Ready to Comply with New York DEC Haz Waste Rules? Start with C7 Regs
Are you an environmental, health, and safety (EHS) or operations manager at any New York facility generating hazardous waste?
If so, are you confident you’re current with all of the New York State Department of Environmental Conservation’s (DEC) hazardous waste regulations? Unfortunately, some of the requirements are very technical, so it’s likely that not all affected managers are up to date with their specifics.
Not only are the regulations detailed and complex, but our New York onsite support (OSS) managers have seen firsthand how DEC enforcement is becoming more aggressive. Because of the situation, this introductory blog is the first in a series to highlight the top five areas where New York state generators are being noncompliant.
These blogs will enable managers to take the steps necessary to adherence. We’ll start by listing the top five commonly seen infractions, as compiled by our dedicated EHS professionals.
They are:
- C7 Notification
- Plans and Training Records
- Universal Waste Compliance
- Manifest Management
- CAA + SAA Compliance
DEC Compliance: Path to Efficiency
Naturally, waste generators will need to proactively address these regulations. In doing so, they will be able to protect human health and the environment, while simultaneously avoiding citations and fines. Aside from avoiding noncompliance, adherence to the rules will likely also result in internal improvements that support more efficient waste handling and disposal processes. In striving for full compliance, EHS managers can pinpoint weak points in current programs and work to improve these operational gaps.
DEC Haz Waste Rules: Whom Do They Affect?
The New York DEC enacts state laws and regulations that are at least as stringent as the federal laws and regulations from the Environmental Protection Agency (EPA). Their framework supports the management and treatment of common hazardous commercial and industrial wastes. Generally speaking, the key industries that are most at risk of violations are:
- Healthcare facilities and chains, from single hospitals and clinics to major networks
- Life science and pharmaceutical organizations, from startups in the innovation state, on to midsize firms, up to enterprise corporations
- Higher education organizations, from small universities to major multi-site campuses—especially when there are teams conducting independent lab research
Fortunately, our team members have worked (often alongside DEC inspectors) through numerous comprehensive inspections. Because of this experience, we have a sound understanding of the regulations and how to comply with them. We’ll begin with the C7 notification requirement, outlining the details of this specific regulation and what’s needed to comply.
5 Answers to C7 Notification Requirement Questions
Q: What is a C7 notification?
A: A C7 notification is a letter informing the DEC that a facility intends to recycle hazardous waste instead of landfilling or incinerating it. These wastes may include:
- Solvents intended for reuse
- Excluded scrap metal
- Hazardous waste scrap metal (lead aprons and bricks, and so on)
C7s are NOT required for:
Q: Who needs a C7 notification?
A: The C7s are necessary for New York state hazardous waste generators seeking to claim a recycling exemption (under 6 NYCRR 370). With the intention to reclaim, recycle, or reuse specific materials, these materials and wastes may be exempt or excluded—thus requiring submittal of a C7 notification.
Q: Why do I need a C7 notification?
A: Closely observing the protocols for C7 notifications eases the regulatory burden in managing on-site waste compliance. Collected data ensures that the DEC can enforce environmental and public health protection regulations without preventing sustainability practices.
They also enable the DEC to track all New York-based organizations that are seeking to recycle the aforementioned waste types. This applies if they are involved in hazardous waste:
- Generation
- Transportation
- Treatment
- Storage
- Disposal
A: These are due:
- At the initial submission of any exemption request
- When there is an on-site process change
Generators must submit:
- A separate form for each unique exemption claim
- A claim for each unique waste type managed under the exemption
To submit:
- Email forms to info.sqg@dec.ny.gov
- Or mail to: RCRA Compliance & Technical Support Section, Bureau of Hazardous Waste and Radiation Management, Division of Materials Management, New York State Department of Environmental Conservation, 625 Broadway, Albany, NY 12233-7256
Remember to retain a copy of your C7 notification for your records.
Q: Where should you store your C7 notification?
A: They can be kept with your waste manifests or waste profiles to enable easy access when requested by an inspector.
Partnership for DEC C7 Compliance
Achieving compliance with New York DEC hazardous waste regulations can be time-consuming, expensive, and difficult. Working with a trusted partner can help ease the regulatory burden and increase compliance. Triumvirate Environmental’s expert team understands all DEC hazardous waste rules and exemptions—and can help ensure successful, full compliance.
Talk to us today to learn how we can assist you.
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