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Cheers to the alcohol exclusion!
EPA originally intended the alcohol exclusion to apply to only aqueous solutions containing less than 24% ethanol (i.e., alcoholic beverages and some latex paints), but codified the regulatory language as simply “alcohol.” In 1990, the agency clarified and conceded that the term “alcohol” in §261.21(a)(1) refers to any alcohol or combination of alcohols. [55 FR 22543]
“All aqueous wastes which are ignitable only because they contain alcohols (here using the term alcohol to mean any chemical containing the hydroxyl [–OH] functional group) are excluded from regulation.” [RO 11060] However, “if the alcohol is one of those alcohols specified in EPA hazardous waste codes F001-F005 and has been used for its solvent properties, the waste must be evaluated to determine if it should be classified as an F-listed spent solvent waste.” [RO 13548]
For the purposes of this exclusion only, “aqueous” means a solution containing at least 50% water by weight [RO 11060, 13548], which EPA codified into §261.21(a)(1) in 2020. [85 FR 40608]
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. 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 such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental 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.
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