SQG Fact Sheet

Alabama Department of Environmental Management

Land Division

P. O. Box 301463

Montgomery, AL 36130-1463

Telephone 334-271-7730

Fax 334-279-3050

February 2021

Hazardous Waste Management

Management of Aerosol Containers

Information presented in this fact sheet is intended to provide a general understanding of the regulatory requirements governing the management of disposable aerosol containers. This information

is not intended to replace, limit, or expand upon the complete regulatory requirements found in Division 14 of the Alabama Department of Environmental Management Administrative Code.

WHAT IS AN AEROSOL CONTAINER?

An aerosol container is a dispenser that holds a substance under pressure and that can release that

substance, usually by means of a propellant gas, in a number of forms such as wet sprays, fine sprays, powder

sprays, foams, or pastes. Common liquefied propellants include propane, butane, and isobutane.

WHAT ARE THE SAFETY AND ENVIRONMENTAL CONCERNS FOR AEROSOL CONTAINERS?

Some aerosol products (for example, paints, solvents, and pesticides) are hazardous due to the presence of

hazardous ingredients. Aerosol products should be used with adequate ventilation and/or personal protective

equipment to prevent inhalation and exposure that may result in harmful health effects. Extreme temperatures

may cause containers to rupture and moisture may cause them to rust, resulting in a release of the contents to

the environment. Many aerosol containers pose a fire hazard because they contain highly flammable

propellants such as propane and butane. Pressurized containers present additional concerns. If punctured,

the contents may be released so forcefully that injuries can result. Also, pressurized containers delivered to a

landfill present safety concerns during compacting.

Spent Aerosol Can Management:

How will you manage your spent aerosol cans?

I will RECYCLE my cans.

Are the cans empty?

Yes:

Empty aerosol cans being recycled

are excluded from management as

solid (and therefore hazardous)

waste.

[See 335-14-2-.01(4)(a)13.]

No:

Cans may be recycled, but the

contents are solid wastes subject to

a hazardous waste determination.

Any liquids or propellants removed

from the cans must be managed in

accordance with ADEM Div. 14

requirements.

[See 335-14-3-.01(2) and 335-14-2-

.01(7)(a)3. ]

I will DISPOSE my cans.

Are the cans empty?

Yes:

Empty Aerosol cans that are fully

depressurized may be disposed of

as solid wastes, subject to a

hazardous waste determination.

[See 335-14-3-.01(2) and 335-14-2-

.01(7)(a)1.]

No:

A discarded aerosol can is a

hazardous waste if the can and its

contents exhibit a hazardous waste

characteristic or if it is a listed

hazardous waste.

Discarded hazardous waste aerosol

cans may also be managed as

Universal Waste.

[See 335-14-3-.01(2) & 335-14-11]

“Empty” means the aerosol can does not contain a significant amount of free liquid and also that the propellant

has been used up so that the pressure in the can is at or near atmospheric pressure. This can usually be

determined during the normal use of the product in the manner it was intended to be used. If you cannot

demonstrate that the can is empty, then it must either be managed as hazardous or universal waste or be

emptied either by the means ordinarily used to render aerosol cans empty (by dispensing the product and

Management of Aerosol Containers

Page 2 of 3

propellant in the normal method) or by some other method (e.g. the can must be punctured, crushed, or

shredded and the gas and the liquid must be contained/captured and managed appropriately). If your aerosol

can held an acute hazardous waste it must be triple rinsed to be considered “empty”. [See 335-14-2-.01(7)]

WHAT IS THE PREFERRED MANAGEMENT METHOD FOR AEROSOL CONTAINERS?

• Manage the container as universal waste. [See 335-14-11 for full details]

• Empty the container, either through normal use or by puncturing and draining.

• When puncturing a container, collect both the liquid and the gas in an appropriate collection device.

• Send the empty container to a scrap metal recycler.

• Dispose of the collected residues appropriately, based on their regulatory status - either as solid or

hazardous waste.

While landfill disposal of the empty containers is an acceptable alternative, it is the least preferred option.

