Full Document:
RCRA Online Number: 11782
Title: REGULATORY STATUS OF USED RESIDENTIAL AND COMMERCIAL/INDUSTRIAL AEROSOL CANS
Document Date: 1993-10-07
To: Crawford
From: Denit
Organization of Recipient: Steel Recycling Institute
Description: EPA is unable to determine if aerosol cans exhibit the characteristic of reactivity (D003). Emptying a steel aerosol can by puncturing and draining it may be exempt as a step in recycling the can as scrap metal. A steel aerosol can qualifies as scrap metal if it does not contain significant liquids (i.e., is fully drained) and is therefore exempt from regulation when sent for recycling. Aerosol cans may be rendered empty in accordance with 261.7. Liquid or gas removed from a can is hazardous waste if it is listed or characteristic. There is no need to determine if a steel aerosol can is empty once it qualifies as scrap metal (i.e., once it no longer contains significant liquids) that is destined for recycling. Aerosol cans generated by households qualify for household hazardous waste exclusion. The exclusion attaches at the point of generation and continues to apply throughout the waste management cycle.
Regulatory Citation(s): 261.4(b)(1), 261.1(c)(6)
RPPC Number: 9442.1993(02)
Official ORCR Policy: Yes
Associated Topic(s):
Characteristic Wastes,
Containers,
Hazardous Waste,
Hazardous Waste Recycling,
Reactive Wastes |
