Pesticide Storage And Disposal

Another facet of our business being impacted by regulations is the area of pesticide storage and disposal. Regulations, mandated by Congress in 1988, are being drafted and will have far-ranging effects on the way pesticide containers are packaged, handled, stored and disposed. The 1988 amendments to Section 19 of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)significantly expanded the EPA’s authority to regulate all aspects of pesticide handling and disposal. The amendments also ended a requirement that the EPA must accept suspended or canceled pesticides for disposal and directed the agency to develop container design regulations encouraging "safe use, safe refill, and safe disposal." The proposed changes to FIFRA will be published under 40 CFR Part 165.

IMPACT ON THE INDUSTRY. The regulations affect manufacturers, distributors and end users. Manufacturers will have to design containers for liquids and solids that meet EPA specifications for rinsing ease, storage and disposal.

With liquid insecticides, in particular, the manufacturer will be encouraged to develop easy-rinse and refillable containers. The tests to "encourage" these designs are being funded by the EPA, and select container manufacturers. Triple rinsing will be a requirement for any disposed, recycled or refillable container. Triple rinsing has demonstrated the ability to remove 99.999 percent of pesticide residues from containers.

Rinsing these containers will be the responsibility of the end user and PCOs will have to assure that proper procedures are followed. There also will be some sort of "testing" procedure to determine if the container has been properly triple rinsed. There already are some quick, colormetric tests on the market that measure pesticides in parts per million.

AN INTERESTING EXERCISE. The next time you walk into your storage room, take a look around. What do you see? Most PCOs will see a conglomeration of packages or boxes containing aerosol products, packets of wettable powders and dose bottles of ECs. Also present might be specially designed dispensers for some of the newer pesticide products and a lot of plastic or molded polyurethane materials.

If your store room is typical of most PCOs, there is a definite lack of large containers. If you do termite work you probably have the largest containers the industry uses. Those 1- and 2-gallon and 1-lier containers are also made of molded "plastic". However, it is likely that they will eventually have a standardized opening and be refillable in the future.

Even with all this innovative packaging there are still some products that require special storage precautions, most notably highly toxic products or those stored under pressure. New storage requirements will force PCOs to modify their current pesticide storage facilities to meet fire codes, as well as spill prevention requirements. Records may also have to be kept on pesticide inventories and storage procedures. Fortunately, the latter requirements will probably be for large storage areas, suppliers and agricultural operations. Pesticide storage in temporary facilities, like U-Store-It garages, will be prohibited. In addition, the issue of storing pesticides in vehicles for long periods of time will be addressed and discouraged.

Distributors will be impacted in a variety of ways, especially if they are involved in bulk storage of materials. Loading pads will have to be installed and special storage conditions met.

IMPACT ON THE PCO. It may be wise for you to take a good look at your storage area(s) to assess the ventilation and fire-proofing precautions in place. Being prepared will keep you from being blindsided by regulations. It is likely that these regulations will require more specific worker training.

The aforementioned regulations will probably not impact the PCO until 1994. If you’re thinking, "No problem, I have a lot of time to solve my pesticide storage and disposal problems," think again. I would remind you that pesticide storage and disposal is a high visibility issue and even though it takes the EPA a long time to promulgate regulations, the impact on states is clear. They are well aware of impending programs and if the legislature is pro-environment, regulation will be a high priority issue.

The disposal question is reaching the critical stage with hundreds of millions of pesticide containers being thrown away each year. Aerosol containers are of particular concern to the EPA. Fortunately EPA officials recognize that the pest control industry contributes only six of the 270 million pesticide containers that are disposed of annually. It is likely that aerosols, as we know them now, will not be the same by the time these regulations are promulgated, as changes will be made to enable recycling or refilling of these application devices. After all, that’s what an aerosol can is.

What makes this issue interesting is that the pest control industry has not yet addressed the recycling issue. The agriculture industry has and if we want to fit into the environmental scheme of things in the 1990s, we had better take a serious look at this issue. A place to start may be with the state extension service. It’s true that we do not contribute the numbers that other industries do, but the next time you throw away a triple-rinsed pesticide container, remember it will be here long after you’re gone.

George Rambo is president of George Rambo Consulting Services, Herndon, VA.