Full Document:
RCRA Online Number: 14941
Title: Management Options for Alcohol-based Hand Sanitizer
Document Date: 2022-02-11
To: Gibson
From: Hoskinson
Organization of Recipient: National Association of Chemical Distributors
Description: Alcohol-based hand sanitizer is usually ignitable hazardous waste when discarded (D001). VSQGs and SQGs may be able to use episodic generation provisions for discarding excess hand sanitizer. When a commercial chemical product is reclaimed, it is not a solid waste, provided the recycling is legitimate. Companies must be prepared to demonstrate that there is a known market for the material, and be able to provide appropriate documentation, per 40 CFR 261.2(f).
Regulatory Citation(s): 260.43, 261.2, 262.230
Official ORCR Policy: Yes
Associated Topic(s):
Characteristic Wastes,
Chemicals (RCRA),
Very Small Quantity Generators (VSQG) (formerly Conditionally Exempt, CESQG),
Generators,
Hazardous Waste,
Hazardous Waste Recycling,
Identification of Hazardous Waste,
Recycling,
Small Quantity Generators (SQG) |
