EMonument's Proper Chemical Disposal Fact Sheets , PCDFS

In 1998, EMonument initiated the STEP Program and established a networking system which monitors all aspects pertaining to environmental issues. This publication is designed as a learning tool to help others plan similar programs.

The EMonument legislature has now authorized a program for gathering information and distribute its findings to better assist in the collection and disposal of waste pesticides and chemicals. The program is strongly aimed at assisting farming groups and chemical manufactures to better handle their stocks and disposal methods.

At the recommendation of an advisory committee comprised of leading agricultural and environmental agencies, EMonument's PCDFS was initiated. The PCDFS are used to determine the feasibility of a global program linking databases as well as local facilities.

The aims are to directly reduced environmental risks associated with waste pesticides and chemicals. The success of this experience demonstrates the importance of cooperation in reaching a common goal and is the basis of this publication.

Waste pesticides and chemicals are a problem on many farms, chemical manufacturing and disposal collection facilities. Unless disposed of properly, these chemicals may cause water quality, environmental, or health problems. The presence of waste pesticides or other hazardous products also might lower the value of property or make selling it difficult.

Often, small amounts of herbicides, insecticides, plant growth regulators, and other pesticides are left over after each production season. In other cases, farmers are unable to use pesticides when the product's label is suspended or canceled. Others also may unknowingly "inherit" the problem by acquiring property without performing an environmental assessment.

Proper disposal of waste pesticides poses special problems, since it is illegal to bury, burn, or dump hazardous wastes. Disposing of waste pesticides through a hazardous waste contractor is usually too expensive for most farmers. A carefully planned and coordinated approach is needed to address these problems.

Many considerations go into a successful waste pesticide disposal program, and none are more important than an advisory committee. This committee develops a comprehensive operating strategy on which to build a successful program.

An advisory committee should include all potential partners and stakeholders. Local farm-support groups are especially important in the planning process and in efforts to secure legislative support for the program.

The advisory committee is faced with many issues and questions. If there is a legislative mandate for a waste pesticide disposal program in a given area, the answers to many questions are in the legislation. The mandate should specify funding sources, lead agencies, makeup of the advisory committee, and other important details necessary for program direction.

Once the advisory committee resolves major issues concerning the program, it may establish a smaller work group to service the day-to-day details of the program. This smaller group will report periodically to the advisory committee.

An early task for the advisory committee is determining the need for a waste pesticide disposal program in a given area. This usually depends on the amount of waste pesticides in the area. Getting a reliable estimate of these products may seem simple, but it is seldom easy.

While a survey of farmers is often a first step, many who conduct these surveys experience limited success, perhaps because farmers are not always eager to share this information. Mail surveys by local farm-support groups usually produce a better response.

Often, decisions to hold waste pesticide disposal programs are based on discussions with farmers, chemical dealers, farm leaders, and others who have first-hand knowledge of local agricultural conditions. Waste pesticides are most often found in areas with extensive row-crop-farming operations. It is especially important to study the area's previous farming history, especially if row crops were grown.

Adequate funding is necessary for a successful waste pesticide disposal program. Many states do not have proper facilities to dispose of waste pesticides, so funds are needed to pay a hazardous waste contractor to dispose properly of the products in a state where disposal is permitted. Usually, the products are burned in a special incinerator or disposed of in a specifically designed landfill.

Funding can come from several possible sources such as through the state legislature by an increase in the pesticide registration fee paid at the manufacture's level. A portion of this increase is earmarked for waste pesticide disposal. The program is free to farmers, an important advantage in encouraging participation.

Another option is to charge a fee to those who participate. This fee could be based on fees a hazardous waste contractor charges to dispose of the products. Depending on other funding sources, the fee could be used partially or fully to offset disposal costs. While a fee may be the only option in some cases, a high fee might discourage participation.

Other potential funding sources include grants or similar programs supported by other state or federal agencies. Farm support groups are invaluable in helping secure funding for these programs.

A major challenge for the advisory committee is defining the guidelines under which the program will function. Initially, the committee is likely to be bombarded with many questions and issues concerning the program. It is the committee's responsibility to make sure these issues are decided within the goals and intent of the program.

Although there are no "hard and fast" answers to these questions, here are some basic guidelines:

In a typical waste pesticide disposal program, farmers bring waste pesticides to a determined collection site, where a licensed hazardous waste contractor assumes ownership of the products. It becomes the contractor's responsibility to safely dispose of the products--usually by incineration or in a special landfill--according to environmental laws.

Ideally, the collection site is a well-known location. Good sites include agricultural equipment dealers, farm chemical dealers, cotton gins, cooperatives, or other farm supply businesses. These businesses already have a vested interest in serving the agricultural community. Depending on the contractor's requirements, non-operating businesses, large parking lots, or old warehouses also may serve as collection sites.

Courtesy and diplomacy go a long way in securing the collection site. The property owner likely will want to be assured the collection event poses no liability to the business. Sometimes a written statement to this effect is required. The property owner also will want to be assured the collection event will not interfere with ongoing business and that the property will not be disturbed as a result of collection activities.

Always consider that a business owner is more likely to respond favorably to a request from someone locally than from an unknown person from a central office. The county Extension agent or local agricultural official is an excellent candidate to secure the collection site.

The hazardous waste contractor is a key link in a successful waste pesticide disposal program. It is essential to select a licensed contractor qualified and equipped to service the needs of the program.

