How to Dispose of and Recycle Alcohol-Based Hand Sanitizer
Manufacturers produced large quantities of hand sanitizer during the Coronavirus disease 2019 (COVID-19) pandemic. Many organizations now have excess hand sanitizer that is reaching or has exceeded expiration dates. Alcohol-based hand sanitizer typically contains at least 60 percent alcohol by volume and is an ignitable hazardous waste when discarded. Hand sanitizers manufactured before or on December 31, 2021 and produced under the U.S. Food and Drug Administration (FDA) temporary guidance, could no longer be sold or distributed by manufacturers after March 31, 2022. Due to these circumstances, households and many businesses and institutions are looking for the proper way to dispose of or recycle excess hand sanitizer.
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General Information
According to the FDA, only ethanol (also known as ethyl alcohol) and isopropyl alcohol (also known as 2-propanol) are acceptable alcohols in hand sanitizer. The FDA requires alcohol-based hand sanitizers to be labeled as flammable. Their ignitable nature makes them hazardous wastes regulated under the Resource Conservation and Recovery Act (RCRA) when disposed of.
Information for Households
Alcohol-based hand sanitizer is ignitable and should be managed and disposed of safely. Alcohol-based hand sanitizer when disposed of at a residence or household would be considered household hazardous waste. Although household hazardous waste is exempt from regulation under federal hazardous waste regulations, hand sanitizer should never be disposed of down the drain (even in a house). Ignitable materials, such as alcohol-based hand sanitizer, can be very dangerous when poured down the drain. The liquid and vapors in water pipes and sewer systems can cause fires and explosions.
An empty container of hand sanitizer may be placed in a curbside recycling bin. However, if hand sanitizer remains in the container, EPA recommends that households not put the hand sanitizer in the regular household trash. Instead, EPA recommends that household hand sanitizer waste be brought to a household hazardous waste drop-off location or event for proper management. Household hazardous waste locations and events are frequently run by local government agencies. To find local household hazardous waste drop-off locations near you, enter your ZIP code in Earth911’s household hazardous waste search.
For consumer information about safely using hand sanitizer, visit FDA’s website.
Information for Businesses and Institutions
Excess alcohol-based hand sanitizer, when it cannot be used or reused for its intended purpose, is considered a RCRA ignitable hazardous waste. EPA encourages recycling of excess hand sanitizer whenever possible. Due to the ignitability risk with excess alcohol-based hand sanitizer, care must be taken to manage it safely and recycling must be done in compliance with the legitimate recycling regulations in 40 CFR Section 260.43.
For businesses and institutions, such as office buildings and schools, EPA provides a summary below of recycling scenarios for managing excess alcohol-based hand sanitizer. Additionally, EPA answers some frequent questions about hand sanitizer disposal and management under RCRA.
Hand Sanitizer Memoranda
EPA issued four memoranda about hand sanitizer, which provide more detailed information:
- Disposal of Hand Sanitizer Letter to U.S. Department of Agriculture, From Kirkland to Harriz; January 24, 2021; RCRA Online #14949.
- Management Options for Alcohol-based Hand Sanitizer, From Hoskinson to Gibson; February 11, 2022; RCRA Online #14941.
- RCRA Management of Excess Alcohol-based Hand Sanitizer, From Hoskinson to Regional RCRA Division Directors; November 17, 2022; RCRA Online #14953 (Partially Superseded).
- Reinterpretation of the Industrial Ethyl Alcohol Exemption to Allow for the Reclamation of Hand Sanitizer; May 5, 2023, RCRA Online #14955.
