Pesticide Container Recycling TPSA conference 2019, Savannah GA Clinton Shocklee
Agenda • Empty pesticide container recycling overview • Label requirements • Definition of triple rinsed • Hazardous Waste • What is RCRA empty • What options are available to recycle/dispose of empty non rinsed pesticide containers?
Disposal of Pesticides EPA overview The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) governs the sale, distribution and use of pesticides in the United States. Pesticides are regulated under FIFRA until they are disposed, after which they are regulated under the Resource Conservation and Recovery Act (RCRA), which ensures responsible management of hazardous waste and non-hazardous solid waste. Pesticide Container Regulations The pesticide container regulations establish standards for pesticide containers and repackaging as well as label instructions to ensure the safe use, reuse, disposal and adequate cleaning of the containers. Pesticide registrants and refillers (who are often distributors or retailers) must comply with the regulations, and pesticide users must follow the label instructions for cleaning and handling empty containers. * Always check local and state regulations as well before proceeding with pesticide container disposal. (I.e. Washington)
FIFRA • FIFRA Label requirements • Example(s) of FIFRA label & guidelines • http://www.cdms.net/ldat/ld7A9004.pdf • http://www.cdms.net/ldat/ld95T000.pdf • Grower is required if stated on label to triple rinse the container at point of use. • Some labels allow option of contacting registrant to handle recycling/disposal. • Definitions of triple rinsed • Triple rinsing procedure (EPA) • Safely cleaning and preparing large pesticide containers for recycling • https://tpsalliance.org/pdf/mini- bulk/TPSA_Safety_Cleaning_Cont_FINAL.pdf
The Resource Conservation and Recovery Act (RCRA) RCRA protects communities and resource conservation. To achieve this, EPA develops regulations, guidance and policies that ensure the safe management and cleanup of solid and hazardous waste, and programs that encourage source reduction and beneficial reuse. • Definition of RCRA empty (EPA) • A container or an inner liner removed from a container holding nonacute hazardous waste as identified in Part 261, Subpart D, is empty when: • all wastes have been removed using practices commonly employed industry-wide toremove wastes from containers or liners, such as pouring, pumping, aspirating, and draining (§261.7(b)(1)(i)), and • no more than 2.5 centimeters (1 inch) of material remains in the container or liner(§261.7(b)(1)(ii)), or • no more than 3 percent by weight of the container remains for containers with a capacityof 110 gallons or less, and no more than 0.3 percent by weight remains for containers with a capacity greater than 110 gallons (§261.7(b)(1)(iii)).
RCRA • Identifying Hazardous Waste • https://www.epa.gov/hw/criteria-definition-solid-waste- and-solid-and-hazardous-waste-exclusions
Environmental, • Consider the following areas of risk when deciding where to send a pesticide container for Health, and recycling/disposal. Safety • Does the site have required permits or authorizations. Assessment • Does the site have proper worker training, equipment, and PPE top ensure safe processing. • Waste management practices • Does the site have past compliance issues or violations
Question: A retailer has a RCRA empty non refillable Non Rinsed pesticide container, the previous product is non Containers hazardous, but the container is not rinsed. How can this container be recycled/disposed of compliantly? Answer: The container would be considered non hazardous solid waste (per RCRA) and could be disposed of as such. Sent to a municipal solid waste landfill or equivalent. Keep in mind the retailer or the disposal contractor will need to triple rinse the container. * Always check local and state regulations as well before proceeding with pesticide container disposal. (I.e. Washington)
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