Bulk Amounts of Expired Hand Sanitizer Requires Hazardous Waste Management

If you bought bulk amounts of hand sanitizer when COVID came to fore, which was about three years ago, and a lot of it’s still lying around, you have a hazardous waste disposal challenge. This blog discusses the safe and legal ways to tackle the problem. Q&As include:

1. How long do hand sanitizers remain effective, and does hand sanitizer expire?
2. Are expired hand sanitizers a RCRA hazardous waste?
3. Can you just pour expired hand sanitizer down the drain?
4. Can you just throw expired hand sanitizer into the regular garbage?
5. How do you dispose of hand sanitizer legally and safely?
6. Are there other options for disposing of bulk amounts of hand sanitizer?
7. Where can you get help disposing of bulk amounts of expired hand sanitizer?

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How long do hand sanitizers remain effective, and does hand sanitizer expire?

Three years ago, COVID-19 caused many companies to make bulk purchases of hand sanitizers, leaving the question, does hand sanitizer expire? The general rule of thumb is three years is the maximum shelf life of hand sanitizer. As a result, the pandemic has calved its own epidemic of expired hand sanitizers, which are a RCRA hazardous waste. How so?

Alcohol—the chief ingredient in hand sanitizers—is prone to evaporation. Thereby, you can expect hand sanitizer to be only 60 percent effective after three years, because the alcohol content will be evaporated by about 40 percent (see source). 

Are expired hand sanitizers a RCRA hazardous waste?

Absolutely. The concentration of alcohol in hand sanitizers is 60-to-95 percent. Doing the math, after three years of degradation to 60 percent, it will still contain 36-to-57 percent alcohol. At such levels, hand sanitizers are classified as Class 3 Flammable Liquids with a flammable liquids flashpoint and thereby of keen interest to a troika of regulatory agencies: OSHA, the DOT, and the EPA.    

Can you just pour expired hand sanitizer down the drain?

Don’t even think about it. 

If you were to pour 50 or so gallons of alcohol-based sanitizer down the drain, once it vaporizes, it would be combustive enough to blow the manhole covers off the municipal sewer system. Such an event would get you a lot of negative attention from federal, state, or local authorities—probably all three. And seven-digit fines are the norm, not the exception.

Can you just throw expired hand sanitizer into the regular garbage?

No. For the same reasons cited in Q.3 above, your dumpster might become an inferno. Or if you escape that conflagration, the garbage truck might catch fire when it compacts your load. Not good.

How do you dispose of hand sanitizer legally and safely?

Bulk amounts of expired hand sanitizer (between 440 and 1,001 pounds) must be transported to a secure hazardous waste disposal facility in an approved tanker truck or industrial waste management containers equipped with emergency pressure-activated vents. Drivers need to have CDLs and specialized safety training. Required Class 3 Flammable Liquids protocols include RCRA hazardous waste labels, registration, manifesting, and reporting. 

Are there other options for disposing of bulk amounts of hand sanitizer?

There are two. However, both nonetheless require the services of a professional hazardous waste disposal company. They are:

• Purposeful fuel blending. I.e., purposefully mixing the hand sanitizer with different wastes to induce a specific chemical reaction that creates a mixture that can be used for other purposes (e.g., use it as a fuel).  
• Incidental reduction. I.e., combining the expired hand sanitizer with other waste removal streams with no intention of creating a specific chemical reaction, but to render it more benign to store, transport, and ultimately dispose of the chemical waste. But you cannot just do this willy-nilly. Certain substances are reactive, meaning that if you mix them with alcohol, the resulting mixture will be even more combustible (or otherwise hazardous) than the hand sanitizer alone. 

Where can you get help disposing of bulk amounts of expired hand sanitizer?

Although (perhaps) you’ve never considered your business to be a hazardous waste generator, be aware that you’ve joined their ranks if you have bulk amounts of expired hand sanitizer onsite. 

Also, bear in mind that in almost all cases, it’s a state agency that provides enforcement and interpretation of EPA hazmat regulations—not the federal government. Thus, individual states can differ about what constitutes hazardous waste disposal and the hazardous waste services needed to handle it. Running afoul of such local requirements can be expensive, litigious, and time-consuming—and especially when you’re talking about bulk quantities.

In sum, you need the professional services of a hazardous waste management company to keep you safe and legal. 

Expert advice is crucial. You can get some here. 

And thank you for reading our blog!