Full Document:
RCRA Online Number: 14953
Title: RCRA Management of Excess Alcohol-based Hand Sanitizer
Document Date: 2022-11-17
To: Regional RCRA Division Directors
From: Hoskinson
Organization of Recipient: EPA
Description: This memo is intended to clarify and provide additional details about how RCRA hazardous waste regulations and exemptions apply to five different scenarios for recycling excess alcohol-based hand sanitizer. The memo also provides a discussion of the safety considerations and RCRA regulations that apply to 1) hand sanitizer that is not a solid or hazardous waste, and 2) generators managing hand sanitizer that is a solid and hazardous waste. (PARTIALLY SUPERSEDED: this policy document, RCRA Online memorandum #14953, has been partially superseded. The elements of the policy document that are not superseded remain wholly in effect. In scenario #5 on page 5 of this November 17, 2022, memorandum, EPA discusses the exemption for reclaimed industrial ethyl alcohol, stating that the industrial ethyl alcohol must be spent in order to qualify for the recycling exemption. EPA has reconsidered our position in the November 17, 2022, memorandum and we have concluded that unused industrial ethyl alcohol, including unused alcohol-based hand sanitizer, also qualifies for this exemption. See RCRA Online #14955, May 5, 2023, for EPA’s updated interpretation of the industrial ethyl alcohol exemption.)
Superseded: Partially Superseded
Regulatory Citation(s): 260.10, 260.43, 266.500, 261.2, 261.3, 261.6, 262.230, 266.20, 266.100
Official ORCR Policy: Yes
Associated Topic(s):
Burning,
Compliance,
Very Small Quantity Generators (VSQG) (formerly Conditionally Exempt, CESQG),
Disposal,
Generators,
Hazardous Waste,
Hazardous Waste Recycling,
Identification of Hazardous Waste,
Large Quantity Generators (LQG),
Recycling,
Small Quantity Generators (SQG),
Solid Waste |
