Spent Aerosol Can Exemptions

RCRA Regulation of Aerosol Cans
40 CFR 261.7 (b) (1(i) & (iii), And (40 CFR 261.23 (a) (6)

A company generates aerosol paint and solvent cans from painting and cleaning operations. The cans are empty as per common industry practices used to empty such devices to less than 3% by weight of the total capacity of the container (40 CFR 261.7(b) (1(i) & (iii). The cans may still contain propellant, making the can reactive if put in contact with strong initiating force.

Irrespective of the lack of contained waste, the aerosol cans would be a RCRA hazardous waste because they demonstrate the hazardous characteristics of reactivity (40 CFR 261.23 (a) (6)