Aerosol Can Puncturing & Waste Management Guide

Aerosol can waste can be one of those sneaky waste streams - hidden in plain sight, often forgotten. And once you start asking around about how personnel manage them, you may get answers you don't like...but don't let this low-hanging fruit trip you up during a regulatory inspection! Check out the tips for compliance below!

Compliant with EPA (40 CFR 273) and TCEQ (30 TAC 335.261)

1. Background and Regulatory Overview

Federal (EPA - RCRA)

As of February 7, 2020, non-empty aerosol cans that are hazardous waste are regulated as universal waste under the Resource Conservation and Recovery Act (RCRA).

40 CFR 273.6 – Definition of Aerosol Can

40 CFR 273 Subparts C & D – Universal Waste Standards

Texas (TCEQ)

Texas adopted the federal aerosol can universal waste rule effective August 24, 2021, allowing handlers to manage these cans under streamlined universal waste standards.

30 TAC 335.261(a) adopts 40 CFR Part 273

See: TCEQ Universal Waste Page

2. Who Can Puncture Aerosol Cans?

Only universal waste handlers may puncture aerosol cans provided they meet specific requirements, including the use of proper equipment and written procedures.

You must:

• Be a small or large quantity handler of universal waste.

• Use a commercially manufactured puncturing device that safely contains contents and controls emissions.

• Train all employees who will operate the device.

3. Requirements for Puncturing Aerosol Cans

Written Procedures Are Required

Handlers must establish and follow written procedures covering:

• Assembly, operation, and maintenance of the puncturing device.

• Segregation of incompatible wastes (e.g., oxidizers vs. flammable liquids).

• Management practices to prevent fires, releases, or employee exposure.

These procedures must be:

• Available for review by regulatory inspectors.

• Updated whenever devices or processes change.

• Implemented through training for all employees operating the equipment.

4. Conditions for Safe Puncturing

Under 40 CFR 273.13(e)(4) and 273.33(e)(4):

• Puncturing must be performed in a designated area with:

  • Ventilation,

  • Spill control measures, and

  • Fire suppression equipment.

• Devices must capture both liquids and gases safely.

• Gases should be filtered (e.g., through a carbon filter) to prevent emissions.

  • Tip: Mark the date of filter installation for tracking.

• Containers of drained liquid must be closed, compatible, and labeled.

5. Waste Generated from Puncturing

Liquid Residue

• Must be evaluated for hazardous characteristics (ignitability, toxicity, etc.).

• If hazardous, it must be managed under 40 CFR Parts 262–268 and Texas Hazardous Waste Rules.

Spent Filters

• Must be evaluated for hazardous characteristics (ignitability, toxicity, etc.).

• If hazardous, it must be managed under 40 CFR Parts 262–268 and Texas Hazardous Waste Rules.

Empty Punctured Cans

• May be managed as scrap metal (excluded from RCRA) if recycled.

• If not recycled, evaluate for residual hazardous characteristics.

6. Safety Measures

• Operate in a non-smoking, well-ventilated area, away from any waterways or drainage areas.

• Ensure all equipment is spark-proof and/or explosion-proof.

• Use PPE: goggles, gloves, respirator if needed.

• Use grounding and bonding practices for flammable contents.

• Inspect puncturing device before each use and maintain per manufacturer specs.

• Use the appropriate waste labels and hazard labels on the waste container.

• Must be accumulated in a container that is structurally sound, compatible with the contents of the aerosol cans, lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions, and is protected from sources of heat.

  • Universal waste aerosol cans that show evidence of leakage must be packaged in a separate closed container or overpacked with absorbents, or immediately punctured and drained.

7. Documentation and Compliance

Maintain:

• Written procedures for puncturing and waste handling.

• Training records for all device operators.

• Maintenance and inspection logs for the puncturing unit (recommendation)

• Waste characterization records (lab results, generator knowledge).

• Universal waste logs and hazardous waste manifests, if applicable.

8. TCEQ-Specific Notes

• TCEQ does not require approval or notification for puncturing under universal waste rules.

• Drained waste must be reported in Annual Waste Summary if hazardous, as applicable in relation to waste generator status.

• You’re required to puncture no more than 40 aerosol cans per day (averaged over 12 months) to remain within the de minimis exemption under TCEQ/TAC rules. Exceeding that limit could elevate you to a regulated source requiring additional air permitting. 

9. Prohibited Actions

Do NOT:

• Operate without written procedures or training.

• Allow contents to discharge to the environment (i.e. puncturing without a commercially manufactured puncturing device).

• Mix incompatible materials (e.g., acids with bases).

• Dispose of drained liquids without characterization.

• Throw unpunctured, punctured cans, or spent filters into the regular trash.

10. Summary Compliance Checklist

Requirement	Met?
Commercial puncturing device in use	☐
Written procedures established and followed	☐
Procedures cover operation, maintenance, waste segregation	☐
Employees trained on procedures and hazards	☐
Puncturing area is ventilated and equipped for emergencies	☐
Gas emissions controlled via filter or closed system	☐
Waste properly characterized and managed	☐
Inspection and training logs maintained	☐

11. References

• EPA Final Rule – Aerosol Cans as Universal Waste

  https://www.epa.gov/hwgenerators/final-rule-management-aerosol-cans-under-universal-waste

• 40 CFR 273 – Universal Waste Rule

• 30 TAC Chapter 335 – Industrial Solid Waste and Municipal Hazardous Waste

• TCEQ Universal Waste Program

  https://www.tceq.texas.gov/permitting/waste-permits/ihw/uwaste.html