State DEC Authorizes Use of Alternative Signature Procedures to Protect Workers

Harris Beach PLLC

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.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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