Early in the COVID-19 pandemic, many of our nation’s distilleries and ethanol plants began producing ethanol-based hand sanitizer to meet global demands. Many of these sanitizers are 60% or greater ethanol content (greater than 24% alcohol), have a flashpoint below 140^◦ F, and must be coded as D001 hazardous waste if disposed. 

Some of these hand sanitizers are going unused due to their odor, over-procurement, and other issues. This excess hand sanitizer has created some concern from various regulatory entities, including the U.S. Department of Agriculture (USDA) and Environmental Protection Agency (EPA), on compliance issues regarding the safe handling and disposal of hand sanitizer.

In response, EPA issued guidance in a June 24, 2021, letter to the USDA addressing considerations and requirements for appropriate hand sanitizer disposal. According to the memo, “…when recycled, hand sanitizer is exempt from hazardous waste regulations and does not have to ship on a Uniform Hazardous Waste Manifest. If not recycled, the disposal of alcohol-based hand sanitizers requires full cradle-to-grave management, including (but not limited to) hazardous waste notification, hazardous waste labeling, manifesting, and waste reporting to the state or the federal government.”

These requirements provide an idea of just how robust the penalties for improper (i.e., “down-the-drain”) disposal would likely be. Facilities may want to try returning the sanitizer to the manufacturer as an easy first step or continue using it for its “intended purpose,” if possible. Alternatively, KTL has the in-house expertise to identify options for hazardous waste management and/or reuse of resources that can help facilities manage excess hand sanitizer or excess hazardous waste. We are currently working to identify alternative end-use destinations for hand sanitizer, including reverse distribution or other entities that may have a use for such products.