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Hand Sanitizer Management

Hand sanitizer is usually flammable due to the high alcohol content. This makes it an ignitable hazardous waste when discarded under the federal Resource Conservation and Recovery Act, or RCRA. There are options for proper management of expired hand sanitizer other than disposal in a hazardous waste landfill. If it is legitimately reclaimed or recycled, then it is not a hazardous waste and, therefore, not subject to the requirements of RCRA. Businesses and organizations that wish to reclaim or recycle their expired hand sanitizer must demonstrate a known market for the material and provide appropriate documentation, per federal regulation.

The information on this page is also available as a fact sheet

Prohibitions

prohibitedDo not put expired hand sanitizer down the drain. Clean Water Act regulations prohibit the discharge of what would otherwise be an ignitable hazardous waste.

prohibited

Do not put expired hand sanitizer in the trash bin or garbage pail. RCRA hazardous wastes may not go into the regular trash unless the generator is considered a household or very small quantity generator.

prohibited

Do not take expired hand sanitizer to a household hazardous waste collection site. Household hazardous waste collection sites can take limited amounts of hazardous waste from households and very small quantity generators. These facilities are not set up to accept large quantities of hazardous waste, nor are they legally allowed to do so.

Alcohol-based hand sanitizer typically contains at least 60 percent alcohol by volume. Because of the alcohol concentration, waste hand sanitizer carries the D001 federal waste code, which means it is ignitable and, therefore, a RCRA hazardous waste. Expired hand sanitizer only becomes a waste when it cannot be used, reused, reclaimed, or recycled.

The U.S. Environmental Protection Agency has issued two memos on this topic, which are available on the web:

McCoy and Associates has provided a summary of EPA's guidance for Managing Alcohol-Based Hand Sanitizer Produced Under Temporary FDA Policies.


One of Oregon's goals is to minimize waste generation when possible. When a material that would otherwise be hazardous waste can be legitimately reused, reclaimed, or recycled, that material is often exempt from hazardous waste regulations.

Hazardous waste regulations provide an exemption for any amount of alcohol-based hand sanitizer returned to the manufacturer or to a recycler who can reclaim the material. Recycling hand sanitizer could involve various salvaging processes to reclaim the alcohol from the hand sanitizer. If a hand sanitizer manufacturer or a third party could extract ethanol from the hand sanitizer and the ethanol could be used as an ingredient to make a new product, then the hand sanitizer would not be a hazardous waste. There are two important exceptions: the reclaimed alcohol cannot be used as a fuel or burned for energy recovery.

Expired hand sanitizer that is not hazardous waste because it will go for legitimate recycling may be stored without needing a storage permit or otherwise being subject to hazardous waste requirements. Businesses and organizations that store such hand sanitizers prior to recycling must demonstrate a known market or disposition for the material and provide appropriate documentation, such as contracts showing that a second person uses the material as an ingredient in a production process. This means that it is your responsibility to ensure that your expired hand sanitizer is legitimately recycled. EPA has provided guidance to help you ask the right questions when selecting a recycler. 

Certain hand sanitizers that have been recalled by the Federal Drug Administration would have to be managed following the FDA-approved recall strategy, which might include returning the product to the manufacturer or pharmacy for proper disposal.​

The following options require adherence to RCRA hazardous waste regulations. RCRA regulations establish basic management standards for entities that produce hazardous waste, called hazardous waste generators.  The amount of hazardous waste generated per month determines a generator's category and the applicable regulations that apply. RCRA regulations require the proper management, transportation, treatment, and disposal of hazardous wastes.

Episodic generation

Hand sanitizer disposal is possible under the episodic generator provisions per Oregon Administrative Rule 340-102-0230. These provisions allow a very small quantity generator or small quantity generator to maintain their generator category while generating an increased amount of hazardous waste that does not normally occur during operations, if certain conditions are met. For example, the generator would need to notify DEQ using the Site Identification Form in the electronic reporting system Your DEQ Online and send the episodic hazardous waste to a designated facility within 60 days -- among other conditions. Refer to our Episodic Generation Fact Sheet or reach out to your regional Technical Assistance Specialist using the information below.

Disposal as a hazardous waste

If it is not possible to legitimately recycle or reclaim expired hand sanitizer or use the episodic generation provision, you must dispose of it as hazardous waste. This means sending the waste to a permitted hazardous waste landfill.

Pharmaceutical rule considerations

If the hand sanitizer has a drug facts label, it is a pharmaceutical when discarded. Healthcare facilities, including retailers or reverse distributors, must follow a different set of regulations in 40 Code of Federal Regulations Part 266 Subpart P to manage hazardous waste pharmaceuticals.​

​Hazardous waste technical assistance available from DEQ is non-regulatory in nature and is available free in the form of on-site visits, training workshops and telephone consultations. This technical assistance is available only for business and municipalities that handle and report regulated hazardous waste. Hazardous Waste technical assistance does not cover regulated infectious waste or household hazardous waste.

To contact DEQ to schedule an on-site visit or receive telephone assistance, please contact the DEQ regional office nearest you:

Northwest Region
Clackamas, Clatsop, Columbia, Multnomah, Tillamook, and Washington counties
Western Region
Benton, Coos, Curry, Douglas, Jackson, Josephine, Lane, Lincoln, Linn, Marion, Polk and Yamhill counties
Eastern Region
Baker, Crook, Deschutes, Gilliam, Grant, Harney, Hood River, Jefferson, Klamath, Lake, Malheur, Morrow, Sherman, Umatilla, Union, Wallowa, Wasco, and Wheeler counties

For assistance with residential issues and handling household toxic substances and waste, please visit our Household Hazardous Waste page or contact:  

  • Pete Pasterz, Program Coordinator, Household Hazardous Waste Program

For assistance with infectious waste, please visit our Infectious Waste page or contact:  

  • Steve Siegel, Senior Policy Analyst, Materials Management Program​

Contacts

For policy questions: 

Ellie Brown
Hazardous Waste Policy Analyst
503-229-6742

For technical questions or assistance, see the "Have questions or need assistance" section above.