Does the EPA Alcohol Exemption Apply to Your Business?

Solid or otherwise, not all waste that incidentally contains alcohol necessarily requires hazardous material removal.  So how do you know?

EPA hazardous waste regulations stipulate that any aqueous solution with a flashpoint below 140F is ignitable and therefore requires hazardous waste management. However, this rule does not apply to aqueous solutions containing less than 24 percent alcohol.

Per the EPA, “alcohol” is defined as any chemical containing the hydroxyl

[-OH] functional group; and a solution is only considered aqueous when it’s at least 50 percent water by weight.

Thus, if the waste is contaminated with a solution that is less than 50 percent water and/or more than 24 percent alcohol by volume, it requires hazardous waste removal. In sum, it is deemed flammable—and dangerously prone to spontaneous combustion when compacted into a trash bin or garbage pail.

So what exactly is the EPA Alcohol Exemption?

If said waste is contaminated with a solution that is at least 50 percent water and less than 24 percent alcohol by volume, it can be disposed of in accordance with the applicable rules for solid waste. It isn’t considered potent enough to self-ignite; or if it should ignite, there’s too much water present for it to sustain combustion.  No hazardous waste management is required.

Thus, bars and restaurants don’t have to worry about discarding cocktail napkins, worn bar rags, or frayed table napery that might be liquor-soaked, so long as the liquor in question is less than 48 proof and more than 50 percent water (48 proof = 24 percent alcohol).

Rules for Textiles and Industrial Wipes

It’s a different scenario altogether for companies that use alcohol solvents. These include direct-to-consumer businesses, such as auto repair facilities or dry-cleaning establishments; or industrial enterprises, such as factories and assembly plants.

Owners and managers of these businesses need to be mindful of what contaminants reside on their discarded job rags and shop towels, which will typically exhibit a wide range of alcohol and water content. Some will require hazardous material disposal, some will not.

In fact, along with the aforementioned restaurant waste, it’s for these particular kinds of discarded textiles—so-called industrial wipes—that the EPA Alcohol Exemption was conceived. I.e., to relieve businesses of having to treat job rags and shop towels as hazardous waste—if and only when they are contaminated with 50 percent or greater aqueous solutions of less than 24 percent alcohol.

It’s not just textiles 

Many sorts of businesses and organizations might generate waste that requires hazardous materials disposal because it incidentally contains high levels of alcohol and is thus deemed flammable.

For example, hospital pharmacies typically have several thousand distinct pharmaceutical materials in inventory, any one of which can meet the EPA criteria for dangerous flammability when they become out-of-date and candidates for disposal.