/ IN THIS BLOG
01 / What is hazardous waste characterization?
The Environmental Protection Agency (EPA) defines hazardous waste using two primary classifications: listed wastes (over 500 substances explicitly identified as hazardous) and characteristic wastes (materials that exhibit specific hazardous properties).
Ignitability—it catches fire under certain conditions. E.g., certain paints, degreasers, or solvents
Corrosiveness—it’s a significant acid or base. E.g., rust removers, certain cleaning fluids, or battery acid
Reactivity—it tends to explode or release toxic fumes if heated, mixed with water, or pressurized. E.g., certain cyanides or sulfide-bearing wastes
Toxicity—it’s harmful or fatal if ingested or absorbed, or it leaches into soil or ground water when disposed of on land. E.g., wastes containing cadmium, lead, or mercury.
02 / Is hand sanitizer a characteristic waste?
Yes. Hand sanitizer is classified as a characteristic hazardous waste due to its high alcohol content, making it ignitable.
Most hand sanitizers contain ethyl or isopropyl alcohol in concentrations of 60-95%, which meets the ignitability criteria set by the EPA. Because of this, businesses, schools, hospitals, and other organizations must handle expired or unused hand sanitizer according to hazardous waste regulations.
03 / What are the special storage requirements for hand sanitizer?
Since hand sanitizer falls under Class 3 Flammable Liquids, specific storage guidelines apply:
Office buildings: Storing hand sanitizer in office spaces is prohibited due to fire hazards.
Bulk storage: If storing 25 gallons or more, it must be placed in a flammable-liquid storage cabinet, even if it’s spread across multiple small containers.
Workplace compliance: The Occupational Safety and Health Administration (OSHA) outlines flammable liquid handling requirements to ensure worker safety.
04 / What is the shelf-life of hand sanitizer?
Hand sanitizer has a limited shelf-life due to its high alcohol content, which evaporates over time. While water boils at 212°F, alcohol does so at around 180°F, meaning the product gradually loses its antibacterial effectiveness.
During the COVID-19 pandemic, businesses stockpiled vast amounts of hand sanitizer. Now, many are left with expired products that require proper disposal.
Household amounts: Small quantities can go into the municipal waste stream.
Bulk quantities: Large amounts must follow hazardous waste disposal regulations.
Prohibited disposal: Never pour hand sanitizer down the drain—it’s both illegal and hazardous.
05 / How do you legally and safely dispose of expired hand-sanitizer?
Expired hand sanitizer in industrial, commercial, or bulk quantities requires hazardous waste disposal. Since it meets the ignitability characteristic under EPA regulations, improper disposal can lead to severe legal and financial consequences.
For example, disposing of 50 gallons of alcohol-based sanitizer down a drain could cause a combustible vapor buildup, potentially leading to sewer explosions and hefty regulatory fines.
Businesses must follow Resource Conservation and Recovery Act (RCRA) protocols, which include:
Proper labeling and manifesting
Certified hazardous waste transport
EPA-compliant disposal procedures
06 / What alternatives are there to hazardous waste disposal for expired hand sanitizer?
Disposal of industrial, commercial, or bulk quantities of out-of-date hand sanitizer generally requires hazardous waste management protocols, which include RCRA registration, labeling, manifesting, and reporting. However there are other options sanctioned by the EPA. Among them:
Fuel-blending. Purposely mixing different materials to produce a desired chemical reaction is an accepted treatment for hazardous waste. This might be done to denature the alcohol in out-of-date hand sanitizer, which would make it safer to store, transport, and dispose of. Fuel-blending can also be used to recover the alcohol in expired hand sanitizer, to be sold or reused.
Incidental reduction. In this process materials are combined to create a mixture that’s safer to handle than its constituents were individually. However, the combined waste must still meet the hazardous waste management requirements for its individual constituents—even if chemical testing demonstrates that one or more hazmat characteristics have been eliminated.
It’s important to remember that fuel-blending and incidental reduction rules vary by state and localities, and they aren’t specifically defined in EPA rules. Fuel blending generally requires a hazardous waste installation and operation permit for storage and treatment. It’s crucial to get expert advice.
07 / Can you recycle expired hand sanitizer?
Yes, expired hand sanitizer can be recycled, often at a lower cost than hazardous waste disposal. However, the process must comply with:
EPA regulations on hazardous waste recycling.
Department of Transportation (DOT) shipping and labeling requirements.
If businesses opt for recycling, they should work with a certified hazardous waste disposal company to ensure compliance.
08 / What’s the best advice about what to do with expired hand sanitizer?
Due to the pandemic-driven surplus, expired hand sanitizer disposal has become a growing concern for businesses and organizations. Since it’s classified as hazardous waste, disposal must comply with EPA, DOT, and OSHA regulations.
Moreover, each state has different hazardous waste management rules, making compliance even more complex. Mistakes can lead to legal action, fines, and reputational damage.
Need help with hand sanitizer disposal? Contact our hazardous waste specialists today!
Robert Losurdo
President, COO
