Submitting A Hazardous Waste Reduction Plan: Ultimate Guide

Are you prepared for New York State’s July 1st Hazardous Waste Reduction Plan (HWRP) deadline?

If your facility generates hazardous waste, now is the time to determine whether you need to submit a HWRP for state approval, update an existing plan, or complete a required status report. With the deadline quickly approaching, delaying preparation could leave you scrambling to gather the necessary information and documentation.

Taking action early not only helps you stay compliant with New York State requirements, but also gives you the opportunity to review your waste reduction efforts, identify cost-saving opportunities, and strengthen your facility’s environmental performance.

Hazardous Waste Reduction Plan: Fast Facts

• NY generators that produce 25 or more tons of hazardous waste in a calendar year need to submit a HWRP

• The submission deadline is July 1, annually
• Reporting and plan revisions will be required every year until the facility reduces its annual waste generation to below 25 tons

What Is a Hazardous Waste Reduction Plan?

A Hazardous Waste Reduction Plan (HWRP) is a written program that outlines how a generator plans to reduce its hazardous waste generation.

What Must Be Included in an HWRP?

Think of an HWRP as your facility’s roadmap for reducing hazardous waste. At a minimum it should include:

• A description of your facility’s operations
• Identification of each waste stream, including:
  • Its source
  • How it is managed and disposed of
• Waste minimization strategies for top waste streams
• How strategies will be implemented, tracked, evaluated for effectiveness, and assessed for financial impact

Waste Reduction Analysis

The first step, which is also the most crucial, is completing a waste analysis. New York State requires you to focus on the waste streams that account for 90% of your total annual hazardous waste generation.

Waste generated from demolition and construction debris projects, as well as “one-time waste streams,” can be excluded from your HWRP. In most facilities, the primary contributors are typically flammable liquids, solvents, and pharmaceuticals.

Once you’ve determined the major waste streams, you are required to assess opportunities to reduce waste. For example:

• Upgrade or modify equipment
• Recycle material (e.g., alcohol, solvents)
• Improve or streamline processes
• Replace hazardous chemicals with non-hazardous chemicals

If reduction is not feasible, you must clearly explain why. This explanation must be supported with data, such as:

• Cost estimates
• Return on investment (ROI)
• Productivity or operational impacts

Remember, your plan must be approved by New York State; providing a clear picture of the facility and what is feasible for you will be helpful in gaining approval. Saying “we just can’t do it” won’t be enough for compliance.

Implementation and Tracking

For each selected waste reduction strategy, your plan must include:

• A timeline for implementation
• A method for evaluating effectiveness
• Criteria for determining whether adjustments are needed

Hazardous Waste Reduction Plan Submission

Who Must Submit an HWRP?

• Any generator of twenty-five (25) tons or more of hazardous waste in a calendar year
• Any generator required to hold a Part 373 hazardous waste storage, treatment or disposal permit for the on-site management of hazardous waste

Why Do I Need to Submit an HWRP?

In New York State, submitting a Hazardous Waste Reduction Plan is not just a best practice; it’s required by law (Environmental Conservation Law §27-0908). This law requires facilities to reduce the amount and toxicity of hazardous waste as much as reasonably possible.

Beyond compliance, reducing hazardous waste is simply good practice. It helps protect the environment, lowers potential risks, and can improve overall operations. As a generator of hazardous waste, you should make every reasonable effort to reduce how much waste you produce and how hazardous it is.

Are There Any Penalties for Failing to Submit an HWRP?

By not submitting an HWRP, you are considered in violation of NYS hazardous waste regulations. Penalties can reach tens of thousands of dollars per day, plus corrective action requirements and even civic or criminal liability.

How to Submit an HWRP

Generators submit their HWRP to the New York State Department of Environmental Conservation (NYSDEC). Once submitted, the NYSDEC must approve the plan.

When Does the HWRP Need to Be Submitted By?

On or before July 1 of each year. The plan should be based on the previous year’s waste activities.

When Does an HWRP Need to Be Updated?

The plan requires an annual status report to the NYSDEC and a biennial update.

For example, if you submitted your HWRP in 2025, you should follow the submission sequence below:

• 2025 – Submit NY Hazardous Waste Reduction Plan
• 2026 – Status Report
• 2027 – Biennial Update
• 2028 – Status Report
• 2029 – Biennial Update

And so on until your hazardous waste production goes below 25 tons.

Differences Between a Hazardous Waste Reduction Plan and Other Reports

A Hazardous Waste Reduction Plan focuses on strategy, procedures, and goals for reducing hazardous waste generated onsite. A report, on the other hand, focuses on results, data, and findings. Ultimately, you will need to create and assess waste reports to devise and implement an HWRP.

Common HWRP Errors to Avoid

Submitting a complete report is crucial—without all the required elements and analyses, the NYSDEC may not approve the plan, leaving you noncompliant and open to penalties. Some common HWRP errors to avoid include:

• Failing to include a waste stream flow chart that clearly shows how and where waste is generated within the facility.
• Not providing accurate cost information for waste streams. When evaluating economic feasibility, you need to consider all associated costs, not just disposal fees. Other costs could include:
  • Supplies
  • Labor
  • Transportation
  • Equipment
  • Reporting
• Including waste reduction ideas that are not practical or feasible. For example, do not state that waste can be reduced through product reformulation or redesign if the product formula cannot actually be changed.
• Not including acute hazardous waste in your waste stream analysis.
• Omitting end facility documentation. If you plan on using a recycler to reduce your hazardous waste generation, you need to provide documentation within your plan showing that the end facility can actually recycle your material. Shame recycling is not allowed.

Working with a qualified commercial hazardous waste disposal partner like Triumvirate Environmental can mean the difference between HWRP success and failure. In fact, our services make Hazardous Waste Reduction Plan submission simple and compliant, without pulling you away from core competencies. We can:

• Implement hazardous waste management software that seamlessly, efficiently, and continually produces waste reports that provide a clear picture of your waste generation activities at any given time
• Conduct a waste disposal assessment to determine if there are recycling options or alternative management practices that can be implemented to reduce your hazardous waste activities
• Prepare a written HWRP for submission
• Provide onsite environmental support to identify gaps and help implement your Hazardous Waste Reduction Plan

Hazardous Waste Reduction Plan FAQ

Have questions about how to prepare an HWRP or waste reduction strategies in general? Talk to an expert at Triumvirate Environmental. We can help your organization maximize waste disposal programs and leverage recycling solutions.