How Does the FDA Regulate Hand Sanitizer?
Regulatory Transparency Project's Fourth Branch Video
Regulatory Transparency Project's Fourth Branch Video
Due to the COVID-19 pandemic, hand sanitizer has been in high demand. The FDA has stringent regulations about the ingredients for hand sanitizer. This guidance was relaxed somewhat to allow more production from a variety of alcohol industries, such as fuel alcohol manufacturers. After these industries invested time and money preparing to produce hand sanitizer, the FDA revoked the initial guidance and dictated that all hand sanitizer must comply with the usual standards. Are the actions of the FDA justified out of a concern for safety, or should some regulations be re-evaluated in times of emergency?
T. Elliot Gaiser is an Associate at Boyden Gray & Associates PLLC.
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Assistant Attorney General, Office of Legal Counsel, U.S. Department of Justice
T. Elliot Gaiser is the Office of Legal Counsel’s 27th Assistant Attorney General. He was nominated by President Donald Trump on April 29, 2025, confirmed by the United States Senate on July 30, 2025, and sworn in as AAG by Attorney General Pam Bondi on August 4, 2025.
Prior to joining the Office of Legal Counsel, Mr. Gaiser served as the 11th Solicitor General of Ohio. In that role, he represented his home state and its agencies before the Supreme Court of the United States, the United States Court of Appeals for the Sixth Circuit, the Supreme Court of Ohio, and other state and federal courts. He also advised Ohio Attorney General Dave Yost on significant legal and constitutional matters important to the people of Ohio.
Mr. Gaiser clerked for Justice Samuel A. Alito, Jr. of the Supreme Court of the United States, Judge Neomi Rao of the United States Court of Appeals for the D.C. Circuit, and Judge Edith H. Jones of the United States Court of Appeals for the Fifth Circuit. In the private sector, Mr. Gaiser worked at the law firms Jones Day, Boyden Gray, and Gibson Dunn. He graduated from the University of Chicago Law School and Hillsdale College. He is also a husband and father.