Aerosol cans that are not empty frequently contain flammable propellants such as propane or butane that can cause them to exhibit the ignitability characteristic. An aerosol can may also contain materials that exhibit hazardous characteristics or contain ingredients that are specifically regulated by EPA. Leaking and damaged aerosol cans may also be managed as universal waste, so long as the leaking or damaged cans are packaged in a separate closed container, overpacked with absorbents, or immediately punctured and drained.
Among other things, the aerosol can wastes will no longer have to be labeled as hazardous wastes (although they will be subject to reduced marking requirements), they may be stored for up to one year or even longer in some cases (rather than just 90 days for large quantity generators), they may be transported offsite without a hazardous waste transporter or hazardous waste manifest.
The requirements for full or partially full waste aerosol cans that will be recycled are the same as other universal wastes. This means they can be accumulated onsite for up to one year, shipped off-site without a hazardous waste manifest or Land Disposal Restriction form, and the universal waste aerosol cans, or the container in which the cans are accumulated, must be marked or labeled with any of the following: “Universal Waste—Aerosol Can(s),” “Waste Aerosol Can(s),” or “Used Aerosol Can(s).” Documentation regarding the fate of the cans needs to be maintained.
According to EPA, even though empty aerosol cans do not have to be managed as universal waste, they may be if the handler prefers to do so. Likewise, nonhazardous aerosol cans may be managed as universal waste, although they are not required to be managed as such.
For more information or to ask any questions, email the Government Affairs Department at firstname.lastname@example.org.