Do not remove. This document
should be retained in the EPA
Region 5 Library Collection.
EPA 540/9-77-018
     ECONOMIC ANALYSIS OF

     PESTICIDE DISPOSAL METHODS
          FINAL REPORT

          March 1977
          U.S. Environmental Protection Agency
          Strategic Studies Unit

          Washington, D.C. 20460

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                FINAL REPORT
ECONOMIC ANALYSIS OF PESTICIDE DISPOSAL METHODS

           Contract No.  68-01-2614
                 Task No.  1
                Submitted to

    U.S. Environmental Protection Agency
           Strategic Studies Unit
           Washington, D.C.  20460
                     by

            Arthur D.  Little,  Inc.
       Cambridge,  Massachusetts  02140
                  March 1977
               EPA-540/9-77-018

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                               ACKNOWLEDGMENT
     This program was conducted by Arthur D.  Little,  Inc.,  staff under
Contract No. 68-01-2614, Task Order 1.   The literature research and field
studies were completed during the period of July 1,  1974 to December 31,
1974.  The information in this report represents current conditions as of
about March 1, 1975.

     Arthur D. Little, Inc. staff contributing to the program include:
Joan E. Harrison, David B. Land, Pauline A. Langen,  Robert  J. Ludwig,
C. Michael Mohr (consultant), Joanne H.  Perwak, Donald M. Senechal,
Janet M. Stevens, Judith A. Varone, and Alfred E. Wechsler.  The authors
gratefully acknowledge the assistance,  guidance and  patience of the
Project Officer, Mr. Raymond F. Krueger, EPA, Office of Pesticide Programs,
throughout the program.  The work was made possible  by the  time spent and
the information generously provided by a large number of state university,
agricultural and environmental agency staff members;  regional and local
cooperative staff members; pesticide formulators, distributors, dealers,
applicators, and users; and others, particularly during the field surveys.
Their assistance demonstrates the general desire of  the agricultural
community to help in understanding and solving potential environmental
problems related to pesticide and pesticide container use and disposal.
                                   ii

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                    EPA REVIEW NOTICE
This EPA Report has been reviewed by the Office of
Pesticide Programs and has been approved for publi-
cation.  Agency approval does not signify that the
contents necessarily reflect the views and policies
of the Environmental Protection Agency, nor does
mention of trade names or commercial products con-
stitute endorsement or recommendation for use.

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                           TABLE OF CONTENTS
                                                                   Page

I.    SUMMARY                                                        1

     A.   Purpose and Scope                                          1
     B.   Results                                                    1

II.   INTRODUCTION                                                   7

     A.   Background                                                 7
     B.   Program Objectives                                         8
     C.   Approach                                                   9
     D.   Report Organization                                       10

III. OVERVIEW OF PESTICIDE AND CONTAINER DISPOSAL                  11

     A.   Pesticide Manufacture                                     11
     B.   Pesticide Distribution                                    11
     C.   Pesticide Use                                             14
     D.   Pesticide Containers                                      17
     E.   Methods of Disposal of Pesticides and Containers          22
     F.   Status of Regulations on Pesticide and Container
         Disposal                                                  30

IV.   FIELD STUDIES                                                 35

     A.   Introduction                                              35
     B.   Iowa Field Study                                          36
     C.   California—Field Study                                   63
     D.   Mississippi—Field Study                                  96
     E.   New York—Field Study                                    115

V.   ECONOMIC ANALYSIS                                            123

     A.   Framework of Analysis                                    123
     B.   On-Site Disposal                                         125
     C.   Intermediate Holding Areas                               126
     D.   Final Disposal                                           127
     E.   Transportation of Containers and Pesticides              133
     F.   Summary of System Costs                                  137
     G.   Container Deposit System                                 153

VI.   ENVIRONMENTAL EFFECTS OF THE DISPOSAL OF PESTICIDE
     CONTAINERS AND UNUSED PESTICIDES                             161

     A.   Incidence of Environmental Damage                        161
     B.   Potential Environmental Effects of Disposal Systems      162
     C.   Pesticide Disposal                                       169
                                   iii

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                         TABLE OF CONTENTS (Cont'd)

