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ERM involved in API study which could impact oil recycling policy worldwide

22 March 2017


ERM and PD Consulting Environment Ltd have completed an extensive study for the American Petroleum Institute (API) on used automotive oil management in California

Assessing the potential environmental impacts of various combinations of management routes of used oil, the study can inform policy worldwide. The recently published report is the result of three years of work and involved ERM working closely with a number of high-profile API members.   

About the report
The API has published a Life-Cycle Assessment (LCA) Study of Used Oil Management which appraises used oil generation in California in 2010. However its key lessons and findings are relevant to other time periods, states and countries with findings including:

  • the impacts of the used oil management system are greatly affected by the amount of uncollected and improperly disposed used oil;
  • increasing collection results in reduced impacts;
  • for a given collection rate, the environmental impacts, and the benefits achieved, of alternative dispositions (beneficial uses) for used oil are highly sensitive to several key factors -- particularly the mix of virgin products displaced by those from the used oil management system and the level of pollution control that is used, especially for combustion of Recovered Fuel Oil (RFO is used oil burned, typically with minimal pre-treatment); and
  • no single disposition shows consistently lower impacts under all conditions, with greater benefits generally flowing from increasing collection, rather than from changing disposition.

Read the report on the API website

ERM Partner Simon Aumonier led the team working on this study: “This work shows clearly that the assumptions made with respect to displacements and pollution control can completely change the results (i.e. which treatment route has the lowest impacts) of an LCA. Where pollution controls are good and effectively applied, fuel use as RFO can have lower impacts than processing to base oil (re-refining). Conversely, in situations without good pollution control, or where cleaner fuels are displaced, reprocessing to base oil or a distillate fuel will often be better.”

ERM’s role in the study
The underlying objective of this work was in response to the California Senate Bill SB 546. In 2009, Senate Bill 546 (Lowenthal) included a number of changes to the system of fees and incentives and mandated that the California Department of Resources Recycling and Recovery (CalRecycle) carry out a Life Cycle Analysis (combining an environmental life cycle assessment (LCA) and an economic analysis) of the used oil (UO) management system in California. SB546 also required that stakeholders be given the opportunity to provide input on the 2013 environmental Life Cycle Analysis sponsored by CalRecycle.

The API has recognized the hard work done by CalRecycle and their consultants and also determined that there were still some gaps that should be addressed. ERM became involved when the API commissioned further work to build on the 2013 environmental LCA sponsored by CalRecycle and to more fully evaluate the implications of the uncertainties and choices of assumptions that were made in the assessment of options for managing used oil.

This study was undertaken in conformance with the International Standard for Life Cycle Assessment (ISO14040 and ISO14044) and was subject to a critical review by a panel of experts including:

  • François Charron Doucet, Scientific Director, Groupe AGÉCO (Chairman);
  • Christopher Loreti, Principal, The Loreti Group;
  • Keith A. Weitz, Environmental Scientist, RTI International; and
  • Richard P. Zink, Chief Process Engineer, Process Engineering Associates, LCC.

The panel’s review confirmed that the study complies with the requirements of the ISO standard, recognized the robustness of the scientific approach used and its utility for responding to the used oil management issues posed by the SB546. The study also benefited from collaborative input by a project stakeholder group made up of members of the API UOTF and CalRecycle, NORA (industry recycling association involved with used oil), and others.

David Lax, a scientific advisor with the API stated: “The study provides an authoritative and thorough analysis that addresses significant limitations of previous studies and it may inform used oil regulation in jurisdictions around the world including the discussion concerning the European Commission’s Circular Economy Package and the Proposed Directive on Waste. Ultimately it will help promote the need for increased used oil collection and treatment for beneficial use as the LCA shows clearly that:

  • improving collection yields important benefits;
  • the choice of disposition is less important; and 
  • the impacts depend critically on ensuring effective control at each stage.

“The aim for a policy maker should be an efficient used oil management system, with maximum collection rates, treatment routes for all used oil arising and effective pollution controls at each stage.”

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