NYSDEC Proposed Revisions to Hazardous Materials Regulations

Image courtesy lebanonnh.gov

Since 2012, the United States Environmental Protection Agency (EPA) has promulgated a number of major changes to the rules that regulate the treatment, storage and disposal of hazardous waste. The New York State Department of Environmental Conservation is considering adopting a number of these federal changes to the applicable state rules.

Before it finalizes any of the proposed revisions, NYSDEC is conducting webinars, holdings meetings, and seeking comments on these potential revisions to the New York State hazardous waste management regulations.

Comments can be submitted to NYSDEC via email or U.S. Mail to the following addresses:



(Include “Comments on FedReg6” in the subject line of the email)

U.S. Mail:
Michelle Ching
625 Broadway
Albany, NY 12233-7256

The dates, times and locations of webinars and meetings can be found at:


The regulations proposed to be amended, revised are added to the New York Code of Rules and Regulations are as follows:

This rule adds regulations for the management of hazardous waste pharmaceuticals by healthcare facilities and reverse distributors. Healthcare facilities and reverse distributors will manage their hazardous waste pharmaceuticals under this new set of sector-specific standards in lieu of the existing hazardous waste generator regulations. These new regulations exclude certain U.S. Food and Drug Administration (FDA) approved over-the-counter (OTC) nicotine replacement therapies (NRTs) (e.g., nicotine gums, patches, lozenges) from regulation as hazardous waste. These provisions also prohibit the disposal of hazardous waste pharmaceuticals down the drain, this ban on sewering hazardous waste pharmaceuticals goes into effect nationwide on the effective date of the federal rule, regardless of adoption status of the rule by authorized states.

  • Increasing Recycling: Adding Aerosol Cans to the Universal Waste Regulations (Regulation proposed by EPA 2018)

Aerosol cans are managed by a wide variety of establishments, including retail stores. Aerosol cans may be hazardous wastes due to residual chemicals but may also be a hazardous waste because of the hazard posed by the pressure in the cans. By adding aerosol cans to the universal waste rule and creating a set of standards specific to the risks posed by this waste stream, collection and recycling of these wastes will be encouraged. This will reduce the quantity of these wastes going to municipal solid waste landfills or combustors.

  • Safe Management of Recalled Airbags Interim Final Rule (2018)

This rule facilitates the more expeditious removal of defective Takata airbag inflators and improve safe and environmentally sound disposal of collected airbag wastes from vehicles by dealerships, salvage yards and other locations.

Revises the definition of solid waste to conditionally exclude solvent-contaminated wipes that are cleaned and reused and revises the definition of hazardous waste to conditionally exclude solvent-contaminated wipes that are disposed.

The Carbon Dioxide Sequestration Rule provides a conditional exclusion for carbon dioxide (CO2) streams in geological sequestration activities. This rule would conditionally exclude CO2 streams that are hazardous waste from the definition of hazardous waste, if they are captured from emission sources and are injected into Class VI Underground Injection Control wells for geological sequestration, provided that certain requirements are met.

  • Hazardous Waste Electronic Manifest (e-Manifest) Rules (2014; 2018)   EPA’s e-Manifest Rules provide the legal and policy framework to authorize the use of electronic manifests. The e-Manifest system went into effect throughout the United States at the same time, even if authorized states had not yet amended their regulations. The e-Manifest system launched on June 30th, 2018. DEC must adopt these provisions to maintain conformance with the federal regulations.

Redefines “hazardous secondary materials.” It streamlines regulation of hazardous secondary material to encourage beneficial recycling and helps conserve resources. By removing unnecessary regulatory controls, it is expected to make it easier and more cost-effective to safely recycle hazardous secondary materials. EPA published substantial revisions to this rule on January 13, 2015. As amended, the rule provides greater safeguards from mismanagement. Certain parts of the 2015 Final Rule are more stringent than current DEC regulations. DEC must adopt these provisions, which include a revised definition of “legitimate recycling,” a prohibition on sham recycling, and new recordkeeping requirements related to speculative accumulation provisions.

Reorganizes and restructures the hazardous waste regulations to make them more user-friendly for the regulated community. This rule also includes revisions that are intended to address existing gaps in the hazardous waste regulations including container labeling, preparedness and prevention, and closure. The rule also contains some less stringent provisions designed to provide flexibility to the regulated community including procedures for episodic generation events, the waiver from the 50-foot setback for large quantity generators, and consolidation of waste from very small quantity generators by a large quantity generator under the control of the same entity.

