[Form 4] CLEAN HARBORS INC Insider Trading Activity

Rhea-AI Filing Summary

Alan S. McKim, Executive Chairman and CTO of Clean Harbors, reported multiple dispositions of Common Stock on 09/16/2025 coded as G (gifts) at a reported price of $0. Reported disposals were 8,567, 4,283 and 34,027 shares. The filing shows continued indirect beneficial ownership positions, including 2,346,744 and 2,342,461 shares via the McKim 2007 Trust and 100,000 shares via the McKim 2025 Annuity Trust. The form was signed by an attorney-in-fact on 09/17/2025.

Positive

• Substantial continuing ownership: Mr. McKim retains large indirect stakes (over 2.3 million shares in trust accounts), indicating ongoing alignment with shareholders.
• Transparent disclosure: Transactions were reported on Form 4 with attorney-in-fact signature, meeting Section 16 reporting requirements.

Negative

• Share disposals recorded: The filing reports gifts totaling 46,877 shares on 09/16/2025, which reduces the reporting person’s direct holdings.
• Lack of economic detail: Transactions are coded as gifts at $0, so the filing does not provide proceeds or recipient details.

Insights

Financial Analyst

TL;DR: Insider reported several gift dispositions while retaining large indirect holdings, indicating estate or personal planning rather than market sell-off.

The Form 4 shows three separate dispositions on 09/16/2025 coded as G, which denotes gifts or transfers for no cash consideration. Aggregate disclosed disposals total 46,877 shares based on the line items. Despite these transfers, Mr. McKim maintains substantial indirect ownership through family trusts and an annuity trust with reported positions of over 2.3 million shares in two trust accounts and 100,000 in an annuity trust. For investors, this filing documents insider transfers but does not provide price proceeds or indicate open-market selling activity.

Corporate Governance Expert

TL;DR: Multiple gift-coded transactions were reported and the filing was executed by an attorney-in-fact, consistent with planned transfers and trustee-managed holdings.

The use of Transaction Code G and the presence of large indirect holdings via named trusts suggest these are structured transfers, likely part of personal or estate planning. The signature block shows the form was submitted by an attorney-in-fact on 09/17/2025, which is common when executives delegate reporting tasks. The filing discloses no derivative activity and no amendments, and it preserves transparency about beneficial ownership changes.

SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0287
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Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

MCKIM ALAN S

(Last) (First) (Middle)

C/O CLEAN HARBORS, INC.

42 LONGWATER DRIVE

(Street)

NORWELL MA 02061

(City) (State) (Zip)

2. Issuer Name and Ticker or Trading Symbol
CLEAN HARBORS INC [ CLH ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

X	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	EXEC CHAIR, CTO.

3. Date of Earliest Transaction (Month/Day/Year)
09/16/2025

4. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
			Code	V	Amount	(A) or (D)	Price
Common Stock	09/16/2025		G		8,567	D	$0	2,346,744	I	McKim 2007 Trust
Common Stock	09/16/2025		G		4,283	D	$0	2,342,461	I	McKim 2007 Trust
Common Stock								34,027	D
Common Stock								100,000	I	McKim 2025 Annuity Trust

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
				Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares

Explanation of Responses:

	/s/ C. Michael Malm, Attorney-in-Fact	09/17/2025
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.

FAQ

What transactions did Clean Harbors insider Alan S. McKim report on Form 4 (CLH)?

The Form 4 reports three dispositions on 09/16/2025 coded as G (gifts) of 8,567, 4,283, and 34,027 Common Stock shares, each listed at $0.

How many shares does Alan S. McKim still beneficially own after the reported transactions?

The filing shows indirect beneficial ownership balances including 2,346,744 shares, 2,342,461 shares (both via the McKim 2007 Trust), and 100,000 shares via the McKim 2025 Annuity Trust as reported in the Form 4.

What does Transaction Code 'G' mean on this Form 4 for CLH?

Transaction Code G is used in the filing to indicate the disposition was a gift or transfer for no cash consideration as reported by the insider.

Who signed the Form 4 for Alan S. McKim?

The Form 4 was signed by C. Michael Malm, Attorney-in-Fact on 09/17/2025 according to the document.

Did the Form 4 report any derivative security transactions for CLH?

No. Table II (derivative securities) contains no reported transactions in this filing.