First contact March 15, 2016:
Do empty aerosol cans that are generated in an office environment have to be treated the same as if they were generated in a manufacturing environment? We generate empty aerosol cans in our manufacturing plant and treat them as hazardous waste. We accumulate them in a metal 55 gallon drum and when filled we pay someone to generate a manifest and pick them up for disposal. How are empty aerosol cans disposed of in an office building? Can they just be tossed in the trash?
I would appreciate any input on this that you can provide. We are located in St. Louis, MO.
My snap reply that same day:
Management of waste aerosol cans, and indeed all waste, is subject to the same federal and state regulations if it comes from a business.
And, a more thorough answer also on March 15th:
The question of whether or not aerosol cans are a hazardous waste is tricky. Please note below:
- If they meet the definition of RCRA Empty they may be disposed of in the trash. Be careful with this since some landfills and state agencies don’t like to see unpunctured aerosol cans in the trash.
- If destined for recycling as scrap metal they don’t have to be RCRA Empty. Be careful with this since some recyclers don’t like to see unpunctured aerosol cans in their scrap.
- If destined for recycling you may puncture the cans in a device designed for that purpose (follow all worker safety regulations). This is not considered to be treatment of a hazardous waste if the punctured cans are to be recycled.
- Many aerosol cans are a D001 Ignitable or D002 Corrosive hazardous waste due to their contents. I believe that an aerosol can retaining any pressure will be a D003 Reactive hazardous waste no matter its contents. Not everyone agrees with that.
I hope this helps. Please don’t hesitate to contact me with any other questions.
Below are some articles I’ve written in the past that will assist in understanding the conclusions of this Q&A:
- Empty Steel Aerosol Cans as a Reactive Hazardous Waste
- Manage Your Waste Steel Aerosol Cans Under the RCRA Scrap Metal Exemption
- Explanation of the Characteristic of Reactivity (D003)
- Explanation of the Characteristic of Ignitability (D001)
- Explanation of the Characteristic of Corrosivity (D002)
Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste
Daniels Training Services