  • Modernizing Ignitable Liquids Determinations (Regulation proposed by EPA 2019)

Regulation currently proposed by EPA to modernize the RCRA test methods used to determine the flash point of waste. Flash point is used to identify waste that is characteristically hazardous for ignitability. These revisions will provide more flexibility with regard to the testing requirements and greater clarity for the regulated community with respect to hazardous waste identification.

  • Hazardous Waste Export-Import Revisions (2016; 2017)

These rules amend existing regulations regarding the export and import of hazardous wastes from and into the United States (US). The rules make existing export and import related requirements more consistent with the import-export requirements for shipments between members of the Organization for Economic Cooperation and Development (OECD), enable electronic submittal to EPA of all export and import-related documents (e.g., export notices, export annual reports), and enable electronic validation of consent in the Automated Export System (AES) for export shipments subject to RCRA export consent requirements prior to exit from the US.

  • Disposal of Coal Combustion Residuals from Electric Utilities (2015)   EPA created this rule to regulate the disposal of coal combustion residuals (CCR) as solid waste under subtitle D of RCRA. This rule establishes a national minimum criteria for existing and new CCR landfills, existing and new CCR surface impoundments, and all lateral expansions. This rule primarily addresses regulation under solid waste rather than hazardous waste provisions. In the CCR rule, EPA revised an existing exclusion to allow certain low-volume wastes commonly produced in conjunction with the burning of fossil fuels to produce electricity to be excluded from the hazardous waste regulations if co-disposed with the fly ash, bottom ash, boiler slag or flue gas emission control wastes from coal combustion. On December 16, President Obama signed the Water Infrastructure Improvements for the Nation (WINN) Act into Law. The law includes amendments to the Resource Conservation and Recovery Act (RCRA) Section 4005, to address the regulation of CCR. EPA expanded their exclusion in 40 CFR 261 to include wastes that are commonly co-disposed with these wastes. DEC is not planning to expand the exclusion in 6 NYCRR 371.1(e)(2)(iv), Identification and Listing of Hazardous Waste. There are currently two coal-fired power plants in the state that operate on an intermittent basis.

Kevin C. Murphy is a member of the Wladis Law Firm, P.C., located in Syracuse, New York. Should you have questions regarding the generation, storage, treatment or disposal of hazardous waste or any of the under consideration changes to New York’s hazardous waste rules or if you would like assistance in preparing and submitting comments to NYSDEC, please feel free to contact Attorney Murphy or Attorney Timothy Lambrecht of the Wladis Law Firm.

Kevin Murphy

Kevin C. Murphy concentrates his practice in the areas of environmental compliance and litigation; environmental and white-collar criminal defense, and complex litigation matters. Mr. Murphy is a graduate of the University of Virginia School of Law and a former senior trial attorney with both the Kings County (NY) District Attorney’s office and the U.S. Department of Justice Environmental Crimes Section in Washington, D.C. He previously taught a seminar on environmental criminal enforcement at the Syracuse University School of Law and has been listed in The Best Lawyers in America.

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Lead-Based Paint: Notice Requirements imposed by Federal Law on Sellers, Property Managers, Landlords and Real Estate Agents

In 1978 the federal government banned consumer uses of lead-based paint, thus effectively stopping the use of lead-based paint in all housing across the country. Prior to that date, lead-based paint was widely used including in housing and homes constructed prior to that date.  If properly managed lead-based paint poses little, if any risk to human health. If allowed to deteriorate (peeling, chipping, chalking, cracking, damaged, or damp), lead-based paint is a potential hazard. It can cause serious health problems, especially to children and pregnant women.


Federal law requires that before being obligated under a contract to buy housing built prior to 1978, buyers must receive the following from the seller:

  • An EPA-approved information pamphlet on identifying and controlling lead-based paint hazards titled Protect Your Family From Lead In Your Home.
  • Any known information concerning the presence of lead-based paint or lead-based paint hazards in the home or building.
    • For multi-unit buildings, this requirement includes records and reports concerning common areas and other units when such information was obtained as a result of a building-wide evaluation.
  • An attachment to the contract, or language inserted in the contract, that includes a “Lead Warning Statement” and confirms that the seller has complied with all notification requirements.
  • A 10-day period to conduct a paint inspection or risk assessment for lead-based paint or lead-based paint hazards. Parties may mutually agree, in writing, to lengthen or shorten the time period for inspection. Homebuyers may waive this inspection opportunity. If you have a concern about possible lead-based paint, you may secure a lead inspection from a certified inspector before buying.