                                                                  Page

VII. CONCLUSIONS AND RECOMMENDATIONS                              173

     A.  Conclusions                                              173
     B.  Recommendations                                          176

VII. REFERENCES                                                   179
                                   iv

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                            LIST OF TABLES
Table No.                                                          Page
     1.  Representative Data on Pesticide Production                12
     2.  Typical Pesticide Use                                      16
     3.  Sizes and Types of Containers Used by Farmers              18
     4.  Estimates of Pesticide Containers in Mississippi - 1972    19
     5.  Estimates of Containers in California - 1970               20
     6.  Estimates of Containers in Montana - 1971                  20
     7.  Estimates of Containers in Oregon - 1972                   21
     8.  Types of Containers in Tennessee and Utah - 1970           21
     9.  Estimates of Total Liquid and Dry Containers
         Used by U.S. Farmers                                       23
    10.  Methods of Empty Pesticide Container Disposal in
         the 5-State Area of Illinois, Iowa, Kansas,
         Minnesota and Missouri                                     24
    11.  Pesticide Container Disposal in Tennessee Agriculture      25
    12.  Method of Disposal of Containers Used by Farmers           27
    13.  Disposal Practices in Iowa From Survey of Dealers,
         Applicators and Farmers                                    29
    14.  Acreage Harvested, Total Production and Farm
         Value of Iowa's Major Crops, 1971-73 Average               37
    15.  Estimated Quantities of Herbicides and Insecticides Used
         in the Five-State Area of Illinois, Iowa, Kansas,
         Minnesota and Missouri on Corn, Soybeans, and Small
         Grains in 1971                                             39
    16.  Percentage of Iowa Farmers Responding to Survey
         Questionnaire Who Applied Various Types of Pesticides      40
    17.  Principal Weeds for Which Chemical Herbicides were
         Applied - Iowa                                             40
    18.  Principal Herbicides and Formulations Used on Corn -
         Iowa                                                       41
    19.  Principal Herbicides and Formulations Used on
         Soybeans - Iowa                                            42
    20.  Principal Types of Soil Insects Treated and Principal
         Chemicals Used for Control of Soil Insects                 42
    21.  Type and Estimated Number of Firms in the Pesticide
         Distribution System in Iowa                                45
    22.  Estimated Number of Empty Pesticide Containers Disposed
         of in Iowa During 1972                                     45

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                       LIST OF TABLES (Cont'd)
Table No.                                                           Page
    23.  Percentage of Questionnaire Respondents in Iowa Who
         Possessed Containers Requiring Disposal, and the
         Estimated Number of Such Containers in Iowa in 1972        46
    24.  Typical Containers for Pesticides Commonly Used in Iowa    46
    25.  The Percentage of Questionnaire Respondents in Iowa Who
         Sometimes Have and Who Currently Had Quantities of Un-
         wanted Pesticides and State-wide Estimate of Unwanted
         Pesticide Quantities in 1972                               48
    26.  Disposal Methods for Container                             51
    27.  Disposal of Unwanted Pesticides                            52
    28.  California's Agricultural Commodities:  Acreage,
         Production, Value, Share of U.S. Production, National
         .Ranking, 1973                                              64
    29.  Usage of Restricted Materials - California, 1973           67
    30.  Usage of Restricted Herbicides - California, 1973          69
    31.  Estimated Number of Pesticide Containers in Use,
         California, 1969 and 1972                                  72
    32.  Mississippi and U.S. Crop Production, Selected Crops, 1973 98
    33.  Estimated Percentages of Cotton Acreage Treated with
         Herbicides by Herbicide and Stage of Growth in
         Mississippi, 1972                                         100
    34.  Estimated Percentage of Soybean Acreage Treated with
         Herbicides by Herbicide and Stage of Growth in
         Mississippi, 1972                                         101
    35.  Estimated Number of Insecticide Containers Used in
         Mississippi                                               103
    36.  Methods of Disposal of Pesticide Containers, 1970         110
    37.  Methods of Disposal of Unused Pesticides, 1970            112
    38.  Pesticides Commonly Used in New York                      116
    39.  Typical Containers for Pesticides Commonly Used in
         New York                                                  119
    40.  Container Weights                                         125
    41.  AMiual Container Generation in California  (1969)          148
    42.  Cost of Alternative Incinerator Systems in California     151
    43.  Costs of Alternative Landfill Systems in California       152
    44.  Annual Container Generation in Mississippi  (1974)         153
    45.  Annual Container Generation in Mississippi  (1974)         153
    46.  Bacteria and Pesticide Compounds Tested in Enzyme
         Degradation Studies                                       172
                                    vi

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                            LIST OF FIGURES




                                                                  Page
Figure No.




