January 19, 2023

Hand Sanitizer Guidance

EPA has published guidance that explains the handling and disposal options for excess hand sanitizer produced during the pandemic. [RO 14949] This guidance reviews the composition of most hand sanitizers and the different regulatory requirements that must be complied with when managing hand sanitizers. Knowing the composition of the hand sanitizer is important to understand the options available for recycling/reclamation and disposal.

Alcohol-based hand sanitizing products are considered flammable liquids by many federal agencies. Under RCRA, any liquid with a flash point below 140°F exhibits the ignitability characteristic (§261.21) and must be managed as D001 hazardous waste when disposed of. An exception exists for aqueous solutions containing less than 24% alcohol by volume, but most alcohol-based hand sanitizers contain above 70% alcohol by volume. Thus, most hand sanitizers will carry the D001 waste code when disposed of.

When disposing of D001 hand sanitizer, containers used to manage the waste must comply with all applicable RCRA container standards in §262.15, §262.16, and §262.17. In addition, hazardous wastes must be treated to meet RCRA land disposal restrictions before disposal. Also, the Clean Water Act generally prohibits discharge of D001 ignitable hazardous wastes down the drain.

Because RCRA generator requirements vary depending upon how much hazardous waste is generated at a site, EPA emphasizes the importance of anticipating the exact quantity of hand sanitizer that will be disposed of. Depending on how much sanitizer will be disposed of, a generator may move to a higher generator category from very small quantity generator to small quantity generator to large quantity generator during the month(s) it is generated. Each generator category has its own specific RCRA requirements that must be met, and higher generator categories have more-stringent requirements. EPA has a summary of the generator requirements on its website.

If the hand sanitizer has a “drug facts” label, it is considered pharmaceutical waste. Healthcare facilities (including retailers) generating hazardous waste pharmaceuticals must comply with Part 266, Subpart P. EPA provides answers to frequently asked questions on Subpart P on its website. On a side note, hand sanitizers recalled by the Food and Drug Administration (FDA) must comply with the FDA recall strategy.

If the hand sanitizer is sent for reclamation to recover the alcohol, it would be considered an unused commercial chemical product being reclaimed. Thus, under §261.2, the hand sanitizer would not be a solid waste unless the reclaimed alcohol will be burned for energy recovery, used to make fuel, or used in a manner constituting disposal. Provided this is not the case, RCRA does not apply to management of such hand sanitizer that will be reclaimed.

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Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.