Summary of RCRA Recycling Scenarios
Several RCRA hazardous waste regulations and exemptions apply to different scenarios for recycling excess alcohol-based sanitizer. The table below provides a broad summary of five potential recycling scenarios. Additional information can be found in the memorandum: RCRA Management of Excess Alcohol-based Hand Sanitizer.
| If the hand sanitizer is... | Then... | |
|---|---|---|
| 1. Burned for energy recovery | --- | The hand sanitizer is a solid and hazardous waste subject to RCRA Subtitle C regulation (Part 266 Subpart H) |
|
2. Used in a manner constituting disposal (e.g., in a product that is used in or on the land) |
--- | The hand sanitizer is a solid and hazardous waste subject to RCRA Subtitle C regulation (Part 266 Subpart C) |
| 3. Reclaimed at a facility with a permit from the Alcohol and Tobacco Tax and Trade Bureau (TTB) to produce ethanol, and | The reclaimed ethanol is legitimately used in a product (including in a fuel or as a fuel additive), |
The hand sanitizer and reclaimed ethanol are solid and hazardous waste, but are exempt from most RCRA Subtitle C regulation, provided the reclamation is legitimate per 40 CFR Section 260.43 (40 CFR 261.6(a)(3)(i)) |
| 4. Reclaimed at a facility without a TTB permit to produce alcohol, and | The alcohol is burned for energy recovery, |
The hand sanitizer and reclaimed alcohol are solid and hazardous waste subject to RCRA Subtitle C regulation |
| The alcohol is used in a manner constituting disposal, |
The hand sanitizer and reclaimed alcohol are solid and hazardous waste subject to RCRA Subtitle C regulation |
|
| 5. Reclaimed at a facility without a TTB permit to produce alcohol, and |
The alcohol is used in a product that is not burned for energy recovery and not used in a manner constituting disposal, |
The hand sanitizer and reclaimed alcohol are not a solid and hazardous waste and are exempt from RCRA Subtitle C regulation, provided the recycling is legitimate per 40 CFR Section 260.43 |
Frequent Questions for Businesses and Institutions
In addition to the information found in the EPA hand sanitizer memoranda and table listed above, below is a set of frequent questions to help businesses and institutions safely manage, dispose of, and recycle excess hand sanitizer in accordance with the regulations.
- What is the best way to recycle excess alcohol-based hand sanitizer that cannot be sold?
- How should excess hand sanitizer be stored?
- Can excess alcohol-based hand sanitizer be disposed of down the drain or in the garbage?
- Can excess, unsaleable alcohol-based hand sanitizer from businesses or institutions be brought to household hazardous waste collection sites for disposal?
- How should a business or other institution with excess, unsaleable hand sanitizer manage the hand sanitizer going for disposal or regulated recycling?
- Can businesses or other institutions (other than healthcare facilities or reverse distributors operating under 40 CFR Part 266 Subpart P) use the episodic generation provision to get rid of excess, unsaleable hand sanitizer that is a solid and hazardous waste?
- How should a healthcare facility or reverse distributor operating under Subpart P manage its excess, unsaleable hand sanitizer?
- How should excess, unsaleable hand sanitizer be transported?
- Are hand sanitizers regulated by EPA as disinfectants under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)?
1. What is the best way to recycle excess alcohol-based hand sanitizer that cannot be sold?
EPA encourages recycling of excess, unsaleable hand sanitizer whenever possible, provided the recycling complies with the legitimacy criteria in 40 CFR Section 260.43. Per the RCRA regulations at 40 CFR Section 261.2(c)(3), excess alcohol-based hand sanitizer is a commercial chemical product and is not a solid waste when it is reclaimed, provided the reclaimed product is not
(1) used as a fuel or burned for energy recovery, or
(2) used in a manner constituting disposal.
In addition, industrial ethyl alcohol, including hand sanitizer, that is reclaimed to recover ethanol may qualify for the industrial ethyl alcohol exemption under 40 CFR Section 261.6(a)(3)(i). In order to use this exemption, the reclaimer must have or obtain the proper Alcohol and Tobacco Tax and Trade Bureau (TTB) industrial ethyl alcohol permits and comply with all TTB regulations for industrial ethyl alcohol. Further, the hand sanitizer, the reclaimed industrial ethyl alcohol, and reclamation processes must comply with the RCRA legitimacy factors in 40 CFR Section 260.43. In this case, the reclaimed ethanol is exempt from most RCRA regulation when used as a legitimate product, including as a fuel or as a fuel additive.