Federal law requires that before signing a lease for housing built before 1978, renters must receive the following from your landlord:

  • An EPA-approved information pamphlet on identifying and controlling lead-based paint hazards, Protect Your Family From Lead In Your Home.
  • Any known information concerning the presence of lead-based paint or lead-based paint hazards in the home or building.
    • For multi-unit buildings, this requirement includes records and reports concerning common areas and other units when such information was obtained as a result of a building-wide evaluation.
  • An attachment to the contract, or language inserted in the contract, that includes a “Lead Warning Statement” and confirms that the landlord has complied with all notification requirements.

Property Managers and Landlords

As owners, landlords, agents, and managers of rental property, you play an important role in protecting the health of your tenants and their children. Buildings built before 1978 are much more likely to have lead-based paint. Federal law requires you to provide certain important information about lead paint before a prospective renter is obligated under lease to rent from you.

Landlords must give prospective tenants of buildings built before 1978:

  • An EPA-approved information pamphlet on identifying and controlling lead-based paint hazards, Protect Your Family From Lead In Your Home.
  • Any known information concerning lead-based paint or lead-based paint hazards pertaining to the building.
    • For multi-unit buildings this requirement includes records and reports concerning common areas and other units when such information was obtained as a result of a building-wide evaluation.
  • A lead disclosure attachment to the lease, or language inserted in the lease, that includes a “Lead Warning Statement” and confirms that you have complied with all notification requirements.

Real Estate Agents and Home Sellers

As real estate agents and home sellers, you play an important role in protecting the health of families purchasing and moving into your home. Buildings built before 1978 are much more likely to have lead-based paint. Federal law requires you to provide certain important information about lead paint before a prospective buyer is obligated under a contract to purchase your home.

Real estate agents must:

  • Inform the seller of his or her obligations under the Real Estate Notification and Disclosure Rule. In addition, the agent is responsible if the seller or lessor fails to comply; unless the failure involves specific lead-based paint or lead-based paint hazard information that the seller or lessor did not disclose to the agent. Read the regulations that includes these requirements.
  • Provide, as part of the contract process, an EPA-approved information pamphlet on identifying and controlling lead-based paint hazards titled Protect Your Family From Lead In Your Home. Attach to contract, or insert language in the contract, a “Lead Warning Statement” and confirmation that you have complied with all notification requirements.
  • Provide a 10-day period to conduct a paint inspection or risk assessment for lead-based paint or lead-based paint hazards. Parties may mutually agree, in writing, to lengthen or shorten the time period for inspection. Homebuyers may waive this inspection opportunity.

A copy of the pamphlet Protect Your Family From Lead In Your Home is available at:


For information on the federal Lead-Based Paint Renovation, Repair and Painting Rule see my August 30, 2017 Wladis Law Firm Blog Post.

Kevin C. Murphy is a member of the Wladis Law Firm, P.C., located in Syracuse, New York. Should you be confronted with lead paint or lead paint renovation issues, please feel free to contact Attorney Murphy or Attorney Timothy Lambrecht of the Wladis Law Firm to determine if we can be of assistance to you. 


Kevin Murphy

Kevin C. Murphy concentrates his practice in the areas of environmental compliance and litigation; environmental and white-collar criminal defense, and complex litigation matters. Mr. Murphy is a graduate of the University of Virginia School of Law and a former senior trial attorney with both the Kings County (NY) District Attorney’s office and the U.S. Department of Justice Environmental Crimes Section in Washington, D.C. He previously taught a seminar on environmental criminal enforcement at the Syracuse University School of Law and has been listed in The Best Lawyers in America.

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Sing It, Celine. My Heart Will Go On.

February 14 is fast upon us and you fall into one of two camps: you either agree with the J. Geils Band that love stinks, or you are all about the chocolate and sweet nothings. History books will record the great NECCO Conversation Heart Tragedy of ’19, when the elementary school classic took a year off after the company changed hands. I’m not really sure how to ask you to be mine if I can’t do it with a peachy hued little gem of tooth-cracking pasty sugar with blurry words printed on it. These Dysfunctional Valentine Hearts appeal to my sense of humor.