    1.  Channels of Pesticide Distribution                         13




    2.  Pesticide Distribution System in Iowa                      44




    3.  Pesticide Distribution System in California                70




    4.  Pesticide Distribution System for Mississippi             102




    5.  Pesticide Distribution System in New York                 117




    6.  General -Three-Level Disposal System                       124




    7.  Encapsulation Process                                     130




    8.  Incinerator for Pesticide Containers                      132




    9.  Incinerator for Unused Pesticides                         132




   10.  Scrapping of Small Metal Containers                       134




   11.  General Disposal System                                   140




   12.  Costs of Encapsulation and Burial                         142




   13.  Costs of Container Incineration                           143




   14.  Costs of Recycle by Scrapping                             144




   15.  Costs of Sanitary Landfill                                146




   16.  Principal Agricultural Areas in California                149




   17.  The Distributor-User-Disposal System                      155




   18.  The Formulator-Distributor-User System                    160
                                  vii

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                               I.  SUMMARY
A.   PURPOSE AND SCOPE

     Under Section 19 of Public Law 92-516,  the Federal Insecticide,
Fungicide and Rodenticide Act (FIFRA, amended), the Administrator of  the
Environmental Protection Agency is required  to establish procedures and
regulations for the disposal and storage of  packages or containers of
pesticides and for the disposal or storage of excess pesticides whose
registration has been canceled.  Within the  past several years, recommended
procedures for container and pesticide disposal have been published in the
Federal Register and comments from the public have been received.  The
purpose of this study was to survey pesticide and container disposal
practices in actual use and to develop information on their technical
feasibility, cost, and potential environmental effects.  More specifically,
the study concentrated on determining the current methods and practices
of pesticide and pesticide container disposal, the economics of these
practices, and the types and quantities of pesticides and container dis-
posal.  Collection, transportation, treatment and ultimate disposal were
examined along with attitudes of pesticide users concerning disposal
methods.  Reuse, recycle and deposit systems for pesticide containers were
also considered.  The potential environmental impact of disposal practices
was studied.

     The focus of this study was on the disposal of pesticides and contain-
ers used in the agricultural sector, with emphasis on pesticide containers.
The information gained in the program was obtained from the literature
and field studies in four representative states.  The analysis of the
costs of alternative disposal methods  is made using data obtained from
both literature and field studies.

B.   RESULTS

     1.  Pesticide and Container Manufacture, Distribution and Use

     The use of pesticides in the United States has increased from about
1 billion pounds per year in 1972 to about 1.4 billion pounds in 1976.
Almost one-half of these amounts are herbicides, nearly forty percent are
insecticides and the remainder are fungicides and other products.  These
pesticides are distributed through manufacturers, to formulators, to  dis-
tributors, retailers, and finally consumers; the exact route varies
considerably.  For example, in the midwest,  cooperatives are the principal
distributors.  In other locations, sales are often made directly from
manufacturer to large consumers.  In yet other locations, most sales  are
made through local cooperatives or retailers.

     In 1971, crops accounted for almost 95% of all pesticides used by
farmers.  Sulfur was the most widely used fungicide product, primarily for
citrus fruits, apples, vegetables, peanuts,  potatoes and nuts.  Almost

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50% of all herbicides was used on corn, soybeans, and cotton.   Important
insecticides such as Toxaphene and methyl parathion,  were used on corn,
cotton, and other field crops.  The use of pesticides in individual
states has not been well documented;  however, California is the largest
user.

