NY Proposed Rules for Used Electronic Equipment - CRT

The New York State Department of Environmental Conservation (NYSDEC) is currently drafting a proposed rules for the management of used electronic equipment. Posting of the preliminary draft regulation is anticipated for Spring 2009, followed by further opportunity for public comment.

The resulting proposed rulemaking will amend NYSDEC regulations to streamline the management of used electronic equipment, whether regulated as hazardous waste or solid waste. The main issues to be addressed in the proposed rulemaking are:

• Adopting provisions of the Federal Cathode Ray Tube (CRT) Rule


• Adopting management standards for Collectors, Dismantlers, and Recyclers of Used Electronic Equipment


• Adopting provisions of the New York State Wireless Telephone Recycling Act


• Amending the requirements of New York's current Generator "c7" Notification

Currently in NYS, intact CRTs destined for recycling are eligible for the hazardous scrap metal exemption. However, when the CRT glass is no longer adherent to the metal, CRT glass could be regulated hazardous waste. The Federal CRT Rule contains the provisions to conditionally exclude this CRT glass from hazardous waste rules.

The current c7 notification requirements require generators (other than CESQGs) sending used electronics for recycling under the hazardous scrap metal exemption to file notifications. In the rulemaking, the NYSDEC is proposing to change the requirement to “[generators] must maintain on site, for a period of three years from the date of each shipment, the names and locations of the dismantling or recycling facilities and any intermediate receiving facilities."

Caltha LLP provides specialized expertise to clients nationwide in the evaluation solid waste and hazardous waste rules, developing waste handling procedures, and preparing cost-effective waste management programs.

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