1. Development of a National Pesticide Container Recycling Standard Pesticide Applicator Certification and Safety Education Workshop August 18, 2005 Nancy Fitz, U.S. EPA Larry Schulze, Univ. of Nebraska-Lincoln

2. Overview Current status of pesticide container recycling Current status of pesticide container recycling Development of a national consensus standard on pesticide container recycling Development of a national consensus standard on pesticide container recycling Discussion Discussion

3. Status: What is the ACRC? The Ag Container Recycling Council (ACRC) was formed in 1992 to manage the collection and recycling of one-way HDPE (plastic) crop protection and other pesticide containers. The Ag Container Recycling Council (ACRC) was formed in 1992 to manage the collection and recycling of one-way HDPE (plastic) crop protection and other pesticide containers. The ACRC is a non-profit organization funded by members of CropLife America. The ACRC is a non-profit organization funded by members of CropLife America. ACRC’s annual budget is $3.99 million. ACRC’s annual budget is $3.99 million. ACRC sampled collected plastic to determine residues; use this data in risk assessment model to determine acceptable end uses for the plastic. ACRC sampled collected plastic to determine residues; use this data in risk assessment model to determine acceptable end uses for the plastic.

4. Status: Which containers are recycled by ACRC? Plastic: High density polyethylene (HDPE) - #2 Plastic: High density polyethylene (HDPE) - #2 Containers that held insecticides, herbicides, fungicides, stickers, spreaders, anti-foaming agents, crop oils, and micro-nutrients. Containers that held insecticides, herbicides, fungicides, stickers, spreaders, anti-foaming agents, crop oils, and micro-nutrients. Size: A few ounces to 55-gal drums. Size: A few ounces to 55-gal drums. Accept containers from: Accept containers from: Farmers who grow food, fiber and ornamentals. Farmers who grow food, fiber and ornamentals. Forest, lawn care, right-of-way, golf course and structural pest control applicators. Forest, lawn care, right-of-way, golf course and structural pest control applicators.

5. Status: Amount Collected per Year

6. Status: ACRC Results Since 1992, more than 74 million pounds of plastic have been safely recycled. Since 1992, more than 74 million pounds of plastic have been safely recycled. Consistently collect over 6.5 million pounds per year; almost 8 million in 2004. Consistently collect over 6.5 million pounds per year; almost 8 million in 2004. More than 80 cents of every dollar is spent directly on collecting containers. More than 80 cents of every dollar is spent directly on collecting containers. End uses include field drain tiles, speed bumps, parking stops, treated lumber substitutes for low-exposure outdoor applications (marine pilings, fence posts, etc.) End uses include field drain tiles, speed bumps, parking stops, treated lumber substitutes for low-exposure outdoor applications (marine pilings, fence posts, etc.)

7. Status: Current Challenges Non-level playing field: ACRC collects all industry plastic, even that belonging to non-members. In 2004, a CLA member resigned because of this. Non-level playing field: ACRC collects all industry plastic, even that belonging to non-members. In 2004, a CLA member resigned because of this. ACRC’s budget of $3.99 M can pay for a certain amount of plastic (around 8 million lbs.) Higher collection rate in 2005, so some collections cut off before end of year. ACRC’s budget of $3.99 M can pay for a certain amount of plastic (around 8 million lbs.) Higher collection rate in 2005, so some collections cut off before end of year. ACRC is investigating more economical methods of collecting plastic in areas of low container concentration. ACRC is investigating more economical methods of collecting plastic in areas of low container concentration.

8. Consensus Standard: Background American Society of Agricultural and Biological Engineers (ASAE) is an accredited standard- setting organization American Society of Agricultural and Biological Engineers (ASAE) is an accredited standard- setting organization Goal: develop a standard for safely and effectively recycling plastic pesticide containers Goal: develop a standard for safely and effectively recycling plastic pesticide containers Focused on the technical/process/safety aspects Focused on the technical/process/safety aspects Based on 10+ years of ACRC’s experience recycling agricultural pesticide & pesticide- related product containers Based on 10+ years of ACRC’s experience recycling agricultural pesticide & pesticide- related product containers

