Q: What is the proper method to store and dispose of waste alcohol prep pads? Are they considered hazardous waste?
A: The quantities of liquid alcohol in the preps would be considered incidental (or minimal) and not subject to the NFPA 30 (1996 edition) requirements for flammable liquid storage. However, even with incidental quantities, a written plan must be established on how your organization will address the disposal of the alcohol prep pads (which are flammable liquids) and how you will respond to a fire involving said flammable liquids. An evaluation is required on how the use and application of the incidental amounts of flammable liquids would pose a risk to safety to the occupants. Then a written action plan addressing those risks is required as well. Now pull those two actions together into a formal risk assessment and a written management plan on the proper use and disposal of the alcohol preps and the response to a fire that you would expect from your staff. As always, run the evaluation and written plan past the Safety Committee for their review and approval. It would also be a great idea to include the local AHJ on the evaluation and written plan to determine if they have any other suggestions or comments. They always want to know where flammable liquids are used or stored in an organization. You are required to have a written inventory of all hazardous materials and waste that is regulated. One can make the argument that the alcohol preps are regulated. Therefore, these alcohol preps would have to be included in the written inventory of hazardous materials and waste.