Waste services
Aerosol can disposal
Universal waste since 2019, and why puncturing on site is a decision rather than a default.
Aerosol cans were added to the federal universal waste list in 2019, allowing management under the lighter requirements of 40 CFR Part 273. Cans may also be punctured and drained on site under specific conditions, which converts them to scrap metal and a liquid waste stream.
Source: 40 CFR Part 273 and 40 CFR 273.13(e)Puncturing on site
Permitted under 40 CFR 273.13(e) if conditions are met:
- Use a commercial device specifically designed to puncture and drain safely
- Establish and follow a written procedure
- Train employees on the device and the procedure
- Capture the contents in a closed container
- Characterize the collected liquid, which is frequently D001 ignitable
- Manage the empty cans as scrap metal for recycling
- Have a spill response plan and equipment for the area
The captured liquid is a new waste stream requiring its own determination. Puncturing converts one problem into two smaller ones, and the liquid is usually the more expensive of the two.
Puncture or ship whole
Puncturing reduces volume dramatically and turns the cans into recyclable scrap. For a site generating aerosols in quantity, distribution centres and maintenance operations in particular, it usually pays.
For a site generating a box a quarter it does not. The equipment, the written procedure, the training and the liquid stream are more trouble than shipping the cans whole as universal waste.
Common questions
Are all aerosol cans hazardous waste?
Discarded aerosols with contents remaining are usually D001 ignitable because of the propellant, and may carry other codes depending on the product. Genuinely empty cans are scrap metal.
When is an aerosol can empty?
When it no longer contains significant liquid or propellant and cannot discharge. A can that still sprays is not empty regardless of how little is left.
Can I just puncture them?
Under 40 CFR 273.13(e) with the listed conditions met. Improvised puncturing without a designed device, a written procedure and containment is neither safe nor compliant.
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This page summarizes federal requirements and is not legal advice. State programs can be more stringent than the federal baseline. Verify against current federal and state regulations before acting. Last reviewed September 2026.