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I once attended a towing association meeting, and the subject was if Dry Sweep and Oil Absorbent pads are considered hazardous waste or not. Also discussed was if we are required to clean then up and dispose of them.
Much discussion was on this subject, as some towers are being told to pick them up and take them with the vehicle that caused the leak. Now if you do that, how do you dispose of them. Well that is a hard question to answer, because according to what I can find out, it depends on how you are going to get rid of them. Do you put it in the vehicle that cause the spill ?.
Lets look at it in simple steps. First, the vehicle caused the accident, and the spill. Insurance companies cover all related claims for the accident, IF the vehicle or person has coverage. In the case of a large spill, such as a overturned tanker, a environmental cleanup company would respond and take care of the cleanup. Insurance would be charged for the costs to do this. This would be out of the capability of most if not all tow companies to handle.
In the case of a automobile accident, the quantity of oil will be small (about 1 gallon), or several gallons of gasoline. Now if the fire department showed up and put out the pads or dry sweep, then are you required to clean it up ?????. In Alabama, as in many other states we are required by law to clean up all debris from a accident scene before we can leave. Now here is the tricky part. DOES YOUR INSURANCE cover you when handling Hazardous Materials ?.
The main problem with Hazardous Materials, is that 2 years or 50 years down the road the incident debris might come back to haunt you. If you sent the debris to a waste disposal site, you are responsible for it till it is destroyed. Now even though you get a receipt, and all sorts of official looking paperwork, and the company provides you with all the legal mumbo jumbo, you as the generator of the hazardous waste are responsible for it. So how can you get around it, well there is a way. When you sign the paperwork, remember that you are acting as a agent ( loosely ) of the insurance company. The insurance company should pay for the disposal or at least be listed on the forms as the real generator of the waste. So when and if you ever have to dispose of any hazardous waste that is generated by a accident vehicle, list the vehicle information that you have on the form, the insurance company information that you have on the form, and then sign it as acting on behalf of the insurance company. Then get your receipt and attach it to your tow bills, and other information about the vehicle, and then create a special file folder that will not get tossed out anytime, you will need this information if it comes back to haunt you.
Now, lets look at how it is going to be disposed of. If the waste is sent to a incinerator, then it should and might be considered fuel if the main purpose of the plant is to generate power or something along those lines. If it is to be recycled and turned into another product, then it is a supply material. But if it is so dangerous that it is going to be buried or destroyed by burning to nothing, then it is considered Hazardous Waste.
I do not claim to have a lot of answers in this area, as this field is so specialized and highly regulated, that it requires special training to be a operator or worker at one of the disposal companies. So this is a subject that you as a towing operator or company owner should study carefully.
Failure to do so, might come back and haunt you later. There are so many agencies that regulate hazardous waste that it is hard to follow all the rules and regulations. But rest assured that if you screw up, the agencies will all be reaching into you wallet and checkbook for hefty fines.
So you might consider asking the EPA, and other regulatory agencies in your area, how and what to do with all this stuff that you might generate. Next you should talk to your insurance agent, so that you can get their answers. They will be involved if you screw up. Better to know if you are covered before you attempt the job. If you are not covered then turn the job down, or contact someone like the local environmental cleanup company. After all they are the experts and they can tell you what to do, and how to do it. And also how much it will cost to do the job. The are the ones that are called by the big guys to clean up the major problems, and who knows, if you show them that you are willing to work with them, you might get a chance to make a lot more money. After all they have people that they call for help.

How I know that this subject is not covered completely, and that is because there are currently regulations and rules changes that are being created as we discuss this subject. As I get more information I will pass it on to you when there is new information.