When my older daughter was a pre-school age, her wonderful daycare provider was having a little Valentine party for the kids. My friend Marilyn and I joked about how we were going to out-supermom each other, and I spent hours late at night after my kids were asleep doing crafts (I am NOT a craft person) but I am pretty sure I won. These little felt pouches held Hershey kisses and little notes for each kid. I won, right?

All of this is the intro to what I really want to talk about today – not love and Valentines, but hearts. More particularly, heart health.

Do you know the difference between cardiac arrest and a heart attack? Did you think they were the same thing? (It’s ok to admit that, I think lots of people confuse the two).

Simply, cardiac arrest is an electrical problem and a heart attack is a circulation problem. With cardiac arrest, irregular heartbeat disrupts the heart’s pumping action and blood can’t get to the brain and other organs.

With a heart attack, a blockage in an artery prevents blood flow within the heart. Even though they are different health events, they are connected in that heart attacks can sometimes lead to cardiac arrest.

You have probably heard that heart attacks present differently in women than they do in men, but do you know the difference? For women, signs include nausea and vomiting, back or jaw pain, and a little thing called shortness of breath. If you (like me!) thought that shortness of breath was like that feeling after you just ran the Corporate Challenge and are totally out of breath, you are wrong. Shortness of breath actually feels like you can’t take deep breaths (I know this first hand, it’s ok to ask me next time you see me, and no, I did not have a heart attack). For men, it’s more like Redd Foxx on Sanford & Son – “I’m coming, Elizabeth!” with the sudden onset and intense chest pain (plus shortness of breath, nausea, etc.).

Whether it’s cardiac arrest or a heart attack, the first thing to do is call 911. The sooner medical intervention starts, the more likely it is that the person will have a positive outcome. I strongly encourage you to learn CPR so that if you ever find yourself in a situation where that skill is needed, you will be prepared. If you are reluctant because you still think of CPR as including mouth-to-mouth resuscitation, I have great news for you – we have gone the way of hands only CPR. Many places of business have AED devices (Automated External Defibrillators) and the machines literally talk you through each step so even if you are completely flustered by the situation, the robot voice will still help you help someone having cardiac arrest.

If you have a family history of heart disease, or if you have risk factors like smoking, poor diet, and lack of exercise, you can still take control of your health and start some heart-healthy habits to reduce your overall risk of cardiac arrest or heart attack. You should always talk to your doctor first, but changes to your diet (more leafy greens, fewer Baconator sandwiches at the Fair) and an exercise regimen will go a long way toward helping YOU go a long way in life. Your friends, family, and your lawyer all agree – you’re worth it.

Jennifer Granzow

Ms. Granzow holds a JD from the Syracuse University College of Law. Her practice is concentrated in the areas of business and corporate law, real estate, economic development, and government relations, with an emphasis on grants and public funding.

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Wetlands: Part Two. New York State Regulation of Wetlands.


My last blog entry discussed what wetlands are and why they are so important.  This blog entry talks about how they are regulated in New York State.

Wetlands are regulated by State and Federal law.   Federally, wetlands are protected by the U.S. Army Corps of Engineers (“ACOE”) under Section 404 of the Clean Water Act. In New York, they are protected under the Freshwater Wetlands Act (“FWA”) of 1975.  The implementing regulations of the FWA are at 6 N.Y.C.R.R. Parts 663 – 665.

The NYS Department of Environmental Conservation (“DEC”) regulates freshwater wetlands “to preserve, protect and conserve” them and their benefits.  DEC classifies them at Part 664.5 into four categories: I, II, III or IV.  Class I wetlands are the most valuable.  They often feature habitat of endangered or threatened species and, therefore, are the most protected.  Class IV are the least valuable and least protected.

Not every wetland is regulated under State law.  To be protected, a freshwater wetland must be 12.4 acres or larger, except in the Adirondack Park, where a lower threshold applies.  Smaller wetlands may be protected, too, but only if they are considered of unusual local importance.  Around every wetland is an “adjacent area” of 100 feet.  This adjacent area also is regulated to provide protection for the wetland.