     A study in 1970 estimated that 133,720,000 containers were used in
the United States in 1966.  A survey of farmers in 1971 showed that about
46% of all containers were liquid containers and 50%  dry containers.  Of
the liquid containers, the majority were 1- or 5-gal*lons.  Of  the dry
containers, the most prevalent were 4-5 pounds and 50 pounds and over.
Container material was found to be about 46% paper, 35% metal, 11% plastic
and 5% glass.  Container use varies from state to state.  For example,
in Mississippi, 1-gallon plastic containers were the  most widely used,
while in California, Tennessee, and Utah paper containers were the most
popular.  In Montana, 5-gallon metal containers were  the most common.

     Disposal methods vary from state to state and by the type of container
used.  Generally, surveys show that paper containers  are usually burned
or buried.  Metal or glass containers are either disposed with trash or
washed out for future use.  Contrary to other states  where surveys were
taken, Pennsylvania reported that 62% of the respondents to a survey
disposed of containers in landfills.  Unwanted or leftover pesticides
are usually burned in bags by farmers and applicators.  Other containers
are buried or taken to landfills.  In many cases, leftover pesticides are
stored for later use.  Dealers generally bury unused  pesticides, take
them to a landfill,  or return them to the distributor.

     EPA recommended procedures for pesticide and container disposal include
incineration or disposal in landfills.  Open burning, open dumping, water
dumping, food and feed contamination, and well injection are generally
prohibited.  State regulations vary considerably but  in states where there
are regulations, they generally follow federal guidelines.

     2.  Field Studies
     Field studies were conducted to develop more specific information on
pesticide and container disposal methods, costs and usefulness of disposal
methods in different areas of the country.  The four states selected were
Iowa, California, Mississippi and New York.

     Iowa

     The field visits in Iowa showed that burning on-site is the most
prevalent practice for disposal of paper containers.  Disposal of metal
containers in landfills was a common and acceptable practice but thought
wasteful of resources by many.  However, rinsing of containers was common.
Recycle or reuse would be acceptable if made simple and economical.
Incineration was generally thought too expensive for general use.  Other
processes such as biodegradation, encapsulation, etc., were not considered
practical or feasible in Iowa.

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     California

     Regulations in California are very specific regarding the disposal
of unused pesticides and the transportation,  handling and storage of pesti-
cide containers.  County and state officials feel the disposal system is
working quite well; however, field surveys showed some deviations.

     Formulator/applicators generally triple rinse smaller containers and
take them to a Class I (complete protection of ground water) or Class II-l
dump site (may overlie or be adjacent to usable ground water).  Larger
containers are recycled in some way or are reconditioned, usually with
some type of deposit.  In some cases, and with special permission, smaller
containers are reused for the same material omitting triple-rinsing.
Paper bags are usually disposed by burning in the field or disposed with
other empty containers.

     The disposal of empty containers and unused pesticides by small
farmers may not conform to state regulations.  Some containers are washed
and then used around the farm, other containers and pesticides may be
buried on the farm.  Often containers are taken to local landfills (neither
Class I or II).

     Unused pesticides do not appear to be a great problem in California.
County agricultural commissions sometime accept small amounts from users
or transport them to a Class I dump.   Applicators apply the pesticides
as intended or take them to a Class I dump.

     In general, regulations are followed, however, on examination of
various records showed that many pesticide containers are disposed of
through "non-approved" channels.

     Mississippi

     Bulk tank storage is becoming more popular in Mississippi and some
companies rely almost totally on this type of distribution.  However, the
majority of pesticides are still sold in larger size containers (55-gallon
drums).

     The State Bureau of Environmental Protection has set up a program
for solid waste disposal.  Disposal containers are placed at various
locations and solid waste, including pesticide containers, is collected.-
On the average, there is one container for every 150 people.  These
disposal containers are emptied periodically and taken to a sanitary land-
fill.  For disposal, containers should be triple-rinsed, cans punctured,
glass containers broken, and plastic containers slashed.  These procedures,
especially rinsing, are probably not often followed.  Combustible materials
can be disposed of in the solid waste containers, but they are more likely
to be burned at the site of use.

     Larger containers are beginning to be collected by the state for re-
conditioning.  Otherwise, they may be collected by the cooperative or

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distributer and then sold to a <<-
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disposal systems for areas of low usage.  Reconditioning larger drums
was found to be. economical if the reconditioning facility was less than
about 450 miles from the holding area.  In general, the cost of a return-
able deposit system does not depend on the amount of the deposit.  However,
this deposit must be greater than the net cost to the user of returning
the container to a holding area or disposal site.

