Simply by virtue of the gas inside them, discarded aerosol cans are treated as hazardous waste under the Resource Conservation and Recovery Act (RCRA). But these same cans, when disposed of by consumers, are treated as household solid waste, meaning they can be managed or recycled differently, including ways that involve substantial steel and aluminum recovery from municipal waste management.
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.