9. Consensus Standard: Committee Co-chairs: Nancy Fitz (EPA) and Johnny Berry (Syngenta) Co-chairs: Nancy Fitz (EPA) and Johnny Berry (Syngenta) Facilitator: Russ Hahn (independent) Facilitator: Russ Hahn (independent) Ag engineers: DuPont, Ohio State, USDA, VA Tech Ag engineers: DuPont, Ohio State, USDA, VA Tech AAPCO/SFIREG: AZ, NE, NY AAPCO/SFIREG: AZ, NE, NY AAPSE: GA, NE AAPSE: GA, NE ACRC: Chair, ex-chair of technical committee, communication lead, container manufacturer, technical expert ACRC: Chair, ex-chair of technical committee, communication lead, container manufacturer, technical expert ASAE: Ex Officio participant ASAE: Ex Officio participant CLA: Stewardship chair CLA: Stewardship chair CPDA: President + 3 companies CPDA: President + 3 companies EPA: OPP & OSW EPA: OPP & OSW

10. Consensus Standard: Scope of Draft Standard Scope Scope Plastic (HDPE) nonrefillable containers up to 56 gal. Plastic (HDPE) nonrefillable containers up to 56 gal. Pesticides labeled for agriculture, forestry, vegetative management, and structural pest control and pesticide-related products (adjuvants such as crop oils, stickers, spreaders, and surfactants) Pesticides labeled for agriculture, forestry, vegetative management, and structural pest control and pesticide-related products (adjuvants such as crop oils, stickers, spreaders, and surfactants) These are containers that CAN safely & effectively be recycled according to the standard. These are containers that CAN safely & effectively be recycled according to the standard. Not saying that these containers MUST be handled according to the standard. Not saying that these containers MUST be handled according to the standard.

11. Consensus Standard: Draft Standard Standard will define “processes” with necessary safeguards: Standard will define “processes” with necessary safeguards: Rinsing Rinsing Preparing rinsed containers Preparing rinsed containers Collection Collection Inspection Inspection Rejecting unacceptable containers Rejecting unacceptable containers Volume reduction (e.g., granulation) Volume reduction (e.g., granulation) Transportation Transportation Storage Storage Processing Processing Determining acceptable end-use products Determining acceptable end-use products Manufacturing end-use products Manufacturing end-use products Recordkeeping Recordkeeping

12. Consensus Standard: Schedule April/May: Created committee with broad representation April/May: Created committee with broad representation May 24: Intro conference call May 24: Intro conference call June 20-21: Meeting to discuss strawman document June 20-21: Meeting to discuss strawman document July 7: Meeting to finish discussing strawman document July 7: Meeting to finish discussing strawman document Late July: Circulate revised draft standard Late July: Circulate revised draft standard August: Email/conference call discussion August: Email/conference call discussion September: Meeting to finalize document September: Meeting to finalize document December: Complete ASAE review process December: Complete ASAE review process

13. Consensus Standard: Implications The standard will establish a baseline for how to recycle plastic pesticide containers safely and effectively (e.g., if new organizations or companies start recycling programs). The standard will establish a baseline for how to recycle plastic pesticide containers safely and effectively (e.g., if new organizations or companies start recycling programs). By itself, the standard will not solve the current challenges. By itself, the standard will not solve the current challenges. Once approved, the ASAE standard will be a tool that state/federal policy makers could use. Once approved, the ASAE standard will be a tool that state/federal policy makers could use.

14. Consensus Standard: More Info ACRC program ACRC program http://www.acrecycle.org/ http://www.acrecycle.org/ ASAE ASAE http://www.asae.org/ http://www.asae.org/ ASAE Container Recycling Standard (X596) ASAE Container Recycling Standard (X596) Nancy Fitz, 703-305-7385, fitz.nancy@epa.gov Nancy Fitz, 703-305-7385, fitz.nancy@epa.gov

15. Discussion What are the biggest issues you see with pesticide container recycling? What are the biggest issues you see with pesticide container recycling? Is the scope of the draft ASAE standard appropriate? Is the scope of the draft ASAE standard appropriate? Are the processes/steps in the draft standard appropriate? Are the processes/steps in the draft standard appropriate? Other suggestions or feedback? Other suggestions or feedback?