     4.  Environmental Effects

     Documentation of environmental and health effects of pesticide and
container disposal has been poor in the past.  Thus analysis ce.n only be
done from the viewpoint of potential effects.

     Open dumping is likely to be the most hazardous method, posing threats
to humans and wildlife through direct or indirect exposure.  The hazards
connected with controlled burial are somewhat reduced.  Open burning of
bags may also be dangerous, since temperature and oxygen supply are often
inadequate for complete combustion and destruction of chemicals.

     Environmental and health effects of holding areas can be minimized
with proper controls.  Sanitary landfills can pose few hazards if hydro-
geologic conditions are suitable.

     Encapsulation, unless a sealing material such as asphalt is used,
would eventually result in the same effects as simple burial.  Incinera-
tion offers the safest method of pesticides and containers, since degrada-
tion should be complete.

     The disposal of unused pesticides by such methods as soil injection
and biodegradation have limited application and require further investiga-
tion.

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                            II.  INTRODUCTION
A.   BACKGROUND

     During the past quarter century, intensive organic and inorganic
pesticide development has resulted in the introduction of many new products
and product forms into the agricultural chemical market and the increased
use of those products.  New types of insecticides, fungicides, herbicides,
plant growth regulators, and combinations of chemicals are being manu-
factured, formulated, distributed, and used.  Production of some pesticides
is reaching new levels, while production of others is being severely limited
because of substitution of new or improved products in the U.S. or
foreign markets.

     Concurrent with the increased use of pesticides, is the increased
exposure to man and to the environment of pesticides, their residues, and
related waste products.  Concern for environmental quality and public
health has led to legislative actions which may affect the research and
development, production, use, and disposal of pesticides and their con-
tainers.  More specifically, under Section 19 of Public Law 92-516, the
Federal Insecticide, Fungicide and Rodenticide Act (referred to as FIFRA,
amended or the Federal Environmental Pesticide Control Act of 1972—FEPCA),
the administrator is required to establish procedures and regulations for
the disposal and storage of packages and containers of pesticides and
for the disposal or storage of excess amounts of such pesticides whose
registration has been cancelled.  Under Section 25 of this law, the
administrator is authorized to establish standards with respect to the
containers in which pesticides are enclosed in order to protect people
from injury resulting from contact with those pesticides.

     Pursuant to this authority, an initial document was published in the
Federal Register on May 23, 1973, recommending procedures for the disposal
and storage of pesticides, pesticide containers, and pesticide-related
wastes.  Following a public comment period, recommended procedures for
the disposal and storage of pesticides were again published in the Federal
Register on May 1, 1974; this republication reflected the concerns ex-
pressed by commentors representing both industry and the public.  The
recommended procedures, based upon investigation and study by the EPA and
the Federal Working Group on Pesticides, apply only to the disposal of
unused pesticides and pesticide containers by federal agencies and those
products under federal control.   On October 15,  1975 prohibited practices
such as were outlined in the Federal Register.

     Although the recommended procedures have been helpful, EPA regional
staff and state environmental staff do not have sufficient information
to recommend specific pesticide and container disposal practices, and
may be unaware of the attitudes of pesticide users toward specific disposal
methods.  More information is required on current disposal practices,
along with their technical feasibility, costs and environmental impacts

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to assist in preparation of specific recommendations to certified
applicators and other pesticide users.  This information will also be
useful in environmental impact analysis of regulations concerning
specific disposal actions.

B.   PROGRAM OBJECTIVES

     The overall objectives of this program are:

     1.  To determine the current methods and practices for disposing
         of pesticides and pesticide containers, the economics of
         these methods and practices, and the types and quantities
         of pesticides and containers disposed of by these practices.

     2.  To evaluate the economics of alternative methods for disposal
         of pesticide and pesticide containers, including the components
         of collection, transportation, and treatment or ultimate
         disposal.

     3.  To determine the attitudes of pesticide users concerning
         disposal methods and to evaluate the potential for coopera-
         tion with alternative approaches to pesticide and pesticide
         container disposal.

