My company punctures aerosol cans on-site. Is a hazardous waste facility license required for this activity?

If the aerosol can or residue inside are intended to be recycled or reclaimed, then puncturing the containers to collect the residue is considered a step in the recycling process and is not subject to hazardous waste treatment facility licensing requirements.

The drum or container used to collect the liquid residue from the punctured cans is regulated as a satellite accumulation container. The requirements in s. NR 662.034(3) Wis. Adm. Code, apply. Refer to the FAQ on satellite accumulation areas for more information.

Note: Empty aerosol cans may be reclaimed as scrap metal. Aerosol cans are considered "empty" if no more than 3 percent of the original net weight of the can or not more than 1 inch of liquid residue remains in the can. (Shake the can. If it feels like 1 inch or less of liquid remains, it should meet this criterion.)

The residue collected from the drained cans may be recycled off-site for fuel blending or burned with energy recovery.