RCRA and Retail: Considering the Fate of Consumer Aerosol Cans

Environmental Law Institute
Date Released
May 2018
RCRA and Retail: Considering the Fate of Consumer Aerosol Cans

Minimizing waste generation includes diverting waste streams to reuse and recycling as well as recapturing materials. In devising new approaches for the management of materials and the diversion of wastes under RCRA, federal regulators can draw on their knowledge and years of experience working with particular sectors and materials. In the retail sector, managing discarded and returned consumer aerosol cans can hit the "tripwire" for RCRA ignitability, requiring their management as hazardous waste. This waste stream also accounts for nearly half of the RCRA-regulated material in the retail sector, driving the status of retail stores as large-quantity generators. Awkwardly, these same cans, when disposed of by consumers, are treated as household waste and can be managed or recycled in other ways, including ways that involve substantial steel and aluminum recovery from municipal waste management. This ELI report examines the regulation of the retail sector, the fate and recovery of materials from aerosol cans, and opportunities for further action.

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