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EPA Victoria developed the Classification for unprocessed used cooking fats and oils (PDF 114KB; the classification) to provide clarity for industry and reduce the regulatory burden associated with the management of unprocessed used cooking fats and oil where there is low risk to human health and the environment.
As a liquid waste, unprocessed used cooking fats and oils are a category A prescribed industrial waste (PIW) under the Environment Protection (Industrial Waste Resource) Regulations 2009 (the IWR Regulations), requiring strict management conditions. Based on risks to human health and the environment, the classification recognises unprocessed used cooking fats and oils as a non-PIW, provided appropriate measures are in place to prevent pollution to the environment.
The classification sets the minimum conditions EPA expects of industry.
Implementation of the classification
Table 1 below summarises materials and activities for which the Classification does and does not apply.
Table 1: Where does the classification apply?
||For these materials
||When materials are
- Used cooking fats and oils
- used for the production of biofuel
|Classification does not apply
- Grease trap inceptor waste
- Residues after processing
- applied to land
When the classification does not apply, you must comply with all relevant requirements under the Environment Protection Act 1970 (the Act), the IWR Regulations and the Environment Protection (Scheduled Premises) Regulations 2017. This includes licensing, vehicle permitting and waste transport certificates requirements.
When the classification applies, you must comply with all management options in the classification and general environmental requirements under the Act.
Compliance and enforcement
If you do not meet the requirements of the classification, the waste will be considered as PIW and EPA may take compliance and enforcement action for managing PIW without necessary approvals. You must be able to demonstrate compliance to EPA through relevant records, systems and procedures.
When using this classification you must continue to comply with your EPA licence conditions (where applicable). If there is conflict with these requirements you should comply with your licence.
Using the classification you will also need to comply with general environmental requirements that apply to all industries under the Environment Protection Act and the relevant state environment protection policies (SEPPs). In particular, odour, noise and dust must not negatively impact the area surrounding your site. Relevant penalties or notices may be applied.
Management options under the classification
The gazetted classification should always be your primary reference. EPA has provided this further guidance to help you comply with the management options outlined in the classification. The management options are compulsory for anyone using the classification.
A copy of the classification (PDF 114KB) must be in any vehicle or site that accepts unprocessed used cooking fats and oils.
Response to comments on the draft classification
|Summary of comments
|The terms ‘tallow’ and ‘used cooking oil’ are not consistent with how industry refers to the relevant wastes.
||This classification was amended to refer to ‘unprocessed used cooking fats and oils’.
|Provide clarity on EPA’s expectation for bunding, particularly in relation to small operators.
||The classification continues to require that all activity occurs in accordance with EPA bunding guidelines. Smaller sites may consider the minor storage requirements in this guideline.
|Transportation and vehicle requirements are not meaningful or clear.
||The transportation and vehicle requirement were simplified.
|The limit of 90 days storage may make it difficult to fully comply with classification.
||The storage limit only applies to unprocessed material at consolidation premises and not the site of generation or reprocessing. This limit is intended to prevent stockpiling and ensure that materials are reused, recycled or used for biofuel production.
|Unintended contamination of used cooking fats and oils is not addressed.
||The classification was updated to require management that ensures prevention of contamination.
|Biosecurity issues are not addressed.
||The classification was updated to refer to requirements of the ruminant feed ban.