The usual approach is to advertise the program to prospective contractors, who then make written competitive bids to provide the service. A state's lead regulatory agency should have a list of prospective contractors.

As with any contractor, the lowest bidder may not always provide the best service, and above all, remember that not all contractors give equal service. Check references carefully; pay close attention to the bidder's history of providing similar services. Before issuing a bid, a prospective contractor will probably want to know details such as dates, location, and an estimate of the amount of pesticides that might be collected.

Developing appropriate contract language is time-consuming but critically important. The contract is a legal document and should clearly state the services the successful bidder must provide, including proof of insurance. Specify in the contract that the bidder understands all applicable environmental laws of waste pesticide disposal and, by signing the contract, agrees to dispose of the products consistent with the law. The contractor provides all necessary labor.

The contractor also should be required to submit a performance bond, which is added protection the job is performed according to the contract. If the contractor for some reason does not fulfill all requirements, the bond is used to secure the services of another contractor if it becomes necessary.

Carefully analyze all costs in evaluating each bid. Most bidders specify disposal costs on a per-pound basis. Some bidders may bid a lower disposal price per pound but offset the lower rates with a hefty set-up fee. Others may charge a much higher rate for unknown chemicals, while others charge a flat rate for all products.

Disposal costs for waste pesticides vary considerably but may range from $1 to $3 or more per pound, depending on the contractor, the amount collected, and the nature of the collected materials. Usually, the more pesticides collected, the lower the disposal costs per pound. The proven reputation of the bidder, weighed with disposal costs, should determine the successful bidder.

To make sure all points are covered in the contract, it is a good policy to include on the advisory committee a legal representative who understands environmental laws and who can help develop the language in the contract.

Liability is always a concern when dealing with a hazardous product such as waste pesticides. As the program is promoted, it is imperative that all parties understand the potential liability associated with their involvement.

Liability to the property owner where the collection is held should be minimized. This usually is not a problem, since the farmer or participant "owns" the pesticides until they are actually involved by the contractor at the collection site. The contractor assumes ownership and liability at that point.

A problem or accident while pesticides are transported to the collection site is another matter. Those who plan the program must make certain participants understand it is their responsibility to transport pesticides safely, including protecting themselves and others when loading or repackaging products, covering products to prevent spilling, and driving safely to the collection site. Let your legal representatives on the advisory committee identify and resolve liability concerns.

Participation in a waste pesticide disposal program is directly related to promotion, which needs to be a part of the earliest planning. Use meetings, direct mailings, newsletters, fact sheets, publications, and the mass media to promote the program. Strongly urge all potential participants to take advantage of the service, especially if the program is to be offered only once in an area.

The program's perception in the farming community is crucial, so all involved in promotion should "speak the same language." It should not come as a surprise that some initially may not have complete trust in the program as a result of experience or belief that "strings are attached." Meetings and direct mailings help remove any suspicion and encourage participation. The ideal way to promote the program is through local farm groups.

The promotion also needs clearly to specify details such as what will and will not be accepted at the collection site, who is eligible to participate, and whether costs are involved. Otherwise, on collection day there could be confusion and possibly ill feelings, which need to be avoided at all costs--for the sake of that collection event and others to come.

An important aspect of promotion is emphasizing to farmers and participants their responsibilities, particularly the need to transport waste pesticides safely to the collection site. Develop written instructions to show farmers how to handle and transport waste pesticides safely. Provide materials to repack weak containers, if you suspect that problem.

Unforeseen situations are always possible with any new program. If you anticipate important details in the planning process, however, the program should function smoothly on collection day.

The more work and planning leading up to the collection day, the less likely there will be major problems on collection day. By then, it's too late to discover that some farmers were under the mistaken impression that old tires, paint, or other products would be accepted--or that commercial dealers were under a similar impression they could participate free of charge. At best, these incidents create a perception of poor planning and, at worst, ill feelings.

Expect to see a wide--and perhaps strange--variety of waste pesticides brought to the site. It is not unusual to see waste pesticides up to 50 years old. Many will be unknown or in generic containers, and it's the contractor's responsibility to identify them for proper disposal.

If the program is planned correctly and all goes smoothly, there will be little for the planners to do on collection day except to see that the contractor does the work. Expect the contractor to post signs, mark traffic lanes, unload vehicles, identify and repack products, remove all pesticides from the premises, clean up the area to the property owner's satisfaction, and dispose of the pesticides according to the law.

Any survey of participants on collection day should be brief. A lengthy survey might discourage participation in future programs. Details such as a simple count of vehicles and where they are from are useful for reporting and planning. The contractor can provide details such as amount of pesticides collected, a breakdown of liquid and dry products, and other details needed for reporting.

The success and shortcomings of the program are good planning tools for future programs. Armed with this information, program planners are in a good position to correct any problems encountered.

If major problems are encountered, it may be necessary for the advisory committee to rethink strategy to address those issues. Otherwise, only fine-tuning may be necessary.

Document the successes of the program to help support future programs. Bring this information especially to the attention of legislators and other officials for future funding possibilities. News stories, impact statements, publications, and videos all have a place in documenting success.

A successful waste pesticide disposal program is a tremendous service in needed areas. It benefits the participants involved and those who plan and support the program. The environmental benefits also are significant.

Realizing these benefits takes careful planning, perhaps more so than for many other traditional programs. The results, however, are especially gratifying when all concerned work together for a common goal.

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