If your trucks collect used oil from more than one customer, federal rules treat you as a used oil transporter. That comes with a paper trail. It isn't complicated once you see it laid out, so here it is.
Are you a used oil transporter?
Under 40 CFR 279.40, a transporter is anyone who transports used oil, anyone who collects it from more than one generator and transports it, and anyone who owns or operates a used oil transfer facility. There are exceptions, such as on-site transportation and generators hauling 55 gallons or less of their own oil to a collection center.
Transporters also need an EPA identification number, which you can get with EPA Form 8700-12 or by letter (40 CFR 279.42).
The record for every shipment you accept
Each time oil goes on the truck, 40 CFR 279.46(a) says your record must include:
- The name and address of the generator, transporter or processor who gave you the oil
- Their EPA identification number, if they have one
- The quantity you accepted
- The date you accepted it
- The signature of their representative, dated when you received the oil
The record for every shipment you deliver
When you hand oil off to another transporter, a burner, a processor or re-refiner, or a disposal facility, 279.46(b) asks for the same kind of record from the other side:
- The name and address of the receiving facility or transporter
- Their EPA identification number
- The quantity delivered
- The date of delivery
- The signature of their representative, dated when they received it
How long to keep them
At least three years (279.46(d)). The same goes for the test results or information you used to decide whether a load met the 1,000 ppm halogen rule (279.44(d)).
Where paper falls apart
None of this is hard on a good day. The trouble is the other days. The ticket gets wet. Nobody's at the counter to sign. The gallons get filled in at the end of the shift from memory. Then an inspector asks for a load from two years ago and someone spends an afternoon in a storage room.
How PiqMax handles it
The driver enters gallons and gets the signature on their phone at the stop, and the receipt is stamped when it's completed. Transfers record what moved, who moved it and how much. All of it stays searchable by customer, driver, receipt number and manifest number. See used oil collection software.
Your state may ask for more than the federal rules do, so check with your state agency. This is general information, not legal advice.