Full Document:
RCRA Online Number: 11780
Title: REGULATORY STATUS OF USED RESIDENTIAL AND COMMERCIAL/INDUSTRIAL AEROSOL CANS
Document Date: 1993-10-07
To: DiFazio
From: Denit
Organization of Recipient: Chemical Specialties Manufacturers Association
Description: Aerosol cans generated by households qualify for the household hazardous waste exclusion. The exclusion attaches at the point of generation and continues throughout the waste management cycle. Steel aerosol cans are scrap metal when they are recycled if they do not contain significant liquids. There is no need to determine if a steel aerosol can is empty once it qualifies as scrap metal. Emptying an aerosol can by puncturing and draining may be exempt as a step in the recycling of the can as scrap metal. EPA is unable to determine if aerosol cans exhibit the characteristic of reactivity (D003). Liquid or gas removed from a can is hazardous waste if it is listed or characteristic. Aerosol cans may be emptied in accordance with 261.7.
Regulatory Citation(s): 261.4(b)(1), 261.1(c)(6)
Official ORCR Policy: Yes
Associated Topic(s):
Characteristic Wastes,
Containers,
Exclusions (RCRA),
Hazardous Waste,
Hazardous Waste Recycling |