Aerosol cans pose a unique hazardous waste determination problem because they consist of three different types of materials, each of which may be classified as hazardous waste: 1) the can itself; 2) the liquid product contained in the can; and 3) the gaseous propellant.
It remains the responsibility of the generator of any particular waste to make this hazardous waste determination. However, a steel aerosol can that does not contain a significant amount of liquid (emptied through normal use) would meet the definition of scrap metal, and if it is to be recycled, would be exempt from the Delaware Regulations Governing Hazardous Waste. Scrap metal that is recycled is exempt from the DRGHW even if it is hazardous waste, so generators need not make a hazardous waste determination.
Used (waste) aerosol cans that are not recycled as a scrap metal are subject to the hazardous waste regulations if it is hazardous.
The Delaware Solid Waste Authority will accept your used aerosol cans for scrap metal recycling, at no charge. The DSWA has recycling centers recycling centers throughout the State. The DSWA recycling containers will accept empty aerosol cans that have the plastic spray knob removed. The DSWA requests small businesses recycle no more than 50 empty aerosol cans at a time.
In short, to properly recycle used aerosol cans as a scrap metal, you should:
• Never dispose of used aerosol cans in the trash. You could be illegally disposing of a hazardous waste which may result in enforcement actions and accompanying penalties;
• Designate a container for the collection of used aerosol cans at your business;
• Label the container "Used (Empty) Aerosol Cans Only;"
• Remove the plastic spray knob from each can. Place the plastic spray knob in the trash;
• Use the DSWA recycling centers to recycle your used aerosol cans;
• Take no more than 50 used aerosol cans at a time;
• In addition to empty aerosol cans, you can also recycle aluminum and steel cans with the DSWA; and
• Items not accepted through this metal recycling program include: foil or pie trays, paint cans, propane cylinders, siding, beach or lawn chairs.
Recycling used aerosol cans as a scrap metal will help reduce some hazardous waste regulatory requirements, save you money on disposal cost and be beneficial to the environment and the State of Delaware.
If you have any questions, feel free to contact the Solid and Hazardous Waste Management Branch at (302) 739-9403.
