The U.S. Environmental Protection Agency (EPA) recently proposed a rule that would streamline the regulation of hazardous waste aerosol cans (currently managed under the Resource Conservation and Recovery Act (RCRA) Subtitle C, generally because of their ignitability, and subject to stringent rules on handling transport and disposal) by adding them to the existing federal list of materials that can be managed under the universal waste management system. EPA’s universal waste rules provide a streamlined hazardous waste management system for common industrial wastes like batteries, pesticides, mercury-containing equipment, and lamps. (“Authorized” states would choose whether or not to adopt the new universal waste rules into their state programs. Some states have already added them to their universal waste lists.) This would likely simplify handling and disposal for contractors and save firms money (e.g., no manifest required for transport). Notably, because aerosol cans are often the only hazardous waste stream produced on a construction site, classifying them as universal waste could change a company’s “generator status” and exempt it from RCRA Subtitle C hazardous waste requirements. Universal wastes do not need to be counted toward a hazardous waste generator’s inventory for determining whether the generator is classified as a Very Small Quantity Generator, Small Quantity Generator, or Large Quantity Generator.