Aerosol Cans in the Shop: Trash, Hazardous Waste or Universal Waste?

1.Start With the Can, but Do Not Stop There

EPA's federal Universal Waste rule applies to aerosol cans that would otherwise be hazardous waste. That means the first question is not simply whether the container is an aerosol can. The dealership needs to determine whether the discarded can and its contents would be regulated as hazardous waste.

Products can become hazardous waste for different reasons, including ignitability, corrosivity, reactivity, toxicity or because the discarded material is specifically listed under hazardous-waste rules.

In practical terms, the same dealership may have aerosol cans that qualify for Universal Waste management and others that do not. Treating every can as identical is easy. It is not always correct.

2.Universal Waste Is an Alternative Management System

EPA's Universal Waste regulations create a streamlined system for certain widely generated hazardous wastes. Aerosol cans joined batteries, certain pesticides, mercury-containing equipment and lamps on the federal Universal Waste list.

For a dealership, the advantage is that qualifying aerosol cans can be managed under Part 273 rather than under the full hazardous-waste standards that would otherwise apply.

That does not make the cans unregulated. It changes the way they may be accumulated, handled and sent off site.

3.Keep Universal Waste Aerosol Cans in a Sound Container

Under the federal rules, Universal Waste aerosol cans must be accumulated in a container that is structurally sound, compatible with the contents, and free of evidence of leakage, spillage or damage that could cause a release under reasonably foreseeable conditions.

The accumulation container also needs to be protected from sources of heat.

Look at the actual aerosol-can collection point, not just the written procedure. Is the container intact? Is it in a sensible location? Is it being used only for the intended waste stream?

4.Leaking Cans Need Different Attention

EPA requires leaking Universal Waste aerosol cans to be packaged in a separate closed container or overpacked with absorbent material, unless they are immediately punctured and drained in accordance with the applicable Universal Waste requirements.

A leaking can is not something to bury under the rest of the pile and hope it disappears during pickup.

Employees who handle the collection area should know what to do when they find a damaged can and who is responsible for dealing with it.

5.Can You Mix Different Aerosol Cans Together?

Federal Universal Waste rules allow handlers to sort intact aerosol cans by type, mix intact aerosol cans in the same accumulation container and remove actuators to reduce the risk of accidental release, as long as the cans remain intact.

That flexibility is useful in a dealership where several departments generate small numbers of different aerosol products. It also makes clear why the collection container needs to be managed deliberately rather than treated like ordinary trash.

6.Puncturing Is Allowed, but It Is Not Casual Shop Work

EPA allows Universal Waste handlers to puncture and drain aerosol cans, but only when specific requirements are met. Those include using a device designed to safely puncture aerosol cans and contain residual contents, following a written procedure, preventing fires and releases, and properly managing the material collected from the cans.

The emptied punctured cans must then be recycled. EPA specifically says a handler that punctures Universal Waste aerosol cans cannot simply put the empty punctured cans into ordinary trash.

For many dealerships, sending intact cans to an appropriate Universal Waste handler may be simpler than establishing and maintaining an on-site puncturing program.

7."Empty" Needs More Thought Than It Usually Gets

One of the easiest mistakes in aerosol-can management is assuming that a can is empty simply because the user no longer wants it or because it no longer sprays as expected.

Whether a container is considered empty under hazardous-waste rules depends on the applicable regulatory definition and the material involved. A can with remaining hazardous product may still present both waste-management and physical hazards.

Make the empty-versus-nonempty decision part of the dealership's waste procedure rather than leaving it to whoever happens to be holding the can.

8.Do Not Mix Regulatory Systems

EPA allows generators to manage qualifying hazardous waste aerosol cans either under the Universal Waste regulations or, where applicable, under the hazardous-waste generator rules.

What a facility cannot do is pick and choose requirements from both systems to create its own hybrid. If the dealership chooses the Universal Waste route, it needs to follow the applicable Universal Waste standards. If it manages the cans under the hazardous-waste rules, it needs to comply with those requirements instead.

9.Your State Matters

The federal government added aerosol cans to the Universal Waste program, but authorized states generally must adopt that provision before it becomes part of their state program.

EPA maintains a state-by-state table showing which Universal Waste provisions have been adopted. State programs can also impose additional requirements.

That is especially important for dealer groups operating in several states. The waste stream may look identical from one rooftop to another while the applicable state rule is not.

10.The Best System Is One Employees Can Actually Follow

Aerosol-can compliance does not need to become a chemistry project for every technician.

Management should determine which waste-management system the facility is using, establish the collection points, label and maintain them appropriately, train the employees who need to use them and make sure the cans go to the correct destination.

The employee-level instruction can then be simple: which cans go where, what not to put in the container, what to do with a leaking can and whom to ask when something does not fit the normal rule.

The Bigger Picture

Aerosol cans are a good example of a dealership waste stream that looks too ordinary to deserve much attention.

That is exactly why they can become a problem. One can gets tossed into the trash. Then another. Eventually the habit becomes the facility's waste-management system.

A designated container, a clear procedure and a little employee training are considerably easier to manage than sorting out an aerosol-can problem after an inspection or a waste-vendor issue.