To meet the demand during the COVID-19 pandemic, many businesses manufactured or acquired large quantities of alcohol-based hand sanitizer that is now reaching or is past its expiration date. Alcohol-based hand sanitizer is typically an ignitable hazardous waste when discarded (D001), so what options do businesses have when disposing of their surplus?
- Episodic generation: VSQGs and SQGs can prepare for a planned episodic generation event, allowing them to dispose of their surplus without it contributing toward their generator status. Notify NDEP at least 30 days prior to your disposal event.
- Recycling: if the hand-sanitizer can be returned to the manufacturer, or returned to a recycler that can reclaim the material, the hand-sanitizer does not need to be managed as a hazardous waste.
- Donation: if the hand-sanitizer is not yet expired, are there local non-profits or other facilities in your area that would accept it as a donation? Hand sanitizer that will be donated and used is not considered a hazardous waste.
- Hand sanitizing solutions containing less than 24% alcohol by volume are not a hazardous waste. Check the alcohol content on your product to verify how it should best be managed.
The EPA has issued several memoranda with more detailed guidance on this issue: RCRA Online #14953, RCRA Online #14941, and RCRA Online #14949. Call BEP for further assistance on the disposal of excess hand sanitizer.