• Customer Questions: Can I Mix the Contents of Aerosol Cans
  • Karen

    Karen D. Hamel CSP, CET, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 25 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 200 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Certified Environmental health and Safety Trainer (CET), Walkway Auditor Certificate Holder (WACH), OSHA-Authorized Outreach Trainer for General Industry, Community Emergency Response Team (CERT) trainer and hazmat technician. She serves on the Blair County, PA LEPC. Her specialties include a wide variety of environmental, safety, emergency response, risk management, DOT and NIMS topics. She conducts trainings and seminars at national conferences and webinars for several national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenea@newpig.com.

  • Susansays:
    03/02/2015 at 11:51 am Reply

    Does this sound right? (Excerpt from an email):
    If the aerosol can is punctured, then the can is definitely “empty” and can be put into scrap metal bin or trash. However an aerosol can may be emptied by depressing the nozzle and dispensing all of the product so that the can is no longer pressurized. Then the “Empty” used aerosol cans can be placed with metals for recycling or into trash as solid waste.

    If an aerosol can still contains haz material (i.e. broken dispenser or product is still inside) then it probably should be managed as a hazardous waste. However, or if the plant is a CESQG and it is not banned by the State, then it can still go into the trash.

    If the can is punctured, the released product must be handled as a hazardous waste. Most sites contain various aerosol products that may be incompatible if commingled in one drum. Most sites don’t use enough cans to “fill” a drum with a single drained product.

    • Karen Hamelsays:
      03/03/2015 at 7:41 pm Reply

      Yes, Susan, if an aerosol can is punctured, it is “empty” and can be recycled as scrap metal. Note that the EPA exemption for scrap metal only applies to scrap metal that is being recycled – so you wouldn’t want to put the punctured aerosol can in the trash. (The EPA is a huge proponent of recycling!)

      An aerosol can that has only been emptied by pressing the nozzle and dispensing whatever product is inside the can is not really “empty” or “safe to throw in the recycling bin.” The can is still pressurized and thus still has a reactivity hazard. Safely puncturing the can relieves it of the remaining pressure and removes the reactivity hazard, allowing it to be recycled with other scrap metals.

      Aerosol cans that still have product in them (broken dispenser, no longer useful, etc.) that are NOT punctured should be managed as hazardous waste. The generator needs to determine what hazards are present (listed and characteristic) and arrange for it to be stored, handled, processed and recycled or disposed of properly. This is a federal requirement. Some states regulations do vary – but state and local regulations must be at least as stringent as federal regulations.

      When a can is punctured, any material released from the can must also be managed properly. Generators must make a hazard determination just like any other waste stream. And, yes, most sites do have more than one type of aerosol product. Safety managers should evaluate the types of products supplied in aerosol cans that will be punctured to determine if there are any incompatibilities. Separate collection drums should be used for incompatible materials.

      Thanks,
      Karen

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