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Hazardous Waste Reduction Plans

What is the Hazardous Waste Reduction Plan (HWRP)?

Section 27-0908 of the Environmental Conservation Law states that it is in the best interest of the State to require facilities that release hazardous wastes and toxic substances into the environment to reduce, to the maximum extent possible, the volume or quantity and toxicity of waste. To facilitate these reductions, the law requires generators of hazardous wastes to prepare, implement and submit to the New York State Department of Environmental Conservation (NYSDEC) a Hazardous Waste Reduction Plan (HWRP). The HWRP, which will be reviewed for acceptance by the NYSDEC, must be reported on annually, and updated on a biennial basis. All hazardous wastes emitted into the air, discharged into waters, or treated and disposed of in a permitted facility, are covered by the law. The HWRP shall establish opportunities to reduce hazardous waste through implementing technically feasible and economically practical waste reduction technologies, process or operational changes, material substitutions, or by other means.

Do I need to comply with the Hazardous Waste Reduction Plan?

You must comply if you:

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

* NOTE - The following hazardous wastes are not included in the calculation of the amount of hazardous waste generated for the 25 tons or greater category:

  1. by corrective action for a release from a hazardous waste treatment, storage, or disposal facility; or
  2. by the remediation of an inactive hazardous waste disposal site; or
  3. the cleanup of a release to the environment reported pursuant to Articles 17, 37 and 40 of the Environmental Conservation Law; or
  4. demolition and construction debris; or
  5. one-time wastes, which are otherwise subject to the requirements of Section 27-0908 of the Environmental Conservation Law.

How do I comply with the program?

You will be required to submit an initial Hazardous Waste Reduction Plan (HWRP) by July 1 for the previous calendar year. Upon approval of the HWRP, you are required to submit an Annual Status Report (ASR) by July 1 of the next year. By July 1 of the next year you are required to submit a Biennial Update (BU). You continue to submit ASRs and BUs every alternating year thereafter. Please refer to the following links for guidance on how to prepare HWRPs, ASRs and BUs:

Guidance for submitting a Hazardous Waste Reduction Plan (HWRP)
HWRP checklist
Environmental Conservation Law Section 27-0908 (leaves DEC's website)