The COVID-19 pandemic triggered large volumes of hand sanitizer purchasing. Many companies over-stocked and couldn't manage the excess of saleable items. They had too much volume, and the hand sanitizer became off-spec: it was manufactured outside of the US and failed to meet the FDA's standard for hand sanitizer products sold within the country. These products did not meet minimum requirements nor have an appropriate level of alcohol to be considered a hand sanitizer. To see a list of recalled or banned brands and products, visit the FDA website.
Clean Earth's ethanol recovery capabilities are valuable to any retailer or manufacturer with a sustainability focus. We can provide ethanol recovery and recycling across the country, so you don't have to report hand sanitizer disposal as hazardous waste. Hand sanitizer products sent to ethanol recovery are exempt from the EPA’s federal hazardous waste regulations because they are a commercial chemical product being reclaimed or recycled.
Generators outside of California and Minnesota do not have to count hand sanitizer waste towards their Generator Status. This mitigates the risk of Small Quantity Generators (SQG) moving to a Large Quantity Generator (LQG) status that comes with significantly more hazardous waste regulations.
When recycled, hand sanitizer is exempt from hazardous waste regulations and does not have to ship on a Uniform Hazardous Waste Manifest. Clean Earth is then able to ship hand sanitizer waste on Bills of Lading, rather than hazardous waste manifests. Bills of Lading do not get submitted to the EPA which significantly reduces risks for our customers.
Are you a generator with hand sanitizer waste? Request a quote from Clean Earth below.
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