Aerosol Cans - PUB1084

Waste aerosol cans are a challenge for businesses to manage. A business may generate one or two cans on an infrequent basis or many as processes demand. All contents of the can (product, inert ingredients, propellants and gases) may or may not be identified on the label or Safety Data Sheet. Cans become waste when they are empty and product can no longer be expelled, or when the product has exceeded the useful shelf life. Sometimes cans become waste when the nozzle or valve fails or the contents begin to solidify. To minimize waste disposal problems, the Missouri Department of Natural Resources encourages businesses to:

• Purchase only what is required.
• Follow label directions to prevent clogging.
• Use the product within its useful shelf life.
• Purchase products without hazardous characteristics.

Aerosol cans and other wastes generated by households are exempt from hazardous waste regulation. This fact sheet and the associated decision tree for managing waste aerosol cans provide general information to help businesses manage their waste aerosol cans safely and legally. It is for general guidance only. Businesses should refer to the appropriate state and federal laws and regulations and to determine compliance. References: 10 CSR 25-4.261(1) incorporating 40 CFR 261.7, 10 CSR 25-5.262(l) incorporating 40 CFR 262.11 and 10 CSR 25-16.273(1) incorporating 40 CFR 273.13(e) and 40 CFR 273.33(e).

Waste Management Options

Universal Waste

On December 9, 2019 EPA published the final rule “Increasing Recycling: Adding Aerosol Cans to the Universal Waste Regulations” in federal register. This rule was promulgated to allow regulated facilities to manage aerosol as universal waste. Universal waste regulations are an alternative standard of management to that of normal hazardous waste regulations which had previously been applicable. On February 28. 2025 Missouri adopted the final rule adding aerosol cans to the list of universal waste in state regulation.

Facilities in Missouri can choose to manage aerosol cans as universal waste. By doing so they are eliminating the need to make hazardous waste determinations on unpunctured waste aerosol cans or manage them in hazardous waste containers. Management of aerosol cans as universal wastes allows facilities to send unpunctured aerosol cans off site to another universal waste handler or destination facility for management. While on site, facilities must manage universal waste aerosol cans in a way which prevents releases to the environment. Universal waste aerosol cans may only be managed on site for up to a year. Facilities must label universal waste cans or containers managing universal waste aerosol cans as “Universal Waste – Aerosol Can(s)”, “Waste Aerosol Can(s)”, or “Used Aerosol Can(s)”.

Puncturing of universal waste aerosol cans is allowed but only if the unit used for puncturing is designed for that function, the facility has a written plan in place for the process of puncturing cans, and the punctured cans are recycled as scrap metal. All residues collected by can puncturing units which are defined as solid waste are subject to the hazardous waste determination regulations at 40 CFR §262.11. A full list of the allowable activities as they pertain to facilities who are managing universal waste aerosol cans on site can be found at 40 CFR §273.13(e) and §273.33(e).
 

Recycling

Both empty aerosol cans and universal waste aerosol cans that have been punctured that are recycled as scrap metal are exempt from most hazardous waste regulations [40 CFR §261.7(a)(2)].

Improper depressurization of aerosol cans is extremely dangerous, and the release of hazardous material may violate the Missouri Hazardous Waste Management Law or the Clean Air Act. If aerosol cans are destined for scrap metal recycling, the process of emptying the cans is considered part of the recycling process and a hazardous waste treatment permit is not required for this activity. However, any liquids or gases removed from the cans are solid wastes if they cannot be used for their intended purpose. If unusable, the collected residues must be evaluated to determine if they are hazardous waste (40 CFR 262.11). If the contents are hazardous waste, they are subject to all applicable hazardous waste regulations regarding on-site management, transportation, treatment and disposal.

Department of Transportation regulations may apply to the transportation of some cans as hazardous material. If the contents of some cans are hazardous and the contents of others are not, the bulking and commingling of the contents are not considered illegal dilution. However, bulked contents must be evaluated for use, recycling or disposal as described above.

Disposal

For all aerosol cans, use as much of the can’s contents as possible for the intended purpose. For the can to be empty, the pressure of the propellant gas should be unable to propel any more material from the can. (Note: If the nozzle or valve malfunctions, and some of the contents remain, the can is not empty.)

If the can is empty of all liquids, gases and propellants, it may be recycled or disposed in a sanitary landfill. Recycling as scrap metal is strongly encouraged. If the can is not empty, a generator must perform a hazardous waste determination on both the can and any residuals remaining in the can (liquids, gases or propellants) before it can be disposed in a sanitary landfill. If the can or the contents are hazardous waste, it must be managed under all applicable regulations including transport, treatment and disposal as a hazardous waste.

Since unpunctured aerosol cans containing acutely toxic materials, including those that are P-listed or U-listed (such as certain types of pesticides) cannot be triple rinsed, disposal as hazardous waste may be the only option for a facility managing aerosol cans.

Additional Information

Hazardous Waste Satellite Accumulation - PUB 2215
Waste Aerosol Can Decision Tree
Code of Federal Regulations