Is the puncturing of aerosol cans with AEROSOLV considered treatment?
No, however, according to the EPA’s Office of Solid Waste: a steel aerosol can that does not contain a significant amount of liquid (e.g., a can that has been punctured and drained) would meet the definition of scrap metal (40 CFR 261.1(c) (6)), and, if it is to be recycled, would be exempt from regulation under 40 CFR 261.6(a) (3) (iv). Scrap metal that is recycled is exempt from RCRA regulation under this provision even if it is hazardous waste, so generators need not make a hazardous waste determination. In 1999 California EPA certified the Aerosolv process to eliminate the classification of treatment.
