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STATEMENT ON RE-REFINED OIL FOR 

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EPA/NHTSA PUBLIC H EARING ON PROPOSED HEAVY DUTY PHASE 2 GHG STANDARDS 

AUGUST 6, 2015 

CHICAGO, ILLINOIS 

Thank you for the opportunity to provide testimony concerning the proposed Heavy Duty Phase 2 

greenhouse gas emission and fuel consumption standards published in the Federal Register on July 13, 

2015. I am here on behalf of Safety-Kieen Systems, Inc. of Richardson, TX and a number of other 

companies engaged in the "cradle to cradle'' recycling of used engine oil. These include HeritageCrystal Clean of Elgin, IL, Vertex Energy of Houston, TX, Avista Oil of Peachtree, GA, and Puralube USA, 

Inc., of Wayne, PA. Together, we collect, process, and refine used motor oil and, thereby, turn the 

most highly refined product made from crude oil into a renewable resource. 

We note that the proposed new Phase 2 standards for fuel economy and GHG reductions from these 

vehicles look at a wide range of options and call for flexibility in how manufacturers meet the new 

standards using averaging, banking, and trading (ABT). We recommend allowing the manufacturers of 

relevant vehicles to obtain credit for the significant greenhouse gas benefits associated with re-refined 

lubricating oil when such oil is supplied as original fill in the vehicle when sold. Further, we would like 

to explore with the agencies how ABT mechanisms can be used to allow credit for re-refined oil 

supplied during subsequent routine maintenance in the engines of vehicles subject to the rule. 

Re-refining used lubricating oil generates significant environmental and energy benefits and has been 

deemed by federal agencies and national research laboratories as an appropriate use for conserving 

crude oil, a non-renewable resource. 

Our independent life cycle analysis, published in an American Chemistry Society Journal after peer 

review, describes how the use of re-refined oil reduces greenhouse gas emissions, compared to the use 

of engine oil made from virgin crude. This analysis, conducted by Environ, a leading environmental 

consulting firm, estimates that production of re-refined engine oil generates 70% fewer GHG emissions 

than production of oil from virgin stock. So, for example, the total GHG savings from use of 50 million 

gallons of re-refined oil is approximately 159,000 metric tons of C02e. That is equal to avoiding 

emissions from combustion of 15 million gallons of #2 fuel oil. Simply put, every 3 gallons of re-refined 

oil used avoids emissions equivalent to burning a gallon of diesel fuel. Our published analysis shows 

that even if we conservatively include other factors such as emissions from collection of used oil, use of 

re-refined engine oil represents a 56% reduction in GHG emissions when compared to emissions 

attributable to production of lubricants from virgin oil. This is because refining engine oil from 

previously refined used oil is a more efficient process than refining comparable engine oil from virgin 

crude. 

Significant carbon reductions are achievable through use of re-refined oil to lubricate engines as 

original equipment and as part of maintenance of the vehicles. Allowing OEMs of medium and heavyduty vehicles to receive credit for these GHG savings will provide them with additional flexibility to 

achieve the targets being set by EPA and DOT. Further, allowing credits for initial fill and future 
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maintenance will encourage more companies to use re-refined oil which studies show is preferable in 

terms of reducing greenhouse gas emissions. 

When the total life cycle benefits are factored in, the use of re-refined oil has benefits comparable to 

the use of low rolling resistance tires. Also, as in the case of low rolling resistance tires, the benefits last 

as long as the original equipment is properly maintained through future maintenance intervals on the 

vehicle (in the case of the tires used) or in the vehicle (in the case of the oil in the crankcase). For tires, 

proper maintenance includes proper inflation and successive use of similar low rolling resistance tires. 

The proposed rule could easily be adapted to allow credit for the use of re-refined oil with 

demonstrated reductions in GHG emissions through both the initial crankcase fill and also during the 

manufacturer's long-term recommended maintenance cycle. Credit for future maintenance could be 

provided on a tradable basis allowing the manufacturer to buy GHG reduction credits each time the oil 

is changed using re-refined oil in the future maintenance cycle. By allowing future tradable credit, the 

manufacturer would be given an incentive to promote use of re-refined oil in future oil changes 

through sales or re-refined oil to their own network of maintenance faci lities as well as from third party 

vendors. The use of such re-refined oil would, in turn, help to reduce total GHG emissions from the 

operation of these vehicles. 

In calculating the GHG benefits we have only included the well to gate benefits from comparing the 

GHG emissions from manufacturing process for re-refined oil with that of manufacturing lubes from 

virgin crude. Several studies show significant additional benefit by diverting used oil to re-refining 

rather than combustion at the end of life. However quantification of the magnitude of those benefits 

are imprecise due to factors such as the choice of fuel combusted in place of used oil. Therefore, we 

have kept these additional benefits out of this analysis to ensure the robustness of our statements. 

We appreciate the opportunity to comment and ask that you consider this additional strategy for 

achieving the targets you have set. We would be delighted to answer any questions you may have. 

Contact: 

Barry McCabe 

Safety· Kleen Systems, 

A Clean Harbors Company 

Richardson, TX 

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972.369.6111 (m)