Basically, DEC regulates certain activities in freshwater wetlands to prevent or mitigate impairment of wetland functions.  The amount of regulation turns on the nature of the activity and its potential effect on a wetland.

For instance, activities like normal agricultural practices, harvesting of natural products and recreational activities (fishing, hunting, trapping, hiking, swimming, picnicking, or firewood collection) or routine maintenance (e.g., dock repair) are exempt from regulation.  More invasive activities, which can adversely impact a freshwater wetland, are regulated.  These activities typically include actions like construction, excavation, placement of fill, drainage, clear-cutting and application of pesticides and require a permit under the FWA.

If you plan to engage in a regulated activity and suspect you are near a regulated wetland, you need to know if you must have a permit.  One way to find out is to review the DEC’s wetland maps and find your property.  Check whether it is in, near or adjacent to a protected wetland. Remember that not all wetlands are protected by DEC, but most wetlands will come under the jurisdiction of the ACOE, whether protected by DEC or not.

If your property has a protected wetland on or near it, or your project looks like it comes within the area adjacent to the wetland, you may want to contact the DEC Regional Office where the property is located and request DEC to visit your site and mark the wetland boundary.  You can hire a private consultant as well, but there likely will be a fee.

If your project involves a regulated activity, and it is within a freshwater wetland area, you will need a permit from DEC.  Essentially, DEC’s permit standards require that impacts to wetlands be avoided and minimized, where possible.  If the activity you propose will not seriously affect the wetland, then absent extenuating circumstances, DEC likely will issue a permit, possibly with various conditions.  If your proposed activity will seriously affect the wetland, the benefits gained by allowing the action to occur must outweigh the wetland benefits lost before a permit can be issued.  DEC often requires compensatory mitigation for significant impacts to wetlands before a permit can issue, such as creating or restoring wetlands to replace the benefits lost by the proposed project’s impact on the nearby wetland.

Getting a permit can be a tricky thing.  In my next blog entry, I’ll discuss the permit application process.


Picture: www.lindenhurst-village.com


Making Time for What Matters Most


In less than two weeks, the New York State Fair will open its annual twelve day run and families from all over New York and beyond will flock to see the incredible new improvements to the fair facilities, ride the latest gravity defying roller coaster, see the exhibits and animals, and gorge themselves on a smorgasbord of fried foods and lemonade.  It’s a tradition that we all look forward to, and a great opportunity for parents and their kids to share some time together.

The closing of the State Fair also brings an end to summer vacation, time for the kids to put away their sandy flip flops in favor of new sneakers and get on the bus for a brand new year of school.  This summer’s end ritual is a time when all of us with school aged children fall back into the routines we gleefully abandoned in June.  It’s time to set the alarm a little earlier, time to pack lunches, time to make sure the library books make it into the backpacks and that the homework planners get signed so your child can get a sticker from her teacher.

Our Central New York summers are short, and we cherish the time to be outdoors, to swim at Green Lakes, hike around Clark Reservation, and attend a Syracuse Chiefs game or go pick up fresh sweet corn from a roadside stand. Not bogged down by homework and sports practice, dance lessons and violin practice, we have more time to spend with our families, seeking and finding joy in achieving the perfect toasty marshmallow to go on our s’mores, and seeing all sorts of crazy shapes in the puffy clouds above hammocks strung between backyard trees. Summer is a blissful, magical time that we snowbelt dwellers crave the other nine months of the year.

It is also a reminder that just as summer comes and goes away again before we have even finished saying a proper hello, childhood too slips away despite our protests to stay, please stay little. Please don’t ever stop saying psgetti, please always want to clutch your well worn teddy bear to get to sleep at night. Years ago, I read a card that said something to the effect of “We had a very disappointing experience with our children.  They grew up.”  That resonated with me then, and it does now as my own children continue their march onward.

The time we spend with our children is never wasted time. They challenge us, they help us to grow, they fill our hearts with love we never knew we could feel.  They are watching our every move, absorbing, taking it all in.  Show them that they are your priority – put the phone down, turn off the tv. Read together, play catch together, sit on the sideline beaming with pride and cheering them on. Take them for ice cream even if they barely touched their green beans at dinner tonight. Learn “the new math”, which is really not so different from the old math, while you help them with homework. Help them build the best baking soda and vinegar volcano to ever grace a fourth grade science fair. When you make time for them, you are making time for you, too. We glorify the concept of “busy”, but the reality is all of us can make the time for the things that really matter to us. Budget your time – return the emails after your kids are asleep, instead of meeting a client for a drink after work, how about meeting for breakfast after the kids are on the bus?  The saying goes “the days are long but the years are short” – make the most of this precious, fleeting time with your family and you will reap the rewards in every single aspect of your life.


