Full Document:
RCRA Online Number: 14955
Title: Reinterpretation of the Industrial Ethyl Alcohol Exemption to Allow for the Reclamation of Hand Sanitizer
Document Date: 2023-05-05
To: Potter
From: Hoskinson
Organization of Recipient: Dynamic Recycling, LLC.
Description: Unused industrial ethyl alcohol that is reclaimed, including unused alcohol-based hand sanitizer, qualifies for the industrial ethyl alcohol exemption in 261.6(a)(3)(i). In order to use this exemption, the reclaimer must have or obtain the proper Alcohol and Tobacco Tax and Trade Bureau (TTB) industrial ethyl alcohol permits and comply with all TTB regulations for industrial ethyl alcohol and the hand sanitizer, the reclaimed industrial ethyl alcohol, and reclamation processes must comply with the RCRA legitimacy factors in 40 CFR 260.43. Furthermore, the reclaimed ethanol may be burned for energy recovery in the United States in a unit that is not subject to RCRA permitting requirements, provided all applicable TTB regulations are complied with. (This memo only supersedes the discussion of the industrial ethyl alcohol exclusion in EPA’s November 17, 2022 memo: “RCRA Management of Excess Alcohol-based Hand Sanitizer” [RO 14953]. The rest of the November memo continues to reflect current EPA policy.)
Regulatory Citation(s): 260.43, 261.6(a)(3)(i)
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 |
