Full Document:
RCRA Online Number: 14949
Title: Disposal of Hand Sanitizer Letter to USDA
Document Date: 2021-06-24
To: Harriz
From: Kirkland
Organization of Recipient: United States Department of Agriculture
Description: Alcohol-based hand sanitizers being discarded are classified as ignitable (D001). The Clean Water Act regulations prohibit the discharge into the sewer system of what would otherwise be classified as a RCRA D001 ignitable hazardous waste (see 40 CFR 403.5(b)). Hand sanitizer going to reclamation would not be regulated as a hazardous waste unless the reclaimed alcohol is burned for energy recovery or used to make a fuel. If not recycled, or if blended to make a fuel, the alcohol-based hand sanitizers require full cradle-to-grave hazardous waste management, including (but not limited to) notification on the Site Identification Form (8700-12), hazardous waste labeling, manifesting, and hazardous waste disposal.
Regulatory Citation(s): 261.21(a)(1), 266.500, 262
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) |
