Aerosol cans hold anything from paints and solvents to food and healthcare products. Some even contain pesticides. Although they’re convenient, when they are “empty,” many aerosol cans are still hazardous because they’re pressurized and because they may still contain a hazardous material. Many facilities aren’t aware of this, causing many aerosol cans to be improperly sent to municipal landfills with other non-hazardous wastes.
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The Environmental Protection Agency (EPA) recognizes that aerosol cans are commonly used at many different types of businesses. They also recognize that even though the empty cans present a hazard, the hazard is relatively small and the cans themselves are highly recyclable. To help encourage recycling and help facilities properly manage this waste stream, the EPA added aerosol cans to the Universal Waste Rule in December 2019.
Managing aerosol cans as universal waste allows them to be collected, stored and managed safely and in a manner that encourages recycling and helps prevent releases to the environment. Generators can:
- Collect and send the intact cans offsite to a universal waste handler, or
- Puncturing the cans onsite and
- Recycle the punctured, drained cans as scrap metal, and
- Managing the residual liquids appropriately.
Prior to the passing of the federal rule, five states already included aerosol cans as universal wastes in their respective states, and most other states had guidance on the handling and recycling or disposal of aerosol cans. The management standards for small quantity generators (facilities that generate less than 5,000 kg of universal wastes at any time) and large quantity generators of universal waste are the same for aerosol cans.
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A feature of this rule is that it clarifies the EPA’s position on aerosol can puncturing as a permissible activity – when the can puncturing is performed with a device that has been designed to puncture the can safely. Another feature of the rule is that allows facilities to determine whether they want to puncture their cans or if it makes sense to send them for offsite recycling by a universal waste handling facility. For facilities that do not generate a large number of aerosol cans, puncturing may not present a cost savings.
Here’s a brief overview of the rule’s requirements:
|Small Quantity Generators (SQG) and Large Quantity Generators (LQG) of Universal Waste Aerosol Cans [SQG’s: 40 CFR 273.13(e) LQG’s: 40 CFR 27.33(e)]
|Management||Manage universal waste aerosol cans in a manner that prevents releases to the environment.
Cans may be:
• sorted by type
• mixed with other intact aerosol cans in one container
Containers must be properly labeled with the words:
• “Universal Waste – Aerosol Cans”, or
• “Waste Aerosol Cans”, or
• “Used Aerosol Cans”
|Collection containers||Accumulate waste aerosol cans in a container that:
• Is structurally sound
• Is compatible with the contents
• Is in good condition (no leaks or significant damage)
• Is protected from heat sources
|Leaking aerosol cans||Must be:
• Packaged in a separate closed container, or
• Overpacked with absorbents, or
• Be immediately punctured and drained
|Permissible activities||Actuators may be removed to reduce the risk of accidental release
|Aerosol can puncturing||Is permitted if:
• The punctured and drained can will be recycled
• Puncturing and draining is performed with a device that is designed to safely puncture the cans and contain the residual liquids
• Written procedures for safely puncturing and draining the can are written and followed
• Manufacturers specifications and instructions are maintained onsite
• Employees are trained to use the puncturing unit
• Puncturing is conducted in a manner that prevents the risk of fire or harmful releases to the environment
• The container holding residual liquid waste meets applicable RCRA standards for security, inspections, personnel training and the safe management of ignitable, reactive and incompatible wastes
• A hazardous waste determination is conducted on residual wastes and it is managed in accordance with any applicable RCRA regulations
• A written procedure is developed for the cleanup of leaks and spills
• A spill kit is provided and spills are cleaned up promptly
As states move to adopt the federal rule, they will help ease the regulatory burden of generators while encouraging the collection and recycling of aerosol cans.
Not all companies can get away from using aerosol cans, especially ones in the manufacturing and automotive industries. Properly disposing of the cans, however, will save landfill space and reduce hazardous waste.
Michelle Leesays:03/12/2019 at 10:04 am
Before reading this article, I did not know that the aerosol cans can even be thought as hazardous. I’ll have to look for an aerosol disposal service to help with the process for when I need it. I did not know that you can get refillable compressed air containers.
Isabella Andersensays:04/02/2019 at 10:15 am
Hi Michelle, thanks for your comment! We’re glad we helped make you aware of this. Here’s some more information on aerosol can disposal/recycling along with products that can help.
Scott Nelsonsays:07/27/2019 at 11:11 am
I have just purchased a new pig can recycler, and am excited to begin using it. I have one concern, are there any regulations or any safeguards as to the mixing of the cans contents in the collection drum?
Isabella Andersensays:09/23/2019 at 11:07 am
We’re glad that you like our can recycling system! Check out this post for more information about co-mingling different effluents in your collection drum.
nathan brownsays:01/29/2020 at 12:33 pm
BE CAREFUL OF THIS!!!! This ruling will help us however it is contingent on each state adopting the new policy and until your state does this it is still considered Hazardous!!… Cheers!!
Isabella Andersensays:01/30/2020 at 10:33 am
Hi there! It’s a great idea to verify whether your state has adopted the Federal Rule as it is or whether they have chosen to develop a more stringent rule.
Eric Gsays:01/29/2020 at 1:35 pm
Our manufacturing facility currently manages Aerosol Cans (used & emptied) as a “scrap metal for recycling” program. We manage the residual contents of the aerosol cans (punctured & collected) as Hazardous Waste. The perspective that I see of the Universal Waste management requirements is significantly more involved than our current waste generation / disposal. To change our management of the scrap metal to Universal Waste will require some additional activities and management than we already have in place. Can you advise what the change to Universal Waste might mean for us? Thank you
Isabella Andersensays:01/30/2020 at 10:35 am
Hi there, thanks for your question! For many facilities that are already safety puncturing their aerosol cans with commercially available can puncturing units, recycling the scrap metal (depressurized cans) and managing the residual drained liquids properly, managing the cans under the federal Universal Waste rules should not present many big operational changes.
Under the new Federal Rule, you have the option to collect the cans and send them for recycling by a Universal Waste Handler; or you may continue to puncture them in a puncturing unit that has been designed to safely puncture the cans, recycle the depressurized cans and manage the drained liquids appropriately (typically, these liquids will need to be managed as hazardous waste).
The biggest changes for you may simply be to have a set of written instructions for using the can puncturing system, maintaining a copy of the manufacturer’s instructions for the puncturing unit, formally training your employees on how to puncture the cans safely, and having a written spill response program (and spill kit) available in case the residual liquids leak or spill.
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