Mark Wladis

Mr. Wladis, founder of the firm, holds both a JD and an LLM in taxation from the Syracuse University College of Law. His practice is concentrated in the areas of business and corporate law, taxation, economic development, and government relations, and he represents individuals and entities across New York State. He serves as chairman of the board of directors of Success by 6 and has served on the boards of directors of a number of other local organizations.

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Utilizing Testamentary Trusts


Many clients are concerned about the son-in-law and daughter-in-law divorcing their child and walking away with a big chunk of their estate. And why shouldn’t they worry? The divorce rate in America is unfortunately still at a very high level. Parents also worry that someone will target their kids for get-rich-quick schemes, foolish financial investments, or even some well-planned scam. There is the real prospect that your kids could get sued for any sort of civil action and a judgment creditor could walk off with your estate. There is also the situation where a parent isn’t so sure their child could handle inheriting a large amount of money and be left to their own devices.

When you give the inheritance outright to your children after you’re gone, there is nothing you can do to protect those assets or your children. The assets are fair game once control passes from the parent’s estate into the hands of the children. Yet almost every estate plan drafted the traditional way delivers the assets straight into the hands of the children regardless of whether the child is ready for that wealth or not. This is what is commonly referred to as Divide, Dump, and Dissipate. This may conjure images of little Johnny buying that new Maserati instead of smartly investing his money to save up to buy a house.

How can parents make sure that their children do not foolishly waste their inheritance? One option is to provide for a testamentary trust in their Wills. Trusts may make you think of the Rockefellers of the world, but in fact they are a commonly used planning instrument. Say Jane and Joe have 2 kids, ages 21 and 23. Between them, Jane and John have a $1 million estate, with life insurance and retirement accounts included. Hopefully this will continue to grow, but say Jane and John pass away today. With their current estate plan, their two children will each receive $500,000 directly into their bank accounts. Now the children are free to use their inheritance on anything they so choose. The money will also be subject to any divorce proceeding or creditor judgment that may come up in the future.

If the parents provided for a trust to hold the money until the children reached a certain age, say 35 years old, along with an Independent Trustee to make distributions to the children when prudent, the money would be fully creditor protected, which means it would not be subject to divorce judgments or creditor judgments. The Independent Trustee should be a party that shares the parents’ philosophies concerning money management and should be someone that they trust to do the right thing.

Utilizing testamentary trusts is a simple and worthwhile way to ensure that the money you want your children to use in bettering their lives is actually used for that purpose. To discuss this and your other estate planning goals further, contact the attorneys at The Wladis Law Firm.

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course, we not working as much, and so I think we not as stressed as we were in Sydney. The kids probably benefit from that. Bureau of Statistics data canada goose outlet in uk showed 11,490 people moved from NSW to the Sunshine State in the three months to September, with another 7239 canada goose clearance uk residents relocating to Victoria.

It mirrors results from the July quarter, where 12,802 people moved from NSW to Queensland and 8126 south to Victoria.

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ABS data shows thousands of people canada goose outlet are leaving Sydney each month, with canada goose shop austria most heading north to Queensland. Picture: AAPSource:AAP

A new survey has found 23 per cent of Millennials would move interstate in order to be able to buy their first home or upgrade to a bigger one.

takes almost double the time to save a deposit in Sydney as it does in Brisbane, and it a similar story in Adelaide, Perth, Hobart and Darwin.

By comparison, Brisbane median price of $489,832 would need $66,770, which would take three years and one month to build up, Ms Tindall said.

canadian goose jacket can afford a nice family home without having nothing left over. It gives people breathing space and financial options that you might not get in Sydney and Melbourne. Picture: Dilvin YasaSource:Supplied canadian goose jacket

People from Sydney were the most likely to consider moving for the sake of housing affordability, with 32 per cent of Harbour City residents open to uprooting their lives, she said.

uk canada goose have come down in Sydney, but even with that, it still hard to get on the ladder, Ms Tindall said. uk canada goose

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