For more information on the TTB regulations and requirements, visit their website.
As a result, three recycling scenarios are likely to be used more often than others. In all cases, the legitimacy criteria in 40 CFR Section 260.43 apply.
- The hand sanitizer is reclaimed at an industrial ethyl alcohol reclaimer with an appropriate Alcohol and Tobacco Tax and Trade Bureau permit;
- The alcohol is legitimately recovered from the hand sanitizer and used as alcohol in another product (e.g., lab chemicals, cleaning agents, cosmetics, etc.); or
- Due to the alcohol content in hand sanitizer, businesses and institutions may also consider contacting RCRA-permitted cement kilns. In this scenario, the solid and hazardous waste hand sanitizer can be recycled through burning for energy recovery under the appropriate regulations. The excess alcohol-based hand sanitizer must be managed as a hazardous waste at the generator site and manifested to the RCRA permitted cement kiln. Due to the energy recovery potential of the excess hand sanitizer, cement kilns may want this hazardous waste for fuel blending.
2. How should excess hand sanitizer be stored?
The National Fire Protection Association (NFPA) has developed dozens of codes and standards related to fire hazards. NFPA 30 is entitled Flammable and Combustible Liquids Code and applies to the storage of hand sanitizer, whether it is a product or a waste. Enforceable under the Occupational Safety and Health Administration (OSHA) regulations, as well as many state and local regulations, NFPA 30 provides safeguards to reduce the hazards associated with the storage, handling, and use of flammable and combustible liquids.
Hand sanitizer that is not a solid waste because it is destined for legitimate recycling per 40 CFR Section 260.43 may be stored as a commercial chemical product without needing a RCRA storage permit or otherwise being subject to RCRA hazardous waste requirements. Companies that store such hand sanitizers prior to recycling must be prepared to demonstrate that there is a known market or disposition for the material. They should also be able to provide appropriate documentation to demonstrate that the material is not a waste, per 40 CFR Section 261.2(f). For example, this documentation could be a contract showing that a second person uses the material as an ingredient in a production process. When excess hand sanitizer is mismanaged, including at warehouses where it is stockpiled, significant fires can occur. EPA notes that in addition to a known market, any hand sanitizer awaiting recycling must be managed as a valuable commodity, which includes addressing the potential risks of fires and explosions.
3. Can excess alcohol-based hand sanitizer be disposed of down the drain or in the garbage?
No. The Clean Water Act regulations prohibit the discharge of what would otherwise be classified as a RCRA D001 ignitable hazardous waste down the drain (refer to 40 CFR Section 403.5(b)). In addition, hand sanitizer is considered a hazardous waste pharmaceutical under 40 CFR Subpart P. All healthcare facilities (including very small quantity generators (VSQGs)) and all reverse distributors are prohibited from disposing any hazardous waste pharmaceutical down the drain (refer to 40 CFR Section 266.505).
RCRA hazardous wastes may not be disposed as municipal solid waste in the regular trash, unless the generator is a VSQG (refer to the Disposal of Hand Sanitizer Letter to U.S. Department of Agriculture memorandum for additional details). Note that many states have regulations that are more stringent than the federal regulations and do not allow VSQGs to dispose of their hazardous waste in municipal landfills or combustors. Consult your state waste program for additional details.
4. Can excess, unsaleable alcohol-based hand sanitizer from businesses or institutions be brought to household hazardous waste collection sites for disposal?
Generally, no. Household hazardous waste collection sites accept hazardous waste from households. However, some household hazardous waste collection programs may also have occasional small business days where VSQGs are allowed to bring hazardous waste for a fee. For VSQGs, it is best to contact these programs individually before attempting to drop off hazardous waste. They are often run by the county or municipality, so contacting your local waste authority is a good place to start.
5. How should a business or other institution with excess, unsaleable hand sanitizer manage the hand sanitizer going for disposal or regulated recycling?