MAY I USE A DEVICE TO PUNCTURE AEROSOL CONTAINERS?

Companies that regularly generate significant numbers of waste aerosol containers may be interested in using

a device to puncture and drain the containers. Punctured, drained aerosol containers are known as

“processed scrap metal”, which is exempt from the solid waste regulations so long as it is recycled. Use of

such a device does not require a waste-treatment permit at this time. If you choose to use one, consider the

following precautions:

• Do not puncture containers with any of these ingredients: ethyl ether (often in starting fluids),

chlorinated compounds, pesticides, freons and foamers, oven cleaners, or unknowns. It is

safer to manage these as either hazardous waste or universal waste.

• Follow the manufacturer’s instructions for operating, cleaning, and maintaining the device.

• Employees operating the device should be thoroughly trained in its use and should wear appropriate

personal protective equipment.

• Sort containers by size and puncture similar sizes at the same time. You may wish to puncture

containers with solvents, degreasers, and/or lubricants last to help clean the device.

• Operate only in an open, well-ventilated area. Avoid confined spaces.

• Collect liquids and propellants in an appropriate hazardous waste container.

• Keep the unit closed when it is not in use.

HOW SHOULD I MANAGE AEROSOL CONTAINERS THAN CANNOT BE EMPTIED?

• First try to return or exchange malfunctioning aerosol containers. Malfunctioning aerosol containers

returned to the supplier or manufacturer are considered “products”, not “wastes”.

• Non-empty aerosol containers that cannot be returned or exchanged must usually be managed as

hazardous waste, depending on the specific contents (including propellants, which are often

flammable).

• Non-empty hazardous waste aerosol containers may also be managed as universal waste.

HOW CAN I REDUCE MY AEROSOL CONTAINER WASTE?

 Determine whether or not a product is needed. Could the process using the aerosol be eliminated?

 Could a non-aerosol product be used instead of the aerosol product?

 If an aerosol product is needed, choose the least hazardous product that will do the job.

 Use only as much as is needed.

 Store aerosol containers away from moisture, sunlight, and extreme heat or cold.

Management of Aerosol Containers

Page 3 of 3

 Follow the label instructions to clean the nozzle after each use.

 Use the entire contents of a container before buying more.

 Purchase according to demand so that the product’s shelf life does not expire.

 Consider purchasing products in bulk and using either a refillable container with compressed air as the

propellant or a non-aerosol pump applicator.

WHERE CAN I GET ADDITIONAL INFORMATION?

ADEM Administrative Code rule (ADEM Admin. Code r.) 335-14-2-.01(6) provides more in-depth information

regarding the status of metal that will be recycled. ADEM Admin. Code r. 335-14-2-.01(7)(b)1. provides a full

definition of “RCRA Empty containers”, while “processed scrap metal” is defined at ADEM Admin. Code r. 335-

14-1-.02(1)(a). ADEM Admin. Code r. 335-14-11-.02(4)(e) provides the rules for management of universal

waste aerosol cans for small quantity handlers.

On-Line Resources

Earth 911 - http://earth911.com

ADEM Home Page - http://www.adem.alabama.gov

ADEM Administrative Code Division 14 - http://www.adem.state.al.us/alEnviroRegLaws/files/Division14.pdf

ADEM Guidance - http://www.adem.alabama.gov/programs/land/guidanceReports.cnt

Hazardous Waste Determination

Hazardous Waste: The Basics

Notification of Regulated Waste Activity

ADEM Publications - http://www.adem.alabama.gov/MoreInfo/publications.cnt

RCRA Small Quantity Generator Handbook

US Environmental Protection Agency’s Homepage - http://www.epa.gov

Telephone Resources

ADEM Ombudsman - - - - - - - - - - - - - - - - - - - 800-533- 2336

Hazardous Waste Compliance Inspectors - - - 334-271-7730

*Adapted from the following sources: Oregon Department of Environmental Quality Program Implementation Guidance Number 2005-PO-001 (dated 07/24/2005);

Nebraska Department of Environmental Quality Environmental Guidance Document 03-067, dated December 2003.