There have been recent cases of generators believing a product was being disposed of,
but it ended up in a secondary marketplace...this can cause brand damage
March 2021 Spray 39
and potential economic consequences...
• VSQGs: Generate 100 kilograms or less per month of
hazardous waste or one kilogram or less per month of acutely
hazardous waste
• SQGs: Generate more than 100 kilograms, but less than
1,000 kilograms of hazardous waste per month
• LQGs: Generate 1,000 kilograms per month or more of
hazardous waste or more than one kilogram per month of
acutely hazardous waste
The major requirements for each generator status are available
at: epa.gov/hwgenerators/categories-hazardous-waste-generators.
Cradle to grave
When it comes to proper disposal, the generator of the waste has
“cradle to grave” responsibility for their product, meaning they
are accountable for their waste from initial generation through
ultimate disposal and beyond. The EPA is very clear on joint
and other liabilities when it comes to long-term environmental
stewardship.
This is why partnering with a quality transport and disposal/recycling
organization is essential to a business’ short- and long-term
liability. It is vital to maintain compliance and ensure an organization
is adhering to Federal and State regulations, which may vary
State-by-State. If an incident happens at any point during a waste’s
lifecycle, or post-lifecycle, a generator can be pulled back into
the “picture” if the organization hired does not have significant
financial strength.
Environmental concerns
While aerosol cans have a long shelf-life, when thrown in the
trash instead of being recycled, those cans put our environment at
risk. Many of the liquids inside aerosol cans are hazardous, such
as paints and flammable lubricants, while other materials may be
toxic, like pesticides and cleaning products. Even after the aerosol
no longer sprays, leftover propellant can pose safety and environmental
challenges. In addition, the pressurized can also presents a
reactivity hazard if exposed to pressure or heat.
Most metals do not break down over time in landfills, including
most components found in aerosol cans. This, combined with
leftover product, causes the potential risk of the liquid or gas seeping
into the soil. By properly disposing of aerosol cans, a generator
can rest assured they are helping protect people, communities
and the environment.
Handling tips
Proper handling, disposal and recycling of aerosols are of the
utmost importance. Primary tips for storing hazardous waste,
including aerosol products, include:
• Segregate incompatible chemicals. It is recommended to use
separate accumulation bins or drums that are designated for
each specific categories of waste—for example: aerosols, flam-
mables, toxics, corrosive acidic, corrosive alkaline (basic),
oxidizers and universal waste.
• Ensure proper storage. All hazardous waste should be stored
in a dedicated, permanent, clean and organized hazardous
waste area. The ideal location is away from traffic areas, elec-
trical panels, perishable or consumable product storage and
dock doors. The containers should be placed on an impervi-
ous surface, such as pavement or tile, without active floor
drains.
• Keep proper records. Maintaining an inventory log will help
the on-site crew manage and track waste generation volumes.
Every time an item is identified as hazardous waste and
placed into an accumulation container, it should be logged
and kept in the facility’s records with thorough paperwork.
Once the aerosol is no longer usable due to being emptied
or no longer exhausting the substance because the propellant is
gone, it becomes waste and is ready for disposal through recycling.
Benefits of recycling aerosol components
While there is a general industry understanding of how to recycle
items such as motor oil, batteries and electronics, there can be a
lack of understanding about how to recycle aerosols. All components
of an aerosol can be recycled, from the marketing collateral
to the consumer packaging to the aerosol components. Additionally,
the following components can—and should—be recycled:
• Actuators (spray, foam, solid stream and spray actuators)
• Dip tubes
• All valve components (continuous spray valves and metering
valves)
• Exterior body containers (tin-plated steel, aluminum and
bag-on-valve)
Recycling 100% of aerosol products provides a number of
important benefits, including:
• Zero landfilling
• Reduction of carbon footprint
• Potential to return contents to manufacturer
• Reduction in the need for brand new containers
• No long-term degradation exposure to the environment
Full recycling also can also protect a brand. For example, there
have been recent cases of generators believing a product was
being disposed of, but it ended up in a secondary marketplace.
In addition to brand damage, there are also potential economic
consequences, including cost liability for the cleanup or correct
disposal. This is why it’s vital to trust a chosen disposal supplier
and to get documentation showing the material was processed
properly.
Find a Trusted Partner
Today, more than 90% of CEOs state that sustainability is a
major component to the success of their companies. Key factors
include maintaining ethical governance, continuous recruiting
of top talent and respecting the local communities that provide
customers, suppliers and employees.
After understanding an organization’s environmental vision,
aerosol professionals should then find a recycling and disposal
partner who can support those sustainability plans. Make sure any
vendor partner shares these same business philosophies. Spray