EPA Eases Requirements for Aerosol Cans
In December, EPA issued a new rule that reduces the regulatory requirements for waste aerosol cans. EPA added waste aerosol cans that would be classified as a hazardous waste to the list of wastes covered under the universal waste program. This rule is significant because aerosol cans are generated by nearly every business in every industry, including printing operations. The new rule is aimed at improving recycling and reducing the cost and burden of aerosol can management by imposing less stringent regulatory requirements on the cans.
Aerosol cans that are not empty frequently contain flammable propellants such as propane or butane that can cause them to exhibit the ignitability characteristic. An aerosol can may also contain materials that exhibit hazardous characteristics or contain ingredients that are specifically regulated by EPA. Leaking and damaged aerosol cans may also be managed as universal waste, so long as the leaking or damaged cans are packaged in a separate closed container, overpacked with absorbents, or immediately punctured and drained.
Among other things, the aerosol can wastes will no longer have to be labeled as hazardous wastes (although they will be subject to reduced marking requirements), they may be stored for up to one year or even longer in some cases (rather than just 90 days for large quantity generators), they may be transported offsite without a hazardous waste transporter or hazardous waste manifest
The requirements for full or partially full waste aerosol cans that will be recycled are the same as other universal wastes. This means they can be accumulated onsite for up to one year, shipped off-site without a hazardous waste manifest or Land Disposal Restriction form, and the universal waste aerosol cans, or the container in which the cans are accumulated, must be marked or labeled with any of the following: “Universal Waste—Aerosol Can(s),” “Waste Aerosol Can(s),” or “Used Aerosol Can(s).” Documentation regarding the fate of the cans needs to be maintained.
According to EPA, even though empty aerosol cans do not have to be managed as universal waste, they may be if the handler prefers to do so. Likewise, nonhazardous aerosol cans may be managed as universal waste, although they are not required to be managed as such.
For more information or to ask any questions, email the Government Affairs Department at firstname.lastname@example.org.
Marci Kinter is the Vice President – Government and Regulatory Affairs for the PRINTING United Alliance. Kinter oversees the development of management resources for the Association and represents the screen printing and digital imaging industries, as well as their associated supplier base, before federal and state regulatory agencies and the U.S. Congress on environmental, safety and other government issues directly impacting the screen printing and graphic imaging industries. She is responsible for directing the activities of not only the government affairs portion of the Association’s activities, but the development and implementation of business resources for the membership.
In 2008, Kinter, in conjunction with colleagues from other printing trade associations, was instrumental in launching the Sustainable Green Printing Partnership program. The SGP Program is a registry system for printing facilities that includes third party verification. The program successfully launched as an independent organization in August 2008.
Kinter is a member of and serves as Secretary for the Academy of Screen Printing Technology. In 2001, Kinter received the William D. Schaeffer Environmental Award for significant advancement of environmental awareness in the graphic arts industry.
Before joining PRINTING United Alliance, Kinter worked for The American Waterways Operators, Inc., the national association for the barge and towing industry.
She holds bachelor’s degree in urban planning from the University of Maryland, College Park, and a master’s degree in public administration from George Mason University.