COVID-19 has encouraged many businesses and organizations to stock up on large amounts of hand sanitizer. And supply-chain challenges have caused many business and department managers to hedge their bets against running short by buying more than they need—and probably more than they’ll ever use. This raises the question: Does hand sanitizer expire?
What is hand sanitizer?
The active ingredient in hand-sanitizing liquids and gels is typically ethyl or isopropyl alcohol in concentrations of 60-to-95 percent. The remaining 5-to-40 percent are ingredients such as aloe vera, glycerin, propylene glycol, tocopherol acetate, and isopropyl myristate.
How should you store hand sanitizer?
Hand sanitizers have special storage requirements. Alcohol concentrations of 60-to-95 percent mean hand-sanitizing liquids are classified as Class 3 Flammable Liquids. OSHA regulations stipulate that hand sanitizers cannot be stored in office buildings at all. Elsewhere, accumulations of 25 gallons or more must be maintained in a flammable-liquid storage cabinet, even if the sanitizer is distributed across many small containers.
Why and how does hand sanitizer expire?
Alcohol evaporates more easily than water, at about 180°F compared to water at 212°F. This means that hand sanitizers lose their potency over time and become commensurately ineffective at killing bacteria.
What to do with expired hand sanitizer?
Commercial or industrial amounts of expired hand sanitizer require hazardous waste disposal because alcohol—its main constituent—meets the ignitability characteristic as defined by the DOT and the EPA. To put that in more graphic terms, consider:
If you pour 50 or so gallons of alcohol-based sanitizer down the drain, it would be combustive enough to blow the manhole covers off the municipal sewer system once it vaporizes. Such an event would not amuse federal, state, or local authorities. And seven-digit fines are standard.
Are there alternatives to hazardous waste disposal for expired hand sanitizer?
Disposal of industrial or commercial quantities of expired hand sanitizer generally requires hazardous waste management protocols, which include RCRA registration, labeling, manifesting, and reporting. However, there are other options sanctioned by the EPA. Among them:
- Fuel-blending. Purposely mixing different waste streams to cause the desired chemical reaction is an approved treatment method for hazardous waste. This might be done to neutralize the alcohol in expired hand sanitizer, which would make it safer to store, transport, and dispose of. But fuel-blending can also be a way to recover the alcohol in expired hand sanitizer, to be reused or sold.
- Incidental reduction. Here waste streams are combined not to cause a specific chemical reaction, but to create a mixture that’s safer to handle than its constituents were individually. However, the combined waste must still meet the hazardous waste management requirements for its individual constituents—even if chemical testing shows that one or more hazmat characteristics have been eliminated by consolidation.
Bear in mind that rules for fuel blending and incidental reduction vary by state and localities, and neither is defined explicitly in EPA rules. (Fuel blending generally requires a hazardous waste installation and operation permit for storage and treatment).
Can expired hand sanitizer be recycled?
Because recycling expired hand sanitizer doesn’t require registering it as hazardous waste, doing so can be more economical than hazardous waste disposal. Still, there are EPA and DOT regulations that must be observed.
Can small amounts of expired hand sanitizer be discarded into municipal waste?
The EPA allows you to throw away “household” amounts of hand sanitizer into the municipal waste stream (aka the garbage), just so long as you don’t pour any of it down the drain. Also, to avoid any unwanted attention, we advise taking larger quantities of hand sanitizer to a local household hazardous waste collection facility.
What’s the upshot about what to do with expired hand sanitizer?
Hand sanitizer is considered a hazardous substance by OSHA, the DOT, and the EPA. Our country is awash in it, and the amount of expired hand sanitizer requiring hazardous waste disposal will grow prodigiously soon.
Complicating matters, it’s usually state agencies that enforce and interpret EPA hazmat regulations—not the federal government.
States differ about what makes a hazardous waste and how it should be handled. Their rules also diverge regarding recycling. Mistakes and misinterpretations about such local rules can be expensive, litigious, and time-consuming.
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