Aerosol can management

May a campus send waste aerosol cans for scrap metal recycling, as non-hazardous solid waste, without first puncturing and draining them?

Yes, if the waste aerosol cans meet the following:

  1. The cans did not hold chemical formulations with sole active ingredients identified in the F027 or P-list hazardous waste listings, and
  2. The aerosol products have been used for their intended purposes so that when holding the cans upright and pressing down on their nozzles, not enough product comes out for them to be useful anymore, and
  3. a) No more than 3% of the original net content weight remains in the cans, or b) No more than one inch of liquid remains in the bottoms of the cans. A practical test is to shake the can up and down. If the can feels like it has an inch or less of liquid in the bottom when you shake it, it should meet this criterion.aerosol

Intact, waste aerosol cans that held chemical formulations with sole active ingredients identified in the F027 in NR 661.31 (1) or P-list NR 661.33 (5) hazardous waste listings should be segregated from other cans for management as acute hazardous waste by the state's hazardous waste contractor.

Most aerosol cans have a round (concave) bottom. The one-inch criterion assumes a flat bottom.

Do not spray aerosol cans for the sole purpose of making them non-hazardous solid waste. Doing so: 1) may meet the definition of hazardous waste treatment and may require a hazardous waste treatment facility license, and 2) may generate wastes, which would require the generator to determine if they are hazardous waste and manage them accordingly.

These criteria should only be applied to waste aerosol cans while they are generated, transported or recycled in Wisconsin . Generators and transporters of waste aerosol cans that are transported and recycled in other states should contact the appropriate state RCRA agencies to determine the requirements that apply in those states.

Waste aerosol cans that do not meet the above criteria

Generators of waste aerosol cans destined for recycling that do not meet the above criteria should determine if the cans are hazardous waste (NR 661) and manage them accordingly as either hazardous waste or non-hazardous solid waste. This involves: 1) determining if the contents of the cans are regulated as hazardous waste, and 2) determining if the cans with their contents have any hazardous waste characteristics. Waste aerosol cans that are not RCRA empty can be sent for disposal/recycling through our hazardous waste contractor. The cap must be in place or the nozzle must be removed.

Puncturing and draining technologies

Puncturing and draining devices are another option, but should be evaluated with care. The devices puncture and drain waste aerosol cans while collecting their liquid contents in a storage drum. Systems that treat gases and vapors with a carbon filter should be used. The waste aerosol cans may then be recycled as scrap metal. The collected liquids and used carbon filters are classified as hazardous or non-hazardous waste and managed accordingly.

Scrap metal recycling

Businesses and institutions should contact the scrap metal recyclers they are using or plan to use to determine if they will accept waste aerosol cans that meet the above criteria listed in the first paragraph of this guidance.

Waste Minimization & Aerosol Product Alternatives

Hold aerosol cans upright when using them for their intended purpose to maximize the use of the contained product. Return defective aerosol cans to the supplier or manufacturer, or in most cases manage them as hazardous waste. Unclog or replace clogged aerosol can nozzles, or in most cases manage aerosol cans with clogged nozzles as hazardous waste.

Ask product suppliers about alternative, non-aerosol products (e.g., reusable pump sprays, refillable containers that use compressed air as the propellant, roll-ons, liquids), which may be less of a fire hazard and less hazardous to human health and the environment, and may produce less waste from their use. Alternatives to aerosol spray painting include brush painting and electrostatic painting.

References

NR 661

EPA Letter

 


Disclaimer

This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice.
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