The US Food and Drug Administration regulates hand sanitizer as an over-the-counter drug, and because of that, expiration dates are required.
Unfortunately, there were many safety and efficacy issues with some of the sanitizers produced for the pandemic, and the FDA is still adding to a growing list of more than 400 hand sanitizers the FDA says to avoid.
WA State DOH is still recommending hand sanitizers that meet safety regulations for school use when hand washing is not readily available (see page 6). Some county health inspectors seem not to understand the nuance of this recommendation, so if your inspection report indicates guidance to remove, please respond that your school will use hand sanitizer in areas where hand washing is not easily accessible and is tracking ingredients and expiration dates for safety & efficacy.
For those struggling to dispose of expired or unneeded hand sanitizers, this issue is being worked on at a county level. For King County, check out:
https://kingcountyhazwastewa.gov/en/about-us/hazardous-waste-library/h/hand-sanitizer.
WFIS is connecting with ESD and county health departments around the state to understand the regional programs available to schools for expired/unneeded hand sanitizer disposal. Stay tuned!