     4.  To examine alternatives to pesticide container disposal
         such as the reuse  and recycle of containers,  bulk transport
         of containers, and deposit systems using returnable
         containers.

     5.  To consider the environmental impact of current pesticide
         and container disposal practices and the potential environ-
         mental cost of alternative disposal methods.

     Study Limitations

     Because of the limited duration and effort of this program, the
focus of the study has been on pesticides and pesticide containers used
in the agricultural sector, rather than on institutional, home and garden,
or other uses.  Further, our effort was concentrated on disposal of
containers with only secondary consideration given to the  disposal  of
pesticides and other wastes.  Attention was gxven to those disposal
practices most commonly used or those which would most likely not be
prohibited in subsequent regulatory actions, i.e., those practices with
the least environmental hazards.  The information gained in this program
has been obtained through a sampling of states and persons involved  in
pesticide and pesticide container disposal and not through a complete
national survey.

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C.   APPROACH

     A brief review of the literature was undertaken to determine the
available information on the state of the art of pesticide container
disposal methods, on costs of disposal methods, and on the quantities
of pesticides and containers which require disposal.  The literature
reviewed included scientific journals, agricultural and other trade
journals, published federal reports and symposia, and other readily
available literature.  Computerized data bases such as NTIS, CHEMCON,
and CAIN were searched.  Pertinent articles were reviewed and abstracted.

     Based upon the information contained in the literature, and contact
with state environmental agencies, we selected several states for field
studies.  An initial field study was made in Iowa.  Our staff con-
tacted representatives of the state agricultural, environmental and
health agencies, state universities, pesticide distributors, dealers,
formulators, regional and local cooperatives, agricultural chemical
associations, pesticide applicators, and farmers.  Information was gain-
ed on current pesticide and container disposal practices, pesticide
distribution systems, types and quantities of pesticides and numbers of
containers used, current disposal methods, and attitudes of participants
to alternative methods for pesticide and container disposal.  Additional
literature and information was obtained on the pesticide container dis-
posal problem, on environmental hazards resulting from improper disposal,
and costs of disposal methods.

     Subsequent to this field study, we conducted similar field studies
in California, New York, and Mississippi.  Throughout these field visits
we attempted to obtain information from participants in pesticide
distribution, use and regulation, on the quantities and types of pesti-
cide containers and pesticides for disposal, on the current disposal
practices, the costs of current practices, the attitudes of various
parties towards current disposal methods, and new approaches which are
being tried.  Instead of conducting a field survey in a fifth state, we
contacted several state environmental agencies and others in the pesti-
cide industry, to obtain a better overview of the differences in practices
in different states, the current status of regulations, and current con-
cern in the states for pesticide disposal.

     Using the information obtained in these field studies, we conducted
an analysis of the costs of several currently-used disposal methods
considering both the effects  and implications of transportation of pesti-
cide containers and the scale of the disposal operation.  We also examined
a typical container deposit system, and the costs which may be incurred
as a result of such a deposit system.  The costs of disposal methods were
analyzed through a generalized approach so that the relative costs of
different methods could be compared on the basis of the distribution of
containers and number of containers available for disposal.

     This cost analysis, along with the results of our literature survey,
field studies, and other contacts, are presented in this report.

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D.   REPORT ORGANIZATION

     The following section of this report (Section III) presents general
information we have obtained from literature, state agencies, and other
sources.  It includes a general discussion of pesticide manufacture,
distribution and use patterns, pesticide and pesticide container dis-
posal methods, and the status of state regulations related to pesticide
and pesticide container disposal.

     Section IV presents the results of our field studies in Iowa,
California, Mississippi, and New York.  An overview of the agriculture
in each state and the pesticide distribution system is first presented
followed by the status of regulations and state policies.  Information
on the number of containers used,  disposal practices  for both
containers and pesticides, and the attitudes of participants in the
disposal process are given.  Available information on the costs of
actual disposal operations is presented along with the brief description
of the environmental effects of disposal noted in these states.

