AEROSOL CANS
Corrected spelling errors on 7/16/01 by Ronald Lee Still.
Many Nevada businesses use aerosol cans in their operations; automotive and heavy equipment maintenance, printing, and various manufacturing operations all tend to generate spent aerosol cans. An aerosol can that is empty (all product has been used for its intended purpose and the propellant inside the can has been discharged) may be disposed of as a non-hazardous solid waste.
Nevada businesses encounter situations when aerosol cans get clogged or the material inside the can has exceed its shelf-life date; in these cases, the can is not empty and the pressure inside the can has not been discharged. Applying the Federal regulations to a situation where a business has a clogged or off specification aerosol can, the business is required to:
1) determine whether the contents inside the clogged or off-specification container are considered a hazardous waste; and
2) since the aerosol can is still pressurized, the entire can will be regulated as a reactive hazardous waste (the can has the potential to react violently when subjected to heat or pressured.
Aerosol cans that are not considered empty (due to residual material and/or pressure) can be a real problem for a small business. Suppliers typically will not take back clogged or off-specification cans from a business that may only purchase 10 or 15 cans of product a month yet may be more flexible when dealing with a large buyer of their products. The Federal regulations would require businesses to manage these few aerosol cans as hazardous waste even though households routinely dispose of aerosol cans as normal household trash.
The Nevada Division of Environmental Protection considers 12 or fewer clogged or off-specification cans per month to be a de minimus generation rate. Therefore, a business that generates fewer aerosol cans than this limit can dispose of them as non-hazardous waste and not be subject to enforcement action by the Division. This position applies to all aerosol can contents except any cans that contain an acute hazardous waste (also referred to as a P-listed waste, as defined under 40 CFR, Section 261.33). Aerosol cans typically do not contain acute hazardous wastes. Any business that generates more than 12 aerosol cans per month that are no longer usable but still contain meferial or are pressurized, should be handling all of these spent aerosol cans as a hazardous waste due to the characteristic of reactivity (40 CFR, Section 261.23) and potentially due to the material within the can being considered a hazardous waste.
There are commercially available can puncturing devices. A can puncturing device may be a wise and cost-effective waste management investment for businesses that generate a number of aerosol cans that contain residual or off-specification material. Some businesses may choose to puncture, drain and dispose of the drained and punctured cans as solid waste while managing the drained residue from all of the cans as a hazardous waste. Once the cans are drained and de-pressurized, they are considered empty containers and are not regulated as hazardous waste. Businesses should be aware of health and safety concerns associated with puncturing aerosol cans and should use equipment designed for this purpose. If a business is considering purchasing a puncturing device, we encourage them to contact the Business Environmental Program at 1-800-882-3233 prior to making any purchase to discuss potential air regulatory requirements associated with their puncturing operations. Obviously, the best strategy is to take proper care in storage and use of aerosol products and to practice good inventory control so that all aerosol products purchased are used for their intended purpose rather than being disposed of.
This fact sheet was developed by the Business Environmental Program of the Nevada Small Business Development Center with funding provided by the Nevada Division of Environmental Protection.