1
                                                                       EXHIBIT 8

                    PAUL, WEISS, RIFKIND, WHARTON & GARRISON
                           1285 AVENUE OF THE AMERICAS
                          NEW YORK, NEW YORK 10019-6064



                                  July 12, 1999



Safety-Kleen Corp.
1301 Gervais Street
Suite 300
Columbia, SC 29201

                  Registration Statement on Form S-4

Ladies and Gentlemen:

                  In connection with the Registration Statement on Form S-4 (the
"Registration Statement") filed today by Safety-Kleen Corp. (the "Issuer"), a
Delaware corporation, with the Securities and Exchange Commission (the "SEC")
under the Securities Act of 1933, as amended (the "Act"), and the rules and
regulations under the Act (the "Rules"), we have been requested to render this
opinion. Capitalized terms used and not otherwise defined shall have the
meanings given those terms in the Registration Statement.

                  In this regard, we have reviewed copies of the Registration
Statement (including its exhibits) with respect to the offer by the Issuer to
exchange up to $225,000,000 in aggregate principal amount of its outstanding
9 1/4% Senior Notes due 2009 (the "Initial Notes") for up to $225,000,000 in
aggregate principal amount of its 9 1/4% Exchange Senior Notes due 2009 (the
"Exchange Notes"). We have also made those other investigations of fact and law
and have examined the originals, or copies authenticated to our satisfaction, of
those other documents, record, certificates
   2
Safety-Kleen Corp.
July 12, 1999
Page -2-


or other instruments as in our judgment are necessary or appropriate to render
our opinion.

                  Our opinion is limited to the Internal Revenue Code of 1986,
as amended (the "Code"), administrative rulings, judicial decisions, Treasury
regulations and other applicable authorities, all as in effect today. The
statutory provisions, regulations, and interpretations upon which our opinion is
based are subject to change, and those changes could apply retroactively. Any
change could affect the continuing validity of our opinion. We assume no
responsibility to advise you of any subsequent changes in existing law or facts,
nor do we assume any responsibility to update this opinion with respect to any
matters expressly stated in this letter, and no opinions are to be implied or
may be inferred beyond the matters expressly so stated.

                  Based upon and subject to the foregoing, the legal matters and
conclusions stated in the Registration Statement under the heading "Certain
Federal Income Tax Considerations" constitute our opinion with respect to those
matters.

                  We hereby consent to the filing of this opinion as an exhibit
to the Registration Statement and to the reference to us under the heading
"Legal Matters" in the Prospectus included in the Registration Statement. In
giving this consent, we do not hereby agree that we come within the category of
persons whose consent is required by the Act or the Rules.

                                   Very truly yours,


                                   /s/ Paul, Weiss, Rifkind, Wharton & Garrison
                                   PAUL, WEISS, RIFKIND, WHARTON & GARRISON