Federal and state regulations require proper management, transportation, treatment and disposal of hazardous waste. The rules also establish basic management standards for hazardous waste generators. The amount of hazardous waste generated per month determines a generator's category and the applicable regulations. A facility is a small quantity generator if, in one month, it produces more than 220 pounds of hazardous waste or about 28 gallons of hand sanitizer. SQGs must register with DEQ, report their waste and pay annual fees. Learn more about generator categories in DEQ's Small Quantity Generator Handbook
The three options for disposing of waste hand sanitizer are recycling, using the episodic generation rule or managing it as hazardous waste.
Reclamation and recycling
One of Oregon’s goals is to minimize waste generation whenever possible. Recycling hand sanitizer could involve various recovery processes to reclaim the alcohol from the hand sanitizer. Alcohol-based hand sanitizer is exempt from hazardous waste regulations when it is returned to the manufacturer or to a recycler who can reclaim the alcohol. In other words, legitimately recycled hand sanitizer is not regulated as hazardous waste and does not require a RCRA storage permit. There are two important exceptions: reclaimed alcohol cannot be used as fuel or burned for energy recovery.
Businesses and organizations that store or recycle their waste hand sanitizer must provide appropriate documentation showing the waste hand sanitizer is legitimately recycled. The U.S. Environmental Protection Agency created guidance
to help ask the right questions when selecting a recycler.
Hand sanitizer disposal is possible under Oregon's episodic generation provisions. This rule allows very small quantity generators or VSQGs and small quantity generators or SQGs, to maintain their generator category while producing more hazardous waste than is typical during normal operations as long as they meet certain conditions. Generators using this rule must notify DEQ 60 days in advance using the Site Identification Form on Your DEQ Online
and send the episodic hazardous waste to a permitted hazardous waste facility within a set timeframe, among other conditions. Refer to DEQ's Episodic Generation Fact Sheet
or contact your regional Technical Assistance Specialist
Disposal as a hazardous waste
If legitimate recycling, reclamation or use of the episodic generation provision isn't possible, then expired hand sanitizer must be disposed of as hazardous waste. Managing hand sanitizer as hazardous waste means sending the sanitizer to a permitted hazardous waste disposal facility, following all RCRA regulations,
700 NE Multnomah Street, Suite 600, Portland, Oregon 97230 Phone: 503-229-5696, Toll-Free in Oregon: 800-452-4011 submitting an annual report to DEQ, paying all applicable fees and meeting other requirements.
Pharmaceutical rule considerations
Organizations must manage hand sanitizer recalled by the Federal Drug Administration in an approved manner, which may include returning the product to the manufacturer or pharmacy for proper disposal.