The U.S. Food and Drug Administration (FDA) regulates hand sanitizer as an over-the-counter drug, which means these bottles of germ killers must have an expiration date.
For many people, expiration dates are merely suggestions. Others take them as seriously as law. But does hand sanitizer expire, or can you still use it past the “use by date” featured on every bottle?
Many health experts agree that hand sanitizer products past their expiration date will still kill germs on your hands. However, the University of Southern California’s Environmental and Health Safety Department warns that the alcohol content that makes hand sanitizer so successful can diminish over time. Especially if a container is partially full or stored in a warm place like your vehicle, evaporation can impact alcohol content. Scientists suggest leaving expired hand sanitizer on your hands for a longer period of time to help make up for this loss.
The shelf life for hand sanitizer is around three to five years after the product is manufactured. Consumers who bought hand sanitizer at the beginning of the covid19 pandemic may want to put it to use this upcoming cold and flu season. But for businesses that sell hand sanitizer on their shelves, having expired products can mean a headache when it comes to disposal.
Does Your Business Have Excess Expired On Your Hands?
Businesses that switched gears during the pandemic and began manufacturing hand sanitizer may also find themselves in a tough situation. Thanks to relaxed guidelines issued by the U.S. government to help meet an extraordinary demand for hand sanitizer, many companies like distilleries manufactured hand sanitizer toward the beginning of the pandemic.
However, the U.S. government withdrew these relaxed guidelines at the end of 2021. Any business producing hand sanitizers under temporary policies were required to stop making new hand sanitizer on Dec. 31, 2021, and they could no longer distribute it beginning March 31, 2022.
That means some businesses may be storing hand sanitizer that never sold in warehouses or storage facilities.
Even post-pandemic, it can be easy for organizations like hospitals and other medical facilities who regularly use hand sanitizer to have some excess quantities on hand that are now expired.
Those that stocked up on extra hand sanitizer or continued manufacturing it under the temporary policies are now faced with the dilemma of disposing of the unused product.
This shift from pandemic-era production to post-pandemic regulations has highlighted the importance of inventory management and adherence to changing government guidelines for businesses involved in the hand sanitizer industry.
What Should You Do With Expired Hand Sanitizer?
The U.S. Environmental Protection Agency has warned that you should never dump it down the drain. Hand sanitizer contains at least 60% alcohol as the active ingredient, with some brands containing a higher amount. Isopropyl alcohol is easily ignitable. If an individual or business pours the substance down the drain, a public health nightmare may occur, with the possibility of fires and explosions occuring in water pipes and sewers.
So what’s the alternative? Residents can often properly dispose of unused alcohol based hand sanitizer at a household hazardous waste drop-off location or at a special disposal event for household hazardous waste.
For businesses, drop-off locations are usually reserved only for residents. Businesses that possess large amounts of hazardous waste must use certified hazardous waste disposal companies to legally transport their products to the proper disposal sites that are equipped to handle these substances.
Because of the dangerous nature of flammable liquids like hand sanitizer, regulations for transporting and disposing of flammable liquids are quite extensive. Some of the transporting requirements include:
- Only approved portable tanks and containers may be used to store and transport class 3 flammable liquids.
- Portable tanks must include provisions for emergency vents that can be used to decrease internal pressure under fire exposure conditions. They must also have at least one pressure-activated vent.
- Small containers holding less than 8 gallons of flammable liquid and with a weight of fewer than 440 pounds can be transported by anyone who has undergone general hazmat training.
- Shipments must include MSDS sheets and must be appropriately labeled as “Gasoline” or “Flammable Liquid.”
- Larger shipments must include MSDS sheets, an emergency response guide and a hazmat bill of lading.
- Drivers who transport more than 119 gallons or more than 1,001 pounds of class 3 dangerous goods must also have a commercial driver’s license or CDL. Extensive driver training is also highly recommended for those who carry large amounts.
- Shippers who transport containers that hold less than 8 gallons and weigh more than 440 pounds but less than 1,001 pounds and containers that hold between 8 and 119 gallons and weigh less than 1,001 pounds must complete emergency response guide training as well as HM-126F training.
- Dangerous Good placards are required by 49 CFR 172.500 as well as the International Maritime Organization. Such placards must be affixed to highway, rail and ocean containers.
If you’re a manufacturer, distributor or business currently in possession of large quantities of expired hand sanitizer, it’s important to find a hazardous waste disposal company that can ensure these products are safely disposed of according to the law.
What A Disposal Company Should Offer Your Business
A disposal company must possess a comprehensive understanding of the current challenges faced by hand sanitizer manufacturers, distributors and end-users. They should have a well-devised plan to ensure the safe disposal of inventory at designated hazardous waste collection sites.
A reputable vendor should also be capable of:
- Preparing labels, manifests and all necessary paperwork
- Providing swift pickup services
- Addressing any cost-related concerns
- Assisting in the proper packaging of materials to prevent fines and cost overruns
- Efficiently managing the disposal of other types of waste you may have
- Offering a hazardous waste walk-through program to identify potential storage and disposal issues
It’s also crucial to ensure that a certified transporter is listed on the California Department of Toxic Substances Control’s Registered Hazardous Waste Transporter Database. This database provides essential information, including the transporter's registration status, expiration date, registration number and location.
Since a hazardous waste transporter's registration is valid for just one year, conducting annual environmental audits of vendors responsible for handling your hazardous waste is advisable, particularly if you are seeking a long-term partnership beyond the disposal of your hand sanitizer inventory.