To prevent spread of COVID-19, the New York State Department of Environmental Conservation (NYSDEC) will exercise its enforcement discretion with respect to certain provisions of 6 NYCRR Parts 364,372,374-2, and 381. According to a Letter issued by the NYSDEC Office of General Counsel, the agency will not pursue enforcement of requirements for signatures on waste shipping documents. lf a waste shipment is being sent to, or is being received from, a state other than New York, the regulated party should contact the other state regulator to ensure compliance with that state’s requirements.
For hazardous waste shipments, affected parties shall use hybrid and electronic hazardous waste manifests, whenever those options are available to all parties listed on the manifest. If this option is not available to all parties listed on the manifest so that a paper-based hazardous waste manifest must be used, all affected parties must follow the specified procedure from Appendix 30 of 6 NYCRR Part 372 for a transporter signing “on behalf of’ a generator for a hazardous waste shipment.
For Non-Hazardous Waste and Used Oil Shipments, the following procedure must be followed:
- The driver picking up the waste must print the name of the generator in the Generator Name box.
- The driver must write “on behalf of in the Generator Signature box and then sign the driver’s name in the appropriate space.
- lf there is only a Generator Signature box on the waste shipping document, the driver must write “on behalf of’, print the generator’s name, and then sign the driver’s name in that box.
For Low-Level Radioactive Waste Shipments, all affected parties shall follow the specified procedure in 6 NYCRR 381.12for a transporter signing “on behalf of’ a generator for a low-level radioactive waste shipment.