7 Rules for Waste Aerosol Can Puncturing

Posted on 10/19/2020 by Ross Kellogg, CHMM

US EPA added hazardous waste aerosol cans to the RCRA universal waste program in February 2020. In states that have adopted the rule, the new relief gives generators flexibility to manage this waste stream more efficiently.

EPA defines aerosol can as “a non-refillable container holding compressed, liquefied, or dissolved gas and is fitted with a self-closing release device that when pressed expels liquid, paste, or powder” (40 CFR 260.10).

A hazardous waste aerosol can is an aerosol can that contains a characteristic or listed hazardous waste. The product may itself have hazardous qualities—like hairspray, deodorant, or other flammable products. Aerosol cans can also be regulated as hazardous waste because of the propellant used to make the can spray.

[VIDEO] Final Rule Alert: Aerosol Cans as Universal Waste

EPA based its aerosols universal waste rule on existing state programs in California, Colorado, Utah, and New Mexico. They referenced two proposed state programs while creating the Federal standards as well, Ohio’s and Minnesota’s.

Manage Aerosols as Universal Waste

For intact (not damaged or leaking) aerosol cans, EPA allows handlers to:

  • Sort aerosol cans by type
  • Mix intact cans in one container
  • Remove actuators to reduce the risk of accidental release

[see 40 CFR 273.33(e)(3)]

Damaged or leaking aerosol cans must be accumulated separately in a closed container or overpacked with absorbents.

7 Rules for Puncturing Aerosol Cans

The aerosols universal waste rule allows handlers to “treat” aerosol cans by puncturing them and draining them of their contents. Properly punctured and drained aerosol cans may be recycled as scrap metal. As for the contents drained from the can—the generator must make a hazardous waste determination and manage the waste accordingly under RCRA.

To manage aerosol cans this way, handlers must follow seven key requirements.

1. Make sure to use the correct device that will puncture and drain the cans safety and leave a manufacturer’s instruction on site. In these rules there is no specific puncturing device required.This allows companies to buy or even develop their own puncturing devices, creating additional flexibility. Do however, keep in mind that other regulations always apply, such as any OSHA safe operating procedures or other environmental rules, such as a Clean air act permit. Always follow best practices for safe usage and follow the optimal maintenance schedule for the puncturing device to keep your workers safe and ensure the device can be used for its full lifespan.

2. Follow a written procedure that details how to safely puncture and drain the cans. Ensure that employees that operate the puncturing device are trained in the correct procedures.There is no formal documentation requirement with this training, but as with so many regulations, it still would be part of “best practices.”

3. Make sure that the procedure established is designed to prevent any releasing of the product and to prevent fires. For example, using a well-ventilated area and flat surfaces. This is especially true for powdered product aerosol cans (such as some bathroom cleaners and powdered dye penetrant) due to the risk of flash fire. Many manufacturers recommend NOT puncturing powdered product aerosol cans for this reason.

4. Immediately after puncturing, transfer the contents to a container or tank that meets the requirements of 40 CFR 262.14, 262.15, 262.16, or 262.17. In short, you want to make sure the contents are placed in something that will prevent spills or could cause damage

5. Conduct a hazardous waste determination on the drained contents of the cans per 40 CFR 262.11. Any hazardous waste generated as a result of this puncturing and draining is subject to further requirements of 40 CFR parts 260 through 272. The aerosol handler is considered the generator of the hazardous waste and they are subject to 40 CFR part 262.

6. If the contents from the punctured and drained cans are non hazardous, the aerosol handler can manage the waste in any way that is in compliance with applicable federal, state, or local solid waste regulations.

7. Establish a procedure to follow in case of a spill or leak, and provide a spill cleanup kit. Any spills or leaks must be cleaned up immediately.

Simplify Hazardous Waste Determinations

Since you must do a hazardous waste determination of the drained contents of the cans, you may want to consider a few additional steps to simplify this process, like:

  • Sorting cans containing non-hazardous contents from those containing hazardous contents
  • Determining whether the contents would be Acute hazardous waste, and
  • Determining whether the drained contents could affect your generator status.

Keep in mind that puncturing your aerosol cans is not required. If you decide that this strategy will help you manage waste more efficiently, be sure to follow the recommendations to properly store, manage, and dispose of hazardous waste aerosol cans and their contents.

Remember, while the new rule took effect on February 7, 2020 Federally, you may only manage aerosol cans this way once your state adopts the revised universal waste standards. Until then, or unless your state has its own similar program, you must manage aerosols as hazardous waste and follow the applicable 90 day, 180 day, or satellite requirements.

EPA has more information on state adoption of Federal universal waste criteria and state universal waste programs on its website.

RCRA Training: Learn Live or At Your Own Pace

US EPA requires hazardous waste professionals to complete annual training on the RCRA requirements. Lion makes it easy to meet your RCRA training mandate with convenient online courses and live, instructor-led webinars.

Browse RCRA training options here to find the course that fits your needs, your schedule, and your learning style.

Tags: aerosol, aerosol cans, haz waste, hazardous waste, hazardous waste management tips, puncture cans, RCRA, RCRA tips, waste aerosol cans, waste cans

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