The Challenge:
Securing an alternative to traditional disposal solution for 5,700 Liters of 20% ethanol at a WTS client site.
The Process:
WTS qualified, vetted and approved an ethanol recycling facility, in compliance with our RCMS process, that was able to accept and recycle the clients ethanol.
The Result:
- Sustainable solution achieved through recycling.
- Cost savings of approximately $16,000 over traditional disposal.
More Details:
Ethanol is used in many industrial applications ,including use as a prime ingredient in hand sanitizers such as in this case. In normal circumstances when it is being discarded, the hand sanitizer would be regulated as Waste Flammable Liquid (D001) under RCRA. Although traditional “disposal” methods such as fuel blending or incineration would have addressed the issue, we embarked on a mission to find a more sustainable solution in support of the circular economy while still ensuring a compliant and regulated service offering. As we examined this challenge, we identified two possible methods to exit RCRA, thus allowing us to pursue proper Hazardous Waste management through recycling. The potential solutions included:
- Use as Commercial Product Substitution: If a hand sanitizer manufacturer (or a third party such as a specialized recycler) could extract ethanol from the hand sanitizer and the ethanol could be used as an ingredient to make a new product, then the hand sanitizer would not be a solid waste. As we know, if it is established that the material is not a solid waste, then it is also not regulated as a Hazardous Waste. The hand sanitizer is not a solid waste if it is destined for legitimate recycling and may be stored as a commercial chemical product without the need of a RCRA storage permit or otherwise being subject to RCRA hazardous waste requirements. We did need to establish that in this case the recycler would use the material as is and not perform any sort of reclamation processing on it and we also had to establish that the company must be prepared to demonstrate that there is a known market or disposition for the material. And of course, all of this has to properly documented both with the client in question and with the recycling company. WTS was able to assist our client in doing the same.
- Another avenue to consider is claiming a different RCRA exclusion commonly referred to as “The Alcohol Exclusion”. If said waste is a solution that is at least 50 percent water and less than 24 percent alcohol by volume, it can be disposed of in accordance with the applicable rules for solid waste, not a Hazardous Waste, or offered for commercial recycling to a verified recycler, whom typically would specialize in alcohol, including ethanol, recycling.
- And in a best of both worlds scenario, WTS identified a specialized ethanol recycler that could both accept the hand sanitizer under the “alcohol exclusion” and use the ethanol as a “commercial product substitute”. A true win-win-win for all parties involved.
All of this demonstrates our commitments to complaint, sustainable, cost -savings solutions for our clients in support of a true circular economy. Please be sure to contact your WTS representative to discuss any similar opportunities we can work with you on.
