In the last few months and particularly during a period of low crude oil prices and a lower demand for petroleum fuels,
the waste derived fuel generically known as Processed Fuel Oil or PFO and offered by a number of ORA members, has been the subject of criticism from a few players in the downstream oil supply industry. Some of the points being made were reflected in an article in the March 2016 edition of Fuel Oil News. The Association was therefore appreciative of the opportunity to put its point of view across in the May edition of the Fuel Oil News.
PFO Quality Protocol
In order to understand the wider situation we should say that allegations may have implied that there are a number of issues about Processed Fuel Oil. This note provides an opportunity to set the record straight. Firstly, all PFO produced by ORA members is certificated to be a residual non waste status fuel only and to be clear even if it is subsequently blended remains a residual fuel.
The PFO Quality Protocol (QP) was developed through rational science comparing the properties of PFO with Heavy (and Medium and Light) residual fuel oils in respect of their environmental impacts. A distillate variant was never finalised in the current QP simply because there was no economic demand for it.
It is important we should say that PFO can only be manufactured in Regulatory approved facilities that are regularly audited; requiring UKAS accredited testing facilities that use UKAS accredited test methods. All supplies are required to be certificated and have easily traceable REACH registration data. It is a condition of the QP and its included standards, that it undergoes a regular review process. Could all of the UK petroleum distribution trade readily match that?
At its latest regulatory review, the QP will see a number of updates focused on the now published test methods for the residual variant, but with no change to any of its listed parameters.
The UK PFO QP has again satisfied the EU Commission on its End of Waste position including passing the rigours of its Technical Adaptions Committee. We were therefore at a loss to understand certain critical comments centred on the thought that the ‘QP (is) due for another review, and new evidence…………. etc.’, as this is simply not the case.
Part of the story portrayed seems to imply that there is a trade involving blending PFO residual quality with kerosene to convert the material to a distillate class.
We assure readers this is not the case for ORA members can only produce materials that remain classified as residual fuels. As a non-waste, PFO is naturally capable of being blended with lighter non-dutiable non waste fuels but only at approved sites where it can be legally managed to meet HMRC handling requirements including their definitions for such fuels and their respective uses. This is an equivalent practice that has been regularly and historically conducted by certain players blending fuels in the wider petroleum fuels distribution industry. If customers are uncertain of the legitimacy of such trade they should contact their local environment regulator and/ or HMRC office.
The fact is most PFO, being lubricating oil derived, is anyway a relatively low viscosity residual fuel while blending with lighter oil can further enhance that property. To reiterate, PFO residual quality remains that, no matter what it is diluted with. Customers who may benefit from using lower duty rate fuels and have any doubts about the provenance of their supplies should check with their suppliers and if in doubt, consult the regulatory authorities.
However in light of allegations being made by some, our Association has asked that all members review their product information for any potential ambiguity and to amend the data accordingly. The fact is that there are a number of applications that are capable of running on residual or distillate fuels – indeed many were historically covered by permits to do so. Thus this class of applicable users of dual residual and/or distillate fuel that are able to switch, can choose their fuel from whatever supply source that suits them, i.e 8oxoboa. a question of convenience and cost.
Customers might not be aware that there are a number of waste lubricating oil derived distillate fuels already produced in the wider EU, some of which it is alleged are being imported into the UK as non-waste. These are not supplied by ORA members. Where that situation occurs it is probably because of different interpretations by other Member States and a lack of a pan EU standard for End of Waste. Such distillate fuels could not meet the existing UK standards simply because there is no current agreed End of Waste position for them.
Perhaps the responsible and more liberal minded suppliers in the petroleum industry already know that PFO acts as a great benefit to the environment in that it has generated a market led mechanism to see otherwise hazardous waste oil is efficiently collected. This occurs at high rates evidenced by fewer waste oil pollution problems, while supporting a responsible means of fulfilling the ideals of the Circular Economy on waste by treating it as a resource for reuse. Further, some may not know because it is a recyclate it offers real benefits in respect of its carbon footprint, indeed outperforming most conventional oil fuels.
While we can all understand that competition is what it says it is and trading times are difficult for all, indeed causing some to react adversely, our aim here is to provide another take on the facts.
Produced by the PFO Suppliers of the Oil Recycling Association