Ask the expert: Medical waste manifests

By: September 7th, 2011 Email This Post Print This Post

Q: How long must our practice keep EPA manifests for medical waste?

A: Manifests for small-quantity generators are to be kept for three years, according to the EPA’s Understanding the Small Quantity Generator Hazardous Waste Rules: A Handbook for Small Business.

Some states have additional requirements, so it is always best to check with your state ­department of environmental quality.


However, if the generator of hazardous waste has “cradle to grave” liability exposure why would one not want to keep forever all manifests to support proper disposal many years hence when they are named in a hazardous waste clean up lawsuit?

With today’s electronic records so easily stored and accessible there is no reason not to keep all records indefinitely. Manifests are easily archived and retrieved for little to no cost. A good disposal and treatment provider will keep these records available to their customers online behind a password protected portal for 24/ 7 access. We do this at for our customers.


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