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Medical Waste Manifests and Tracking Forms: How Long Do I Need to Retain These?

Packaging and transportation are part of medical waste regulation. Proper documentation is required for both. How long do you need to retain medical waste manifests?

Medical waste cannot be tossed in the regular trash, nor can it be transported by your municipal waste management company.  Infectious waste must be transported in rigid containers that have been approved by the Department of Transportation. These containers are leak-proof, spill-proof, puncture resistant, and reusable. Many municipalities also require that hazardous or medical waste manifests and tracking forms be recorded for compliance reasons, but there are some exceptions. North Carolina, for example, does not require generators to maintain manifests, nor does it require “cradle to grave” tracking of medical waste. For others who do require it, how long do these paper trails need to be retained?

Manifests: The Basics

Hazardous or medical waste manifests are the forms used by all generators who transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage or disposal, unless the generator is exempted from this requirement. Manifests are required to track medical waste haulers and the destination of the hazardous waste. Manifests are initiated by the hauler and consist of an original and copies for the chain of custody.

Manifests and Cradle to Grave Processing

Labeling, packaging, and tracking medical waste in a facility that deals with regulated medical waste is the responsibility of the facility itself.  This is part of “cradle-to-grave” processing. What “cradle-to-grave” means is from the moment you generate medical waste, the disposal of that waste is ultimately your responsibility.  Even if you hire someone else to do it, you are still liable for any failure on their part to follow the law. “Cradle-to-grave” comes from The Resource Conservation and Recovery Act of 1976, or RCRA.  This was enacted because, prior to this law, only 10 percent of hazardous waste material was being managed properly. Manifests help maintain compliance.

Retention Periods

Manifests are to be kept for three years, according to the EPA. Some states have additional requirements, so it is always best to check with your state department of environmental quality.

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