Various States, US


Cummins, Inc – Cummins Sales & Services, North America



Core Practices

Services Provided

  • Environmental Land-use & Permitting Compliance
  • Regulatory Consulting
  • Environmental Consulting
  • Waste Management

Project Overview

Cummins Sales & Services, North America (CSSNA) performs service on engines and generators for their customers off-site. As a part of this service, they transport the used oil removed from the equipment back to each branch site the machine was sent from. 

The Environmental Protection Agency (EPA) and some states have notification and/or permitting requirements for the transporting and onsite storage (transfer facility) of used oil. The regulation is applicable if a facility transports more than 55 gallons of used oil at any one time and if they store that oil onsite more than 24 hours but less than 35 days. CSSNA has over 100 facilities where this activity occurs and where these regulations apply. 

T&M supported CSSNA in updating the waste notification forms to obtain an EPA Identification Number which included review and approval for the transport and transfer facility activity and submittal of the form to the agencies. There are several states that have additional notification/permitting requirements. T&M supported the investigation of these requirements by filling out the application assisting CSSNA in obtaining the appropriate documents (insurance, business certificate of good standing, training, etc.), and submittal of the application to the agencies.   T&M’s services helped the client develop a standardized process for use at all of their facilities,and ensuring compliance with these important regulations and consistency among their sites and workers.

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