Rosie Bottone is a Senior Instructor for Lion's RCRA hazardous waste workshops.
What does a product expiration date mean? Generally, it’s the manufacturer’s way of telling you if you use the product by that date, they stand by the quality and maximum efficacy of the product. Does the EPA require you to dispose of the product when it reaches its expiration date?
No!
Of course, there are many reasons why you may no longer want to keep these unused commercial chemical products (CCPs) once they expire: quality control in a laboratory setting; customer/contract specs; loss of full efficacy; unwanted excess; a change in protocol; or a periodic clean-out. If they are regulated elsewhere (e.g. by the Food and Drug Administration) you may be required to dispose of or incinerate the materials.
But if the law allows, what else can you do with these CCPs? Below are some strategies that may help prevent your commercial chemical products from adding to your RCRA compliance burden.
1. Smarter SOPs
To give your organization more flexibility when handling these products, be careful how you word your company’s standard operating procedures (SOPs).
If your SOP states the equivalent of “as of expiration date, all products will be held for disposal,” you are declaring the expiration date to be the moment the unused CCP becomes a solid waste. If the chemical or sole active ingredient is listed at 40 CFR 261.33, or if the product exhibits the characteristic of ignitability, corrosivity, reactivity or toxicity, then it becomes a hazardous waste at that moment too.
2. One Man's Trash...
Keep in mind this old idiom—
One man’s trash is another man’s treasure! Consider donating your commercial chemical products to people or groups who can use them.
For example:
Employees. If you allow employees to take chemical products home, always provide instructions for proper household use and disposal.
Charitable organizations. Many organizations can use cleaning products, paints, and other surplus chemical goods. Of course, you should first check with the organization to make sure they accept what you’ve got.
Local high schools, colleges, or universities. Your local high school theater department may be able to use your excess paint in their theater department or wood shop. Many colleges and universities run chemical “redistribution” programs. Here are a few of examples you can check out:
Surplus chemical buyers. Post them on waste exchange lists that connect companies with unwanted materials with those who can use them. A simple online search using the terms “Waste Exchange Lists” will yield local, state and country-wide options. You can also contact industry associations to find other companies that can use your products as a substitute for a product they use, or as an ingredient to make their product.
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3. Proactive Inventory Control
The best solution to handling unwanted CCPs is to not have them to begin with. This can be accomplished with comprehensive
inventory control programs like;
- First in, first out policies;
- Communication between departments;
- Just-in-time purchasing; and
- Coordination between acquisitions and the hazardous waste management team.
Online RCRA Training–Convenient and User Friendly
US EPA requires annual RCRA training for hazardous waste personnel. Lion makes it easy to get effective, comprehensive RCRA training with two convenient online courses. Or, join us for a RCRA Refresher webinar to get instructor-led training from any internet connection.
RCRA Hazardous Waste Management (Online Course)
RCRA Hazardous Waste Management Refresher (Online Course)
RCRA Hazardous Waste Management Refresher (Webinar)
Courses are packed with original graphics, professional narration, and engaging exercises–so you learn by seeing, by hearing, and by doing. When we learn something in multiple ways, we retain more information and are better prepared to apply our knowledge to real world situations.
See all online Lion's RCRA training options at
Lion.com/RCRA.