If you look in any maintenance shop or facilities department, you're likely to find a variety of products in aerosol cans. These are typically products such as lubricants, cleaners, paints and degreasers. Aerosol cans provide a convenient way to use these and other products.
If you are like many employers, your workplace uses some products in aerosol cans. So, what's the problem? The problem isn't in the use of the products, but in the disposal of the aerosol can. What is the proper way of discarding empty aerosol cans? Do you need to do anything special when discarding them?
It's a great question – do you know the answer?
In general, it is EPA's view that aerosol cans are capable of holding either compressed gas or liquid. But if they are empty, can they be disposed of as nonhazardous? What is EPA's definition of empty? Should an employer empty the cans first?
Use KOL's tools
KellerOnline's Search area can assist you in finding the information you need to make decisions such as these. If you search under Environment for “aerosol can”, you will find the regulations which address the issue.
If the can is sent for scrap metal recycling, the can and its contents are exempt from regulation as a scrap metal under 40 CFR 261.6(a)(3)(iii).
The act of emptying the can may be an exempt recycling activity under 261.6(c). However, any residues from emptying the can would be regulated if they are listed or exhibit a characteristic of hazardous waste.
If the can is sent for disposal, both the contents of the can and the can itself are subject to regulation. According to the regulation, to dispose of the aerosol can as nonhazardous waste, the can must be empty according to 261.7 of EPA's Resource Conservation and Recovery Act (RCRA), and the can itself must not qualify as a hazardous waste.
However, to determine if venting the can to empty it constitutes treatment, the appropriate EPA region or state must be consulted. You can find those contacts in the KellerOnline Reference area under the State-Specific tab by locating your state in the left column under Environment.
For more information, visit www.jjkeller.com.
