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.