Disposal of Alcohol Prep Pads

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.

Disinfectant Hand Wipes

Q: What are your thoughts on the flammability of disinfectant hand wipes? One of our VPs raised the question, noting that the wipes burn pretty well. Are these wipes a fire concern for hospitals?

A: There is no specific code or standard that directly addresses alcohol-based disinfectant wipes (ABDW), other than NFPA 30 for total accumulative gallons of flammable liquids, which really doesn’t apply in this case. So, the enforcement of ABDW is left up to the respective authorities having jurisdiction (AHJs) to interpret. In unofficial conversations with The Joint Commission Standards Interpretation Group, they have said they would add the accumulative total of ABDW to the accumulative total to the alcohol based hand rubs (ABHR) totals and limit the overall total of ABHR and ABDW to 10 gallons in dispensers per smoke compartment, and 5 gallons in storage (outside of a fire rated cabinet) per smoke compartment. This is consistent with the NFPA Tentative Interim Amendment (TIA) 787 dated April 15, 2004 that permits ABHR dispensers in hospital corridors and is retroactive to the 2003 and 2000 editions of the Life Safety Code. This TIA places limits on total quantities of ABHR products in dispensers per smoke compartment, which is 10 accumulative gallons total, for ABHR product in dispensers, and 5 gallons total in storage (outside of a fire rated cabinet) per smoke compartment. There are other AHJs who enforce the Life Safety Code in hospitals (CMS, State DPH, Local Fire Marshal, State Fire Marshal, Insurance Companies) and there is no guarantee they would take the same position as Joint Commission. It is advised that you check with your respective AHJs to determine compliance.