“alcohol exclusion” in EPA’s ignitable waste definition

Under EPA’s hazardous waste regulations, any aqueous solution that has a flash point of less than 140 degree F is considered to be ignitable and therefore a hazardous waste.

There is one exclusion (40 CFR 261.21(a)(1)). The ignitability definition does not apply to any aqueous solution that is ignitable because it contains less than 24 percent alcohol by volume. That excludes wine and some liquors that have less than 24% alcohol by volume. It also means that  most bar tenders will not become hazardous waste generators.

The term alcohol refers to any form of alcohol – not just ethanol.  It includes any chemical containing the hydroxyl [-OH] functional group.  The term “aqueous solution” refers to any solution that has at least 50% by weight of water.

This is all documented in one of EPA’s guidance documents on RCRA Online.

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