This is an issue that has arisen at our school; be sure to check with your state and local regulators (if any) to determine how they interpret the EPA’s guidance in light of their own regulations.

- Ralph

EPA Provides Guidance on Proper Disposal of Hand Sanitizer

Proper disposal and recycling of hand sanitizer is a hot topic. We know states have been getting a lot of questions about this issue as have we. EPA released a detailed guidance document on how recycling and disposal of hand sanitizer is regulated and safety considerations to keep in mind.
• Read through the guidance.

https://rcrapublic.epa.gov/files/14953.pdf

Introductory paragraph:

During the COVID-19 pandemic, the demand for hand sanitizer surged. Many companies stepped up to respond to the demand. Some of those companies were traditional hand sanitizer manufacturers, others were not but adapted their processes to meet the Food and Drug Administration’s (FDA) temporary guidance for alcohol-based hand sanitizers. Now many businesses, schools and other organizations that manufactured or acquired large amounts of hand sanitizer during the COVID-19 pandemic are finding that the sanitizer is reaching expiration dates. Additionally, on October 12, 2021, FDA announced the withdrawal of its temporary guidance for alcohol-based hand sanitizers.1 As a result, effective December 31, 2021, companies that manufactured alcohol-based hand sanitizers under the FDA’s temporary policies had to cease production of these products. Further, hand sanitizers manufactured before or on December 31, 2021, and produced under the temporary guidance could no longer be sold or!
distributed by manufacturers after March 31, 2022.

(Seven pages of RCRA language follow).

---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
Follow us on Twitter @acsdchas