Recycling Spray Products
The importance of properly discarding aerosol cans Howard Ray
Aerosol cans are widely used to dispense a broad range of
products and account for nearly 40% of retail items that
are managed as hazardous waste at large retail facilities.
It is estimated that 3.67 billion aerosol cans were filled in the
U.S. in 2019 for commercial, industrial and household use. As
sustainability goals remain a meaningful priority for organizations
of all types, it is critical that these products are handled
and disposed of responsibly in compliance with State and
Federal law in a way that reduces their potential environmental
impacts.
Aerosols as Universal Waste
In early 2020, the U.S. Environmental Protection Agency (EPA)
put into effect a Final Rule adding aerosol cans to the Universal
Waste (UW) Program under the Resource Conservation & Recovery
Act (RCRA). The streamlined universal waste regulations
provide a clear, protective system to manage discarded aerosol
cans, with the intent to:
• Ease regulatory burdens on retail stores and others that
dispose hazardous waste aerosol cans
• Promote the collection and recycling of these cans
• Encourage the development of municipal and commercial
programs to reduce the quantity of these wastes going to
municipal solid waste landfills or combustors
38 Spray March 2021
States can adopt the rule change as-is or place additional
requirements on it. At this time, approximately half of U.S. States
have adopted the rule or shared a timeline for when it will go into
effect.
For organizations operating in multiple States, the “aerosols
as universal waste” program may differ for each facility. It is
important to keep a pulse on State-by-State adoption of the rule.
The Retail Industry Leaders Association (RILA), the trade association
for retail leaders, offers a tracking matrix following State
implementation of the rule with information on the State process
where relevant. As SPRAY goes to press, Indiana was the latest
state to adopt the Final Rule.
Categories of Hazardous Waste Generators
Facilities with aerosol products that fall under the EPA guidelines
for hazardous waste must follow the EPA guidelines as
to whether they are a very small quantity generator (VSQG),
small quantity generator (SQG) or large quantity generator
(LQG). A generator is any person who produces a hazardous
waste as listed or characterized in Part 261 of Title 40 of the
Code of Federal Regulations (CFR). Each distinction has its
own set of requirements and generators must comply based on
their status. The main component of each category of generators
is:
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