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Hazardous Waste Notification Forms

C7 Notifications

Some materials and/or activities may be exempt or excluded from the hazardous waste regulations, if specific conditions are met. When a generator (i.e., any business that generates hazardous waste) wishes to claim that certain materials are not a solid or hazardous waste under the 6 NYCRR 370 regulations (link leaves DEC website), or are exempt or conditionally exempt from regulation, because of their intent to reclaim, recycle or reuse the material, they must notify DEC Central Office in writing by mail, fax or email before using that exemption or exclusion. This notification, known as a "C7 Notification," must include: the names and physical addresses of the generator and receiving facility or facilities; the exemptions and exclusions that the generator is claiming and the corresponding regulatory citation; and the activities and materials that the generator believes are exempt or excluded. Materials that are exempt or excluded from the hazardous waste regulations may still be regulated as solid waste under the 6 NYCRR 360 regulations, even if a material is deemed to not be a "solid waste" in the 6 NYCRR 370 regulations (links leave DEC website).

The notification must be submitted when the generator is first claiming each exemption as well as any time a field on their form changes (e.g., the composition of the material or waste types being sent to a recycler changes, the material will be sent to a different recycler, a company who has already notified wants to claim the same exemption for additional facilities that were not on the original notification, the point of contact for the facility changes, etc.).* A separate form must be submitted for each unique exemption being claimed by a generator and each unique waste type being managed under the exemption. For example, a generator sending lead bricks for scrap metal recycling and waste unused solvents being sent for solvent reclamation would submit two notifications, one for the lead bricks and one for the solvents. In some cases, similar wastes being sent to the same place for the same type of recycling can be combined on the same notification. For example, lead bricks and lead shielding being sent for scrap metal recycling could be listed on the same form.

*Generators do not need to submit notifications to DEC for:

Note: Generators still need to keep the information required in these notifications in their records on-site, keep them up-to-date and provide them to DEC inspectors upon request, even if the generator is not required to submit a C7 notification to DEC before they begin using one of these exemptions or exclusions. Generators can use the generic C7 notification form on this page to meet this requirement.

Common Exemptions That Require a C7 Notification

Some commonly used exemptions and exclusions and their associated regulatory citations can be found in the table below (links in table leave DEC website):

Citation
(6 NYCRR)
Description Conditions Commonly Used For Additional Supporting Documentation Required
371.1(c)(6) Use/Reuse

Must be:

  1. used or reused as ingredients to make product;
  2. used or reused as an effective substitute for a product; or
  3. returned to the original process to be used as feedstock.
  4. Cannot be for materials that are: used in a manner constituting disposal; burned for energy recovery; or that are inherently waste-like.
  5. Must meet speculative accumulation limits.
  • Solvents
Yes
371.1 Table 1 Characteristic sludges being reclaimed
  1. Must meet speculative accumulation limits.
  • Photo processing solutions/filters
  • Baghouse filters
  • Spent granulated active carbon
  • Paint booth filters
No
371.1 Table 1 Commercial chemical products being reclaimed
  1. Only unused materials can qualify;
  2. Cannot be used for materials being reclaimed for use as fuels, unless the material itself is a fuel (e.g., gasoline).
  • Off-spec solvents
  • Unsold retail products
  • Fuels
Yes - If sent for other than original intended use (e.g., nail polish remover sent for solvent reclamation).
371.1(e)(1)(viii) Closed loop recycling
  1. Only tank storage may be used;
  2. Closed process connected by pipes or similar equipment;
  3. No controlled flame combustion;
  4. Must meet speculative accumulation limits;
  5. No burning for energy recovery, no land placement.
  • Solvents
No
371.1(e)(1)(xiii) "Excluded scrap metal" being recycled
  1. Metals must meet one of the definitions in 371.1(a).
  2. Metals containing liquids do not qualify (e.g., mercury switches, batteries, metals mixed with free flowing oils).
  3. Metal powders do not qualify, unless they have been agglomerated.
  • Hazardous waste scrap metal that has been sorted, baled, shredded, etc.
  • Metal scrap generated from steel mills, foundries, refineries and metal fabrication
No
371.1(g)(1)(iii)(b) HW scrap metal being recycled that is not "excluded scrap metal"
  1. Metals containing liquids do not qualify (e.g., mercury switches, batteries, metals mixed with free flowing oils).
  2. Metal powders do not qualify, unless they have been agglomerated.
  • Electronic waste/e-waste
  • Metal with lead-based paint
  • Lead bricks, shielding, wheel weights, etc.
No

C7 Notification Form to Submit to DEC

  • Generic C7 Notification for Generators - (PDF) (58 KB)
    This form may be used by generators that are operating under exemptions or exclusions for hazardous materials that are being sent for reclamation, recycling, or reuse. Examples include lead aprons or lead shielding being sent for recycling; printed circuit boards being sent for scrap metal recycling; lead bullets or ammunition being sent for recovery. Generators must indicate each exemption or exclusion that they are claiming on a separate form. (Generators who are managing electronic waste, precious metals, lead acid batteries, or dental amalgam as specified above and do not need to submit this form to DEC, may still use this form to record the information that is required for their on-site records.)

Airbag Waste Collection Facility Notification Form

An "Airbag Waste Collection Facility" is defined by EPA in 40 CFR 260.10 as "any facility that receives airbag waste from airbag handlers subject to regulation under 40 CFR 261.4(j) and accumulates the waste for more than ten days."

Facilities located in New York State that want to act as Airbag Waste Collection Facilities must notify DEC, using the DEC Airbag Waste Collection Facility Notification (PDF) (1284 KB), prior to receiving airbag waste. See DEC's Management of Waste Airbags page for information about additional airbag handling requirements.

Additional Assistance

If you require assistance with a particular hazardous waste issue that is not addressed in the information above, you may contact DEC for technical assistance by phone at (518) 402-8652 or by email at info.sqg@dec.ny.gov.