Puncturing Myths about Aerosol Can Waste Management

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.

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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:

• The can is as empty as possible, using standard practices
• The spray mechanism does not work properly
• The propellant is spent
• The product is no longer used

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:

• Structurally sound and compatible with the contents of the aerosol cans
• Kept closed except when waste is being added or removed
• Placed in a location with sufficient ventilation
• Placed above a bermed impervious area with no cracks or gaps
• Kept a safe distance from heat and open flames
• Designed and maintained to withstand pressures expected during storage and transport
• Properly labeled as “Universal Waste Aerosol Cans” (with the date the first can was added)
• Sorted by type and compatibility of contents

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:

• Waste aerosol cans are processed in a manner that prevents fire, explosions, and unauthorized releases into the environment
• Processing equipment used is placed in a bermed impervious area with no cracks or gaps
• A spill clean-up kit  is provided to promptly clean-up spills or leaks
• The contents of the drained aerosol cans are promptly transferred to appropriate containers
• Processing occurs in a well-ventilated area
• Employees are trained on procedures for sorting and processing emergencies

Additionally, a written operating procedure for safety and emergencies must be developed and implemented. The operating procedure must detail the following:

• Type of equipment used
• Operation and maintenance
• Segregation of incompatible wastes
• Proper waste management practices (i.e. away from heat and flames)
• Waste characterization

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 info@altaenviron.com.