwater. Washwater is a "spent material" because it was used during manufacture or treatment of the part, and as a result of contamination, can no longer serve the purpose for which it was produced unless it is processed. Spent materials are solid wastes when they are reclaimed and are considered to be reclaimed if they are regenerated or processed to produce a usable product. Contact our office to learn more about the management standards between oily washwater vs. used oil.
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