Aerosol Can Puncture Safety and Operation (Environmental)

Purpose

The purpose of this document is to describe the operations and safety procedures of the J7 Aerosol Can Depressurizing System, and the disposal requirements of the empty can and can contents.

Background

Improper puncture and disposal techniques can result in unintentional emissions or residue leading to potential human health hazards. St. Mary’s will puncture aerosol cans in accordance to the procedures described in this policy.

Applicability

This document applies to all employees responsible for collection, puncturing, and disposal of aerosol cans generated on campus.

References

Reference Regulatory Sources

Spray Can – An aerosol spray can that has been both punctured and drained of its contents would meet the definition of scrap metal (40 CFR 261.1(c)(6)) and can be disposed as scrap metal or in a class I landfill via normal trash dumpster disposal. St. Mary’s will implement operational controls to puncture less than 40 cans per day as required to be considered a “de minimis” process per 30 TAC 116.119.

Contents – St. Mary’s co-mingles all aerosol spray contents into one puncturing system container (33 gallons) which is subsequently treated as hazardous waste. Hazardous waste determination will be performed on the container that holds the aerosol can contents. Disposal of this hazardous waste container will comply with 40 CFR 262.11.

Reference Documents

• Operating Instructions – J7 Aerosol Can Depressurizing System
• Standard Operating Procedure – Disposal Methods of Special Material
• Universal Waste- EPA Overview of the Universal Waste Program
• Standards for Waste Management- Title 40 of the Code of Federal Regulations

Procedures

• Before processing aerosol can, observe the color of the filter-viewing window: if black, change filter and then proceed (filter to be disposed of as Hazardous Waste); if not black, proceed.
• Place aerosol can to be emptied upright in the lower chamber of the can–emitor.
• Lower the top of the can-emitor cover down slowly until spring plunger engages, cover should be locked during the evacuation process.
• To puncture can, pull handle on puncturing mechanism down to lower vertical position.
• Slowly return handle to vertical upright position.
• Liquid and aerosol contents are immediately expelled through lower chamber into receptacle (drum).
• After contents of can are emptied, release spring locking device on back of top cover, lift cover and remove empty can.
• Place empty can into container labeled “Punctured Spray Cans – Scrap Metal”.
• Clean up any residual on inside and outside of can-emitor: every 30 days apply a thin coat of lithium grease to the following components of the can-emitor (inside machined surface of the cover, the O-ring itself, and the plunger piercing mechanism).
• Check the level of liquid waste in the receptacle (drum): if full, notify Facilities Services.

Responsibilities

Housekeeping will:

• Pickup aerosol cans within Facilities Services on a weekly basis.
• Pickup aerosol cans from Charles Francis Rooms 230, 234, and 235.
• Pickup aerosol cans from other departments outside of Facilities Services per work order requests.
• Place all waste aerosol cans in a container marked “Waste Aerosol Cans – Pending Puncture” in the Haz Waste Primary Accumulation Area.
• Puncture all aerosol cans using the J7 Aerosol Can Depressurizing System following all safety instructions (refer to Section-6).
• Place punctured cans into container labeled “Punctured Spray Cans – Scrap Metal”.

Training

All personnel responsible for picking up, puncturing and/or disposing of waste aerosol cans shall be trained on this procedure. This training is conducted annually and incorporated into the housekeeping monthly meeting schedule.

Record Keeping

An inventory tracking system will be completed at the time of puncture by the aerosol can puncture operator to track the number of cans punctured and the date of puncture. This inventory will be maintained quarterly and filed by the Housekeeping Superintendent in the Facilities Services Office, per St. Mary’s Record Retention Policy.

Disposal records for the container that stores the can contents will be retained as part of the Hazardous Waste Manifest tracking system by the Housekeeping Superintendent in the Facilities Services Office.

Glossary

Aerosol Can: A non-refillable container holding compressed, liquefied, or dissolved gas and is fitted with a self-closing release device that when pressed expels liquid, paste, or powder (40 CFR 260.10).

Hazardous Waste: A waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment.

J7 Aerosol Can Depressurizing System: A specialized equipment designed for the safe puncturing and depressurizing of aerosol cans. It features a completely sealed evacuation chamber that protects the operator from harmful propellants and emissions in compliance with the EPA and OSHA guidelines for worker safety.

Scrap Metal: Bits and pieces of metal parts or metal pieces that may be combined together with bolts or soldering, which when worn or superfluous can be recycled.

Universal Waste: A specific category of hazardous waste that is subject to streamlined management standards to facilitate proper recycling and disposal.