Retail Initial Discussion Topic - E-cigarettes

Unused e-cigarettes, when destined for disposal or recycling must be evaluated to determine if they are subject to hazardous waste regulation.  E-cigarettes generally have two components that may cause them to be subject to hazardous waste regulation: a nicotine containing cartridge or cylinder and a lithium battery.  The nicotine in an e-cigarette is toxic and is a P075 listed hazardous waste when discarded.  The lithium battery is also presumed to be a D003 reactive hazardous waste if is 6 volts or greater.  To minimize the amount of hazardous waste generated, where possible and where it can be done safely, a generator may remove the hazardous components of the e-cigarette and manage them separately.  If the nicotine containing cylinder/cartridge is removed and disposed separate, only the weight of the nicotine containing cylinder/cartridge must be counted when determining a site’s hazardous waste generator status, assuming the battery is either removed or determined to be non-hazardous ( less than 6 volts).  If any hazardous component remains in the e-cigarette (the nicotine or a battery 6 volts or greater) one must count the weight of the whole e-cigarette when determining a site’s hazardous waste generator status.  If a battery in an e-cigarette is reactive, the simplest option is to manage the battery as a universal waste.  Note too, if the nicotine container within the e-cigarette is legitimately recycled into nicotine that is used to make new nicotine products, the nicotine is exempted from hazardous waste regulation.  All e-cigarette disposal and recycling must be documented.  Even if e-cigarettes are generated by a conditionally exempt small quantity generator of hazardous waste and lawfully landfilled, the generator must provide verification of special waste approval for disposal by the landfill.