     In Section. V we present an economic analysis of principal disposal
methods employed at the site of pesticide use and at a disposal site.  Costs
of transportation of containers and pesticides as well as a summary of
system costs as a function of numbers and distribution of pesticide
containers are discussed.  Specific examples related to the states con-
sidered in the field visits are given.  A brief analysis of a deposit
system is also presented.

     In Section VI we present a brief description of the environmental
effects of current pesticide disposal methods.  Section VII
describes our conclusions and recommendations.
                                   10

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             III.  OVERVIEW OF PESTICIDE AND CONTAINER DISPOSAL
     The production, distribution, and use of pesticides in the United
States has been summarized in a recent EPA publication (von Rumker,  et al.,
1974).  Although there is no single authoritative source of data on the
quantities produced, imported, exported, and used throughout the various
locations in the United States, the above mentioned report summarizes
available information in 1974 and presents a relatively complete picture
of the production, distribution, and use of 25 of the major pesticides.
In this section we will summarize some of this information, and also
discuss information obtained from the literature on numbers of pesticide
containers distributed and used, on amounts of unused pesticides requiring
disposal, and on regulations pertaining to pesticide and container disposal.

A.   PESTICIDE MANUFACTURE

     The production of insecticides, herbicides, and fungicides in the
United States estimated from several sources is shown in Table 1.
In the five-year period 1967 through 1971, the production of fungicides
has remained essentially constant, whereas the production of herbicides
and insecticides (including fumigants and rodenticides) has increased
somewhat.  The majority of the pesticides are synthetic organic pesticides.
Data from another source—the U. S. Tariff Commission, 1972—indicate
that approximately 451 million pounds of herbicides, 564 million pounds
of insecticides, and 143 million pounds of fungicides were included as
synthetic organic pesticides, making a total of 1,158 million pounds of
active ingredients produced.  Inorganic pesticides are approximately 10%
of this total amount.  In 1972, imports of pesticides were estimated at
23 million pounds and exports were estimated at 323 million pounds, leav-
ing a domestic supply of approximately 976 million pounds of active pesti-
cide ingredients.


B.   PESTICIDE DISTRIBUTION

     As shown in Figure 1» the manufacture and distribution of pesti-
cides basically follows a pathway from manufacturers, to formulators, to
distributors, retailers and finally consumers.  There is considerable
variety in the pathways and participants among states.

     At the start of the distribution system are the manufacturers and
formulators.  The manufacturers generally are multi-product firms with
pesticides comprising from 1% to 40% of their total business.  Formulators
tend to also be multi-product firms, although pesticides comprise a large
percentage of their business.  Both manufacturers and formulators vary
from small to very large companies.  Larger companies generally assume
both roles, with facilities to convert their pesticide active ingredients
into usable products.  From the formulator, the product goes to the distri-
butors who may be wholesalers, brokers, manufacturer branch offices or
agents, and regional cooperatives.  As with manufacturers and formulators,
                                   11

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             Table  1.   Representative Data on Pesticide Production
                                          PRODUCTION (lOOO's Ib AI)

PESTICIDE TYPE                           1967                 1971

Synthetic Organic and Inorganic  '

   Insecticides                           504,000              565,000
   Herbicides                             440,000              459,000
   Fungicides                             178,000              180,000

      Total                             1,122,000            1,204,000
Synthetic Organic

   Insecticides                             ---                557,000
   Herbicides                               ---                429,000
   Fungicides                               ---                149,000
Sources:  (1)  U.S. Dept. of Agriculture (1973).  The Pesticide Review,
               1972, Agricultural Stabilization and Conservation Service,
               Washington, D.C.

          (2)  U.S. Tariff Commission (1973).  U.S. Production and Sales
               of Pesticides and Related Products, Washington, D.C.
                                     12

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imports
   Producer

(Manufacturer)
exports
imports
  Formulator
exports
                      Distributors
                 (Wholesalers,  Brokers,
                 Manufacturer Branches,
                 Agents,  Regional
                 Cooperatives)
                       Retailers
                 (Dealers, Local Coop-
                 eratives , Commercial
                 Applicators)
                       Consumers
           (Farmers,  Institutional Users,
           State and  Federal Government, Home
           & Garden,  and Commercial
           Applicators)
      Figure 1.   Channels of Pesticide Distribution
                           13

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distributors vary considerably in size and may limit their operations in
one sector of the state or extend over a large number of states.  Distri-
butors and regional co-ops generally handle several companies' products.
In many cases, the formulator is also a distributor of pesticides.