Hand sanitizer is considered a solid and hazardous waste when it is going for disposal and in many cases when it is going for recycling. Refer to the table above and the memorandum, RCRA Management of Excess Alcohol-based Hand Sanitizer, for additional details about whether RCRA regulations apply to various recycling scenarios.
Managing excess alcohol-based hand sanitizers that are solid and hazardous waste requires full cradle-to-grave management under RCRA, including (but not limited to) hazardous waste notification, hazardous waste labeling and accumulation standards, manifesting, hazardous waste reporting, and hazardous waste treatment and disposal.
Refer to the memorandum, Disposal of Hand Sanitizer Letter to USDA, for additional details about how the RCRA regulations apply to different types of generators. This includes generators that are operating under 40 CFR Part 262 and healthcare facilities operating under 40 CFR Part 266 Subpart P.
6. Can businesses and other institutions (other than healthcare facilities or reverse distributors operating under 40 CFR Part 266 Subpart P) use the episodic generation provision to get rid of excess, unsaleable hand sanitizer?
If hand sanitizer must be managed as hazardous waste, generators that are VSQGs or small quantity generators (SQGs) may want to explore the possibility of disposing of the excess hand sanitizer under the episodic generator provisions of 40 CFR Part 262 Subpart L. These provisions allow a VSQG or SQG to maintain their generator category while generating an increased amount of hazardous waste that does not normally occur during their operations, as long as certain conditions are met.
For example, the generator needs to notify using the Site ID form, 8700-12, and send the episodic hazardous waste to a designated facility (usually a RCRA-permitted treatment, storage or disposal facility (TSDF) or recycler) within 60 days, among other conditions. VSQGs and SQGs are limited in the number of times they can use the episodic generator provisions per year, so it might not be the best strategy in all cases. VSQGs and SQGs should check with their authorized states to determine if the episodic generation provisions are available.
7. How should a healthcare facility or reverse distributor operating under Subpart P manage its excess, unsaleable hand sanitizer?
If the excess, unsaleable hand sanitizer is a waste, a healthcare facility or reverse distributor operating under 40 CFR Part 266 Subpart P must manage the waste hand sanitizer as a hazardous waste pharmaceutical. They may not use the episodic generator standards of 40 CFR Part 262 Subpart L, with respect to their hazardous waste pharmaceuticals.
Under Part 266 Subpart P, all healthcare facilities are regulated the same, regardless of the amount of hazardous waste pharmaceuticals they generate. The same goes for all reverse distributors. This makes the episodic generation provisions unnecessary. For additional detail about the intersection of the episodic generation provisions in Part 262 Subpart L and the standards for managing hazardous waste pharmaceuticals in Part 266 Subpart P, go to page 5935 of the Hazardous Waste Pharmaceuticals Final Rule (pdf), and the Episodic Generation section of the Frequent Questions about the Pharmaceuticals Rule webpage.
8. How should excess, unsaleable hand sanitizer be transported when it is sent for legitimate reclamation and is not considered a solid or hazardous waste?
A commercial chemical product being reclaimed does not need to be manifested as a hazardous waste when being returned to the manufacturer (or third party) for reclamation. If it is a hazardous material as defined by the Department of Transportation (DOT) it would still need to follow all applicable DOT regulations. You can find additional guidance at the Hazardous Materials Information Center.
9. Are hand sanitizers regulated by EPA as disinfectants under FIFRA?
No. Hand sanitizer is not regulated as a disinfectant under FIFRA (access a frequently asked question about this). Since it is applied to the body, hand sanitizer is regulated by FDA as an over-the-counter (OTC) drug. However, surface disinfectants, such as alcohol-based wipes and sprays are regulated under FIFRA. Regardless of how they are regulated as products, when discarded, both surface disinfectants and OTC drugs (such as hand sanitizer) may be regulated by RCRA if they meet the definition of hazardous waste in 40 CFR Section 260.10.
Related Resources
- FIFRA FAQs
- RCRA Websites
- EPA Coronavirus Websites
- TTB Regulations