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Hand Sanitizer Management

Businesses, schools and other organizations across Oregon acquired large amounts of hand sanitizer during the COVID-19 pandemic. Much of that hand sanitizer is now expiring. Hand sanitizer generally has a high alcohol content making it an ignitable hazardous waste when discarded, according to the Resource Conservation and Recovery Act, or RCRA. When legitimately reclaimed or recycled, hand sanitizer is not regulated under RCRA as hazardous waste. The Oregon Department of Environmental Quality outlines these options for adequately managing expired hand sanitizer.

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 garbage. Regulated 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 household generators. Some facilities can also accept small quantities of hazardous waste from very small quantity generators. Contact them first.

Alcohol-based hand sanitizer typically contains at least 60 percent alcohol by volume. Because of this, waste hand sanitizer is a regulated hazardous waste that carries the D001 waste code for ignitability – its ability to catch fire. 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.


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. 

Episodic generation 
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​ with questions. 

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 
Hand sanitizer with a drug facts label, such as the one shown to the right, is a pharmaceutical waste when discarded. Healthcare facilities, including retailers or reverse distributors, must follow 40 Code of Federal Regulations Part 266 Subpart P regulations to manage hazardous waste pharmaceuticals. 

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.


​​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.