Crushing Hazardous Waste is Regulated as Treatment [40 CFR 260.10]
If you are a hazardous waste generator that crushes hazardous waste as part of your management practices, you are conducting a form of hazardous waste treatment.
Treatment is defined as any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste non-hazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume (40 CFR 260.10).
EPA has previously noted that crushing aerosol cans (EPA Memorandum, Petruska to Citizen; September 12, 1989 (RCRA Online 11466)) and decanning and crushing operations (EPA Memorandum, Skinner to Scarborough; April 26, 1984 (RCRA Online 12214)) meet the definition of treatment.
However, hazardous waste generators may conduct treatment, including crushing, in regulated units without a permit as long as they are not conducting thermal treatment (56 FR 10146, 10168; March 24, 1986).
To ensure that your hazardous wastes are managed properly, attend Environmental Resource Center's Hazardous Waste Management - The Complete Course, or state-specific hazardous waste management training in California or Texas.