/ IN THIS BLOG
01 / What is hazardous waste characterization?
There are more than 500 substances “listed” as hazardous by the EPA. But even if a material isn’t on that list, the agency might nonetheless consider it hazardous according to four categorical “characteristics.” And so you’ll often hear the term “characteristic wastes.” These characteristics are:
- 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?
Absolutely, as it’s characteristically ignitable—and in a big way. The active ingredient in hand sanitizer is typically ethyl or isopropyl alcohol in concentrations of 60-to-95 percent. In fact, there are special storage requirements stipulated by OSHA for hand sanitizer.
03 / What are the special storage requirements for hand sanitizer?
Believe it or not, it’s illegal to store hand sanitizer in office buildings at all. Alcohol concentrations of 60-to-95 percent mean that hand sanitizers are classified as Class 3 Flammable Liquids. Apart from office buildings, accumulations of 25 gallons or more must be kept in a flammable-liquid storage cabinet, even if the hand sanitizer is dispersed across many small containers.
04 / What is the shelf-life of hand sanitizer?
This is a problem that looms large on the horizon. Hand sanitizer is mostly alcohol, which evaporates easily—while water boils at 2120 F, alcohol does so at about 1800 F. This means that hand sanitizers rapidly lose their antibacterial efficacy over time.
COVID-19 has encouraged many businesses, schools, and organizations to stock up on large amounts of hand sanitizer. And supply-chain challenges have caused many business and department managers to hedge their bets against running short by buying more than they need—and probably more than they’ll ever use.
And therein lies a huge disposal challenge for businesses, schools, hospitals, and other enterprises. Although the EPA allows you to throw away “household” amounts of hand sanitizer into the municipal waste stream, industrial, commercial, or bulk quantities require hazardous waste disposal.
Note: It’s prohibited to pour any amount of expired hand sanitizer down the drain. We advise taking moderate quantities of hand sanitizer to a local household hazardous waste collection facility.
05 / How do you legally and safely dispose of expired hand-sanitizer?
Industrial, commercial, or bulk quantities of expired hand sanitizer require hazardous waste disposal because it’s mostly composed of alcohol, which meets the ignitability characteristic of the the EPA. To illustrate this more plainly, consider for a moment:
If you were to pour 50 or so gallons of alcohol-based sanitizer down the drain, once it vaporizes, it would be combustive enough to knock the sewer manhole covers off the street. Apart from what that would do to the brand image of your enterprise, such an event would draw the legal ire of federal, state, and local authorities. And seven-digit fines are the norm.
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, and it can be more economical than hazardous waste disposal. This is because recycling expired hand sanitizer doesn’t require registering it as a hazardous waste. Still, there are EPA and DOT regulations that must be observed. And as in all things regarding the EPA and the DOT, it’s wise to get expert advice.
08 / What’s the best advice about what to do with expired hand sanitizer?
Disposal of industrial, commercial, or bulk quantities of expired hand sanitizer requires hazardous waste management per OSHA, the DOT, and the EPA. Due to COVID-19 and chronic supply-chain issues, many managers have overbought. As a consequence, the country is awash in it, and the amount of expired hand sanitizer requiring hazardous waste disposal is on track to grow tremendously.
Complicating things, states differ about what they deem a hazardous waste and how it should be managed. Their rules also diverge about recycling. Misinterpretations and/or errors about such local rules can be time-consuming, expensive, and litigious.
Expert advice is crucial. You can get some here.
And thank you for reading our blog!
Robert Losurdo
President, COO
