Available Now: 2023 Schedule of Hazmat & RCRA Training

Question of the Week: Classifying Aerosol Can Waste

Posted on 6/30/2011 by James Griffin

Q. Are aerosol cans considered to be a D003 simply because they are pressurized?
A. When it comes to waste identification, it is the responsibility of the generator to make a waste determination based on all aspects of the material (40 CFR 262.11). RCRA programs in some authorized states simplify your waste classification process and declare that each and every aerosol can with contents under pressure is a D003 (reactivity characteristic) hazardous waste. So always check your State regulations to see how your specific state regulates these wastes.
Whether or not your State program insists that aerosol cans are D003 wastes, since aerosol cans can contain a variety of chemicals, they can also bear any number of other waste codes. The generator must consider the contents of the can, both the propellant and the propelled substance, and if any of those chemicals are listed (40 CFR 261, Subpart D) or exhibit a characteristic (40 CFR 261, Subpart C), then the aerosol can is that kind of hazardous waste.
Here are some things to consider when managing aerosol cans that might make your life easier:
  • Household hazardous wastes, including aerosol cans, are excluded from regulation as hazardous material. As this exclusion applies at the point of generation, in the household, it would continue to apply to aerosol cans collected by most municipal recycling programs. [40 CFR 261.4(b)(1)]
  • If you recycle the metal portion of an aerosol can, it is excluded from hazardous waste regulation as “scrap metal.” [40 CFR 261.4(a)(13), 40 CFR 261.6(a)(3)(ii)]
Empty Aerosols
If you use up all the contents of an aerosol can so that “the pressure in the container approaches atmospheric,” then it is an “empty container” and any residues of chemicals that do remain are no longer regulated as hazardous waste. [40 CFR 261.7(b)(2)]
But if pressure remains in the can even if you are done using it, how can you render it “empty”?
In some jurisdictions, you may puncture an aerosol can (using specialized equipment to capture the contained gas and other chemicals) in order to relieve the pressure and neutralize the reactivity characteristic and then recycle the remnants. Changing the physical character of the waste to make it more amendable for recycling is technically waste treatment and may trigger notification, permitting, or other requirements set by your State waste management authority or other regulatory agencies. After puncturing, the can itself can be recycled as scrap metal, and any vapors, liquids, powders, or other materials remaining must be evaluated as potentially hazardous waste and managed accordingly.

Tags: disposal, hazardous waste, RCRA

Find a Post

Compliance Archives

Lion - Quotes

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

No comparison. Lion has the best RCRA training ever!!

Matt Sabine

Environmental Specialist

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training.

Caroline Froning

Plant Chemist

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms.

David Hertvik

Vice President

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

Download Our Latest Whitepaper

Explore the four specific 29 CFR Standards that OSHA inspectors overwhelmingly cite employers for when investigating COVID-19 exposure in the workplace.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.