Cradle-to-Grave Tracking: Hazardous Waste Manifest Requirements

by Kim Caserta, Consulting Safety Officer, Safety Partners, Inc.
Denise Aronson, President, Safety Partners, Inc.

Do you ship hazardous waste from your New Hampshire facility? If you answered yes, there are regulations for submitting a copy of a hazardous waste manifest to the New Hampshire Department of Environmental Services (DES) Waste Management Bureau within five days of the waste shipment. This document tracks hazardous waste cradle to grave - from the point of generation to its off-site treatment, recycling, storage, or disposal.

The U.S. Environmental Protection agency (EPA) estimates that 12 million tons of hazardous waste are shipped annually on hazardous waste manifests. Prior to 2005, there were many state-to-state variations in these manifests. In 2005, the EPA and U.S. Department of Transportation (DOT) adopted a uniform hazardous waste form to meet both the manifest requirements of the EPA and the shipping paper requirements of the DOT. The goal of this uniform hazardous waste manifest was to reduce the burden on waste handlers by removing the state-to-state variability while building critical accountability in the transportation and disposal processes that are key to protecting human health and the environment. The use of this uniform hazardous waste manifest became mandatory as of September 5, 2006.

As a generator of waste in New Hampshire, within five days of shipment, you are required to photocopy and mail page 6 of the manifest to the following address:

NH Dept. of Environmental Services
Waste Management Division-RIMS
PO Box 3900
Concord, NH 03302-3900

To help streamline the reporting process, place a sheet of labels that are printed with this address in your hazardous waste manifest files. After each shipment, a photocopy of page 6 can be placed into an envelope and the address labeled affixed for quick and easy mailing of the manifest. If your waste is being shipped to a state that also requires a copy of the manifest, make an additional photocopy of page 6 and mail it to the receiving state.

Are you unsure if the receiving state requires a copy of the manifest? Check the state's website or visit the EPA website, where there are links to each state's manifest requirements here.

To learn more about this hazardous waste disposal and related compliance information, visit the New Hampshire DES website at www.des.nh.gov or the EPA's website at www.epa.gov/osw.

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Safety Partners efficiently and cost-effectively implements hands-on environmental, health, and safety (EHS) programs at emerging life sciences companies. Safety Partners tailors its programs to each client's unique science, processes, procedures, and facilities, while reducing program implementation burdens. Its expertise is unmatched, clocking over 85,000 hours at over 120 New England life sciences firms.