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Aerosol Can Questions continued from page 6

Are you planning to recycle the can?

If so, here are the management topics that affect you:

  • If the aerosol can contained only a compressed gas, such as the previous example, then the

can is empty once it reaches atmospheric pressure. Once that occurs, then it no longer contains a hazardous waste. Since you are recycling the container, it is not subject to hazardous waste rules.

  • If the aerosol can contained a product such as paint or solvent, then once it no longer

contains a significant amount of liquid, it meets the definition of scrap metal and would be exempt from regulation under OAC rule 3745-51-04(A)13).

According to U.S. EPA, aerosol cans that have been punctured so that most of the remaining liquid may drain from the can (for instance, at either end of the can), and drained (for example, with punctured end down), would not contain significant liquids (view the U.S. EPA letter). However, although recommended, there is no specific regulation requiring that aerosol cans be punctured. That is unless you maintain a can puncturing unit at your facility, wherein puncturing would be considered “a practice commonly employed to remove materials from aerosol cans,” and therefore, your aerosol cans must be punctured in order to be considered empty. In addition, many scrap metal recyclers require that cans be punctured.

If aerosol cans are not empty and have not been punctured, must they be managed as hazardous waste (can and contents if they are not being reclaimed, reused or recycled)?

The best way to manage aerosol cans is to recycle both the can and the contents. When managed this way, they are not subject to the hazardous waste rules.

If you intend to throw away non-empty aerosol cans, you must evaluate the contents to determine if they are hazardous. If the contents are hazardous waste, either listed or character- istic, then they will be subject to the hazardous waste rules. In addition, the can itself must be evaluated regardless of its contents. If the shell (can) is listed or characteristic, then it must be managed according to the hazardous waste rules.

New Option for CESQGs in Northeast Ohio

by Pam Allen

Are you a conditionally exempt small quantity generator (CESQG) in Northeast Ohio?

If so, you may have a new option for managing your hazardous waste, universal waste and used oil. The BIZMATSM center is open for business and is accepting certain wastes from CESQGs in Summit, Cuyahoga, Stark, Portage, Medina and Wayne counties. The majority of the material brought to the center will be recycled.

BIZMATSM is operating as a two-year pilot program and is managed by the Ohio Organiza- tion for Recycling and Reuse (OORR), a non-profit organization. Heritage Environmental Services oversees the daily operations.

As participants, CESQGs will be able to bring their waste to BIZMAT. The cost to dispose of as much as 220 pounds of material is $95; $75 of that fee will go toward paying the operating costs for the center and $20 will go into a fund established to help businesses finance brownfield restoration projects.

Additional information is available at www.bizmatcenter.org.

Notifier-Winter 2006

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