In light of COVID-19, the New York State Department of Environmental Conservation (DEC) recently published a direction letter addressing safety concerns regarding the collection of required signatures on waste shipping papers pursuant to 6 NYCRR Parts 364, 372, 374-2, and 381.

Pursuant to its enforcement discretion, DEC has authorized the use of alternative signature procedures for solid waste, hazardous waste, and low-level radioactive waste shipping papers. Now that trash and recycling processing and disposal services are considered “essential” pursuant to Governor Cuomo’s Executive Order 202.6., DEC’s new policies are designed to reduce person-to-person contact and protect workers in these industries.  DEC further notes, however, that all regulations associated with these industries are still in effect.

DEC also advises that if a shipment is being sent to or being received from another state, the regulated party should contact the other state’s jurisdictional agency to ensure compliance with that state’s requirements. The alternative signature procedures will expire on September 7, 2020, unless they are extended or revoked. The specific procedures for each type of waste are outlined in DEC’s memorandum.

For further resources and developments, visit our firm’s COVID-19 response page.

This alert does not purport to be a substitute for advice of counsel on specific matters.

Harris Beach has offices throughout New York State, including Albany, Buffalo, Ithaca, Long Island, New York City, Rochester, Saratoga Springs, Syracuse and White Plains, as well as New Haven, Connecticut and Newark, New Jersey.