Enforcement Discretion: Alternative Signature Procedures for Waste Shipping Papers during COVID-19 Emergency

New York State Department of Environmental Conservation
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Enforcement Discretion: Alternative Signature Procedures for Waste Shipping Papers during the COVID-19 Emergency

Notice of New Enforcement Discretion Concerning the 6 NYCRR 360, 370, and 380 Series of the Solid Waste Management, Hazardous Waste Management, and Radiation Regulations.

DEC recently published a new enforcement direction letter to address safety concerns regarding the collection of required signatures on waste shipping papers (bills of lading, hazardous waste manifests, low-level radioactive waste manifests, etc.) during the COVID-19 public health emergency.

Given that waste collection, processing and disposal providers, and many of the industries that they serve are considered essential services, DEC is exercising enforcement discretion to allow these businesses to continue to safely manage waste without imposing requirements that run counter to social distancing practices. A copy of the enforcement discretion letter and the alternative signature procedures that will be allowed in lieu of the handwritten signatures that are typically required can be found on DEC’s website.

Contact: For more information about this enforcement discretion letter, please contact NYS DEC, Division of Materials Management, 625 Broadway, Albany, NY 12233-7250; Phone: (518) 402-8651; E-mail: hwregs@dec.ny.gov. Please state if you want to know more about solid waste, hazardous waste, or low-level radioactive waste requirements in your correspondence so we can route your questions to the appropriate staff member.