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Aerosols as universal waste: retail implications

The EPA has signed a proposed rule to handle aerosols as universal waste instead of hazardous waste. This rule is expected to ease regulatory burden of managing aerosols and will allow many retailers to reduce their generator status.

At large retail facilities, aerosols account for up to 40% of the items managed as hazardous waste. Managing aerosols as universal waste means that many retailers will be able to significantly reduce how much hazardous waste they are generating. 

Currently, the 5,194 affected retail LQGs cannot store waste for more than 90 days, must complete hazardous waste manifests, and are required to manage aerosols under the full RCRA Subtitle C hazardous waste management program. This often translates to more headaches for all levels of business, from corporate strategy and compliance, to store management and day-to-day operations.

With the passing of this rule, aerosols will join hazardous waste batteries, certain hazardous waste pesticides, mercury-containing equipment, and hazardous waste lamps as universal wastes. 

Universal wastes do not count towards generator status; they do not have to be labeled as hazardous wastes; they may be stored for a year or longer; and they do not require hazardous waste manifests. 

This presents a major opportunity for retailers to reduce their generator status and save operational time and dollars, provided they have the waste disposal systems in place to make these changes quickly. Contrarily to the usual 180 day implementation period, this rule will be effective 60 days after publication in the Federal Register. 

As this rule is less stringent than the status quo, states will have the option to adopt the new rule. States will either chose to adopt or decline during the 60 day period, resulting in an incredibly shortened timeline to make operational changes.

For Smarter Sorting customers, this process is quick and painless, our platform will automate decisions for retail back of store employees, allowing retailers to realize reduced generator status from the first day of this rule being in effect. Our historical data and real-time generator status tracking gives retail compliance professionals the confidence and peace of mind to manage their waste programs at a lesser generator status without running the risk of retroactively realizing they have spilled over into the next generator status level. 

Have any questions about universal waste or generator status? Drop us a line and we’ll be in touch.