Why industry should take advantage of the OBHSM exemption

In our industry, the 2911 Oil Bearing Hazardous Secondary Material (OBHSM) exclusion status is a powerful exemption that can make doing business easier, safer and more cost-effective while creating sustainability benefits. But it's also an exemption that's defined by a confusing checklist of technical requirements, leading to misunderstandings as to what the true nature of the benefit is.

In simplest terms, 2911 OBHSM exemption is a refinery-to-refinery exclusion. It allows qualifying refineries to ship materials and recoverable products between one another on a bill of lading without categorizing those materials as waste. Sludges, residuals or other oil-bearing materials can be exchanged between petroleum refineries while avoiding Resource Conservation and Recovery Act (RCRA) designation.

The technical and infrastructure requirements for this exemption are twofold: A company must qualify as a refinery and must be able to recover oil from the accepted material. The presence of on-site centrifuges and distillation processes are crucial to meeting those qualifications and lends operations the capability to receive these materials and recover oil from them. That recovered oil, of course, is the end goal of this allowed exemption and a significant step toward making our industry more sustainable.

The benefits of this EPA-approved exclusion are numerous. For individual refineries, being able to send these materials to another 2911 facility that can provide off-site processing creates significant cost savings. Because of the exclusion, those materials are not subject to waste taxes and will not be included in the company's EPA Annual Waste Summary. Plus, off-site processing for large-scale refineries eliminates daily equipment and labor rates, costly chemical and polymer programs, expensive roll-off boxes and safety risks associated with on-site processing. Think about it: If you could complete a project at your own site with a significant amount of additional costs and safety risks, or rely on a third-party location to handle the job and simply pay for the materials processed, what's the better choice? It's a smarter alternative to on-site centrifuge processing.

But while the cost-benefits created by this designation are perhaps the most attention- grabbing, the greater implications for our industry as a whole are even more powerful. By making it easy for large refineries to send these off-spec materials to more specialized refineries, our industry is preventing these streams from simply being categorized and disposed of as pure waste.

That's a significant win in the fight for sustainability. These 2911 facilities with threephase centrifuge capabilities can process these materials, separate the water and solids from recoverable oil, and get that oil back into our economic system for use as product instead of waste. That creates fresh value for our industry, supports a truly circular economy, and creates an opportunity for residual wastewaters and solids to be managed and disposed of sustainably, rather than being sent to a landfill as post-treatment ash. It's good for business, good for the environment and can protect refineries from lifetime liability.

It's imperative that more producers and operators take advantage of these kinds of exemptions made available by regulatory organizations like the EPA. It's a savvy business practice, streamlines operations, decreases site safety risks, and creates additional opportunities for our industry to work smarter and more sustainably. Making use of the 2911 OBHSM exclusion should give operators an extra level of security, knowing that their partners are managing residual materials safely and responsibly. There's a real opportunity to eliminate residuals and landfill liability -- the story of waste ends right there. And that's good for our industry.

For more information, visit www.circonenviro.com or call (281) 474-4210.