At the beginning of the Covid-19 pandemic, factories, distilleries and other companies switched gears and began manufacturing hand sanitizers at record speeds.
As medical facilities and grocery stories struggled to keep their shelves stocked, manufacturers and distributors worked to get the alcohol-based cleansers into hands as quickly as possible. To help, the U.S. government issued relaxed guidances to help meet this demand, allowing for more temporary regulatory flexibility when it came to formulation, labeling and disposal.
However, because data indicates that consumers and healthcare professionals are no longer experiencing these difficulties, the U.S. Food and Drug Administration (FDA) began withdrawing temporary hand sanitizer guidelines.
This means if you manufacture, distribute or have in possession excess hand sanitizer and have to dispose of it because it is past its expiration date, you must comply with all applicable regulatory requirements that were in place prior to Dec. 31, 2021.
Why are these updated guidelines important? Federal regulations require that alcohol-based hand sanitizers be treated as hazardous waste.
If you have large quantities of hand sanitizers on hand, it’s important that you act fast and secure legal methods for proper disposal. The longer you wait, the more likely there will be other manufacturers and distributors lined up and waiting for disposal services. This may cause not only a delay in your disposal but a significant price hike as the demand for these certified disposal services increases.
Although hand sanitizer products are considered over-the-
Effective hand sanitizers typically are manufactured using a formula that includes ingredients that range between 60 and 95% ethyl or isopropyl alcohol. At this concentration, hand sanitizer is classified as a Class 3 Flammable Liquid, according to the U.S. Department of Agriculture.
Class 3 Flammable Liquids are those that have a flashpoint of not more than 140 degrees Fahrenheit. A flashpoint is a temperature at which a particular organic compound gives off sufficient vapor to ignite in air.
Released vapor is the true danger of flammable liquids. For example, if static electricity is present, a highly flammable substance can be ignited.
This means businesses disposing of hand sanitizer must follow specific handling and disposal requirements, ensuring that there is no threat to human health and the environment.
Meeting federal disposal regulations can be achieved by working with certified hazardous waste disposal companies.
It’s important to keep in mind that because of the dangerous nature of flammable liquids, regulations for transporting and disposing of flammable liquids are quite extensive. Some of the transporting requirements include:
If you’re a manufacturer, distributor or end-user currently in possession of large quantities of hand sanitizer that are about to expire or have expired and must be disposed of, hazard waste disposal should be a top concern NOW.
Because time is of the essence, finding the right hazardous
Don’t trade short-term cost savings for long-term liabilities.
A disposal company should be familiar with the challenges hand sanitizer manufacturers, distributors and end-users are currently facing and have a plan in place to ensure their inventory can safely be disposed of at the appropriate hazardous waste collection sites.
A quality vendor will also be able to:
A certified transporter should also be listed on the California Department of Toxic Substances Control’s Registered Hazardous Waste Transporter Database. This database provides information about when the transporter’s registration expires, its registration number and its location.
A hazardous waste transporter registration is valid for only one year, so it’s a good idea to conduct annual environmental audits of vendors handling your hazardous waste, especially if you are looking for a long-term partner beyond the disposal of your hand sanitizer inventory.
If your company is holding on to excess quantities of hand sanitizer, it’s time to dispose of it … before it’s too late. While once a hot commodity, hand sanitizer is regularly available. That means you’ll soon be left with a stash of worthless products.
And, the longer you wait to dispose of it, the more likely you’ll pay for higher and higher disposal costs. It’s a simple case of supply and demand. More and more manufacturers and distributors are beginning to unload their surplus supplies, and if you get caught getting rid of your supply too late, you’ll pay a higher premium for in-demand disposal service.