A handful of States allow spent aerosol cans to be handled under State Universal Waste rules (email Caltha LLP if you would like to know if your State is included), although this waste stream is not a Federal universal waste under 40 CFR 273. The Minnesota Pollution Control Agency has finalized rules that will allow generators to manage aerosol cans as universal wastes.
Because documenting that an aerosol container or gas cylinder meets “RCRA Empty” standard can be impractical, MPCA allows generators to assume that an aerosol container is empty when both the following conditions are met:
· No liquid is felt or heard when the container is shaken by hand; and
· No gas or liquid is released when the spray/discharge valve is activated and the container rotated through all directions, as long as the valve is not observably or known to be clogged.
Hazardous waste aerosols and gas cylinders that are not empty can be managed under rules equivalent to universal wastes in Minnesota. Generators must accumulate hazardous waste aerosols and gas cylinders in closed containers labeled with one of these phrases:
· Universal Waste Aerosols/Gas Cylinders (whichever is appropriate)
· Waste Aerosols/Gas Cylinders
· Used Aerosols/Gas Cylinders
Accumulated hazardous waste aerosols/gas cylinders can be stored on-site for no more than one year and must be dated to verify how long they have been stored. Generators can ship hazardous waste aerosols/gas cylinders without a hazardous waste manifest to any site that has agreed to accept and properly manage them.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
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