In 2002, Senate Bill 1158 came into effect adding Section 25201.16 to California Health and Safety Code, Division 20, Article 9. The bill intended to mitigate regulatory requirements for managing hazardous waste aerosol cans. Fifteen years later, confusion still exists among hazardous waste generators about aerosol can waste management. When deciding how to manage waste aerosol cans, it is important to understand your options and the requirements associated with each option.
What are universal wastes?
Universal wastes are hazardous wastes that have a lower risk of harming people and the environment than other hazardous wastes. Universal wastes are often common hazardous wastes such as electronic waste, batteries, fluorescent lamps, mercury-containing thermostats, and other household wastes.
Are waste aerosol cans universal waste?
Waste aerosol cans are considered universal waste if they contain residual hazardous product or propellant. Aerosol cans become universal waste when they are discarded or no longer usable for any of the following reasons:
There are several circumstances in which waste aerosol cans may be considered non-hazardous waste. Waste aerosol cans that do not contain hazardous product or propellant (i.e. not ignitable, corrosive, reactive, or toxic) are not hazardous waste. Additionally, aerosol cans that have been emptied to the maximum extent practical or that have been punctured, drained, or crushed are not hazardous and can be recycled as scrap metal or disposed of in the trash if accepted by your landfill.
Storage Requirements for Universal Waste Aerosol Cans
Aerosol cans that are classified as universal waste must be managed in a manner that prevents fire, explosion, and unauthorized release into the environment. Containers used to accumulate or transport universal waste aerosol cans are required to be:
Aerosol Can Processing
A universal waste handler may choose to process universal waste aerosol cans to remove and collect the contents of the cans. Aerosol can processing includes puncturing, draining, or crushing aerosol cans. When processing waste aerosol cans, the handler must ensure that:
Additionally, a written operating procedure for safety and emergencies must be developed and implemented. The operating procedure must detail the following:
If you choose to process waste aerosol cans or change your processing operations, you must notify your local CUPA or authorized agency.
To Puncture or Not to Puncture?
Overall, there are many considerations to make when deciding between processing waste aerosol cans and managing them as universal waste. For example, processing waste aerosol cans may be less expensive depending on the quantity of waste generated. However, managing waste aerosol cans as universal waste requires less time and effort from generators.
Alta Consultants have extensive experience with Hazardous Waste Management. For more information, call Alta at (800)-777-0605 or email firstname.lastname@example.org.