Why lubricating oil is hazardous and how much is out there in SA

JEANETTE CLARK: As environmental concerns grow, waste management in South Africa is becoming increasingly regulated, with various sectors such as the electronics, lighting, packaging, and single-use plastics industries already being subjected to stricter legislation.

On March 30, 2022 the Government Gazette published a formal notice to the lubricants industry to formalise extended producer responsibility [EPR] in the sector, which requests producers of lubricant oil to implement specific additional measures.

Joining us today is Bubele Nyiba, the CEO of the Rose Foundation, to discuss these regulations and how the foundation can assist generators of used oil to comply.

Bubele, one litre of used oil can contaminate one million litres of water. Used lubricating oil taken out of cars and machines is therefore quite rightly regarded as an environmental hazard. Why is it hazardous and exactly how much used oil is out there?

BUBELE NYIBA: Used oil is made up of base oil and additives. You mix the two or you blend the two to produce a particular type of lubricant. To use an everyday example, if you are making bread, you have flour, which would be the base oil in this example, and yeast which would be the additive in this example, and you mix those two to produce bread.

So, in the lubricant environment you produce the lubricant blended … those two items, but in the use of the oil in the machine, the additive in particular breaks down and that is why the oil comes out black when you’re taking it out of the machine. That black substance, which looks very different from what you put in, in terms of colour, has some hazardous environmental effects. It would contaminate water, for example. It’s known to cause some skin cancers if the skin is exposed to it for long periods of time.

So it is something that needs to be handled with care and is regarded as a hazardous substance by law in South Africa. To that extent people need to know that they need to handle it with care, and it cannot be thrown into the environment either – on the ground for example – because it would damage the ground on which it is poured, or even the water if it gets to the underground water, for example. So it is hazardous and therefore needs to be handled properly.

JEANETTE CLARK: If we look at South Africa, how much used oil is there actually out there that needs to be handled carefully, and dealt with under the correct waste-management regulations?

BUBELE NYIBA: We estimate there to be around about 120 million litres of used oil per annum in South Africa. All that oil needs to be recovered from the generators of the used oil, the generators being those people who buy the oil in bulk and then use it in machines. So, if you talk about the transport industry, for example, bus companies would be generators because in their workshops, when they do the oil change in their buses, then they will keep that oil. That would be another example of a generator.

JEANETTE CLARK: Now, the major players in the lubricants industry formed Rose Foundation back in 1994 to manage used oil waste as part of their extended producer responsibility. Can we delve into extended producer responsibility and why the manufacturers and resellers undertook the responsibility for the management of used oil?

BUBELE NYIBA: Well, if you look at international best practice, the lubricant manufacturers all around the world – especially in Europe and in the Americas – have extended producer responsibility as part of looking after the afterlife of a product.

‘Extended producer responsibility’ is the idea that when you manufacture a product you must be mindful about how you will recover it and recycle it at the end of use.

So, the lubricant manufacturers understood that at some point in future that extended producer responsibility would become legislation in South Africa and therefore, back in 1994, they decided that it would be better to be proactive than to be reactive, and to start implementing extended producer responsibility in the lube sector. That is why the Rose Foundation is the oldest extended producer-responsibility scheme in the country, and the most successful.

JEANETTE CLARK: I would like to understand how the model works. What exactly does the Rose Foundation do to support the recycling of used motor oil in South Africa?

BUBELE NYIBA: How it works is that our role as the Rose Foundation is that we play more [a] facilitation and the champion role for the collection of the oil. What that means in critical terms is that we credit the collective and the recyclers. So, if anyone wants to be a collector, they’ll come to us and say ‘I want to be a collector’, and we would give them the guidelines of what they need to do.

Our job is to ensure that, if you want to become a collector, you can do so, and we can train you. So, we provide training and we provide support on how to collect and drop off the oil at the correct place, how to store it, and who recycles the oil.

So, our job is to play an oversight role in the system and to provide guidance and ensure that there is compliance, so that a collector, when [they have] picked up the oil from the generator and [are] taking it to a recycling plant, that collector is [doing it] in the correct way so the oil is not dripping from the point of collection to the drop-off point. It’s all done [like that] and they’re wearing the correct PPE [personal protective equipment], and the oil is transported correctly and stored correctly, so that there is no chance that that oil can spill and damage the environment.

That’s in a nutshell what our job is all about.

JEANETTE CLARK: So, Bubele, what measures exactly were published in the gazette in March?

BUBELE NYIBA: The notice that was published in March – by the way, it was not only for the oil, it was also for two other industries, pesticides and batteries, so in this line you’ve got oil, pesticides and batteries – but the oil notice specifically is saying to the lubricant manufacturers, giving them notice that the lubricant industry is receiving a notice, that it must comply with the extended producer responsibility regulations. So there are regulations up there, and you don’t have to comply with the regulations until you are given a specific notice that says go and implement extended producer responsibility. So effectively now the government is giving a directive to the lubricant industry to start implementing extended producer responsibility.

JEANETTE CLARK: And what should the generators of used oil be aware of now that that notice has been published, and the government is formalising EPR in the lubricating oil sector?

BUBELE NYIBA: Once the notice becomes final and formal, which will be issued maybe in the next month or so, the generators of used oil will be required to participate. This participation means that the Rose Foundation becomes the approved scheme for the lubricant industry – that, if you are handling lubricants, you must get rid of that oil only through the recognised scheme.

In other words, in practical terms, if there’s a collector out there who is picking up oil from a generator, but that collector is not with the Rose Foundation, it would be illegal for the generator to give that oil to that collector. Right now, generators can give oil to anybody that they wish to, even though they were not [associated] with the Rose Foundation.

The main difference between where we are now and where the law is taking us is the fact that it is voluntary, it’s a voluntary system, so you choose to be part of the Rose Foundation as a lubricant producer and as a collector.

But with the EPR, the major shift is the fact that now the system will no longer be voluntary, so everybody will have to participate in the system. And if you are handling oil without using the recognised systems of the Rose Foundation, that would become a contravention of the law.

JEANETTE CLARK: Bubele, is it easy to approach the Rose Foundation to get that accreditation from you?

BUBELE NYIBA: Yeah, absolutely, absolutely. You do that by contacting us. You can call our office, 021 448 7492. You can send us an email on [email protected]. You can get in touch with us on our LinkedIn page, or even on our Facebook page under the name Rose Foundation. So there are various ways that you can make contact with us, and we will be ready to assist.

JEANETTE CLARK: The Rose Foundation has paved the way for extended producer responsibility since its formation, but this will now be more stringently enforced once the notice from the government is formalised, allowing for the appropriate management of hazardous used oil.

That was Bubele Nyiba, CEO of the Rose Foundation.

Brought to you by Rose Foundation. 

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