     The next distribution point is that of the dealer or retailer.  A
dealer may be a large wholesale outlet for pesticides or a small farm
dealer.  Local cooperatives and certain applicators are also dealers in
the sense that they retail pesticides to other customers.  Retail opera-
tions in pesticides may range from the "corner drugstore" which sells
home and garden supplies to consumers, to a large dealer in a farm
community that sells several million pounds of pesticides each year.

     Consumers of pesticides are the final point in distribution.  Con-
sumers include farmers, institutional users, contract applicators  (pest
control operators), state and federal government agencies, and home and
garden users.

     The pesticide distribution practices in different areas of the country
vary considerably.  For example, in the midwest, regional and local
cooperatives are often the principal centers for pesticide distribution.
In California, on the other hand, regional and local cooperatives play
only a small role in pesticide distribution.  In many cases, sales are
made direct from the manufacturer or manufacturer's branches to large
consumers bypassing distributors and retailers.  In other locations,
practically all sales are made through local cooperatives or retailers
direct to the individual consumer.  A complex variety of distribution
systems suggests that there are many persons and organizations involved
with the handling and distribution of pesticides and their containers.

     Because of this variability among states, no single method or approach
to pesticide and container disposal which involves specific groups in the
distribution chain will be acceptable across all states.  Aspects of this
variability as it affects viable disposal alternatives will be discussed
throughout this report.

C.   PESTICIDE USE

     Statistics and data on the use of pesticides in the United States
are generally difficult to obtain.  The Department of Agriculture periodically
prepares summaries of pesticides used, the major types, their distribution,
principal crops requiring pesticides, etc.  Unfortunately collection and
analysis of data usually require from one to three years after the year
for which the estimates of use were valid.  For example, in July of 1974
the Department of Agriculture released a publication on the farmer's use
of pesticides in 1971  (U.S. Dept. of Agriculture, 1974).  The study was
based on a survey of 8600 farmers throughout the United States.  Data
from the survey were expanded and adjusted to represent total crop and
livestock production within the United States.  Although the data will not
be given in detail here, some figures are important because they show the
nature of the chemicals used, the quantities, and the principal areas
                                   14

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 throughout the country in which the pesticides are used.

     Crops accounted for almost 95% of all pesticides used by farmers in
 1971.  More specifically, crop use accounted for 95% of fungicides,
 practically all of the herbicides, 91% of insecticides and 85% of other
 pesticides used by farmers.

     Sulfur was the most widely used fungicide product and accounted for
 more than three times as many pounds of all other fungicides used.
 Fungicides were primarily used on citrus fruits, apples, vegetables,
 peanuts, potatoes, and nuts.   Approximately one-third of the fungicides
 used on farms were in the southeast, approximately 18% in the northeast,
 17% in the Pacific, and 13% in the corn belt.  Principal inorganic fungi-
 cides included copper sulfates, and other copper compounds.  Principal
 organic fungicides included Maneb, Captan, Zineb, and others.

     Atrazine was the principal herbicide used by farmers and accounted
 for nearly one-fourth of all herbicides used.  Use of other herbicides
 was increasing considerably, including Amiben and Trifluralin.  Herbicide
 2,4 -D showed decreasing use.  About 45% of all herbicides were used on
 corn, 15% on soybeans, 9% on cotton.  Farmers in the corn belt accounted
 for about one-third of all farm herbicides used.  The Lakes Region was
 second and the Northern Plains third, each accounting for about 12% of all
 farm herbicides used.  Wheat and sorghum were other significant uses  of
 herbicides.

     About 90% of all insecticides used by farmers were applied to crops;
 most of these were organochlorine and organophosphorus compounds.  In
 1971, DDT and Toxaphene were the principal organochlorine insecticides.
 Their use has decreased significantly since 1971.  Methyl parathion was
 the principal organophosphate insecticide at this time.  Although its use
 has also decreased, other organophosphates have continued to be used in
 significant amounts.  The use of carbamates has generally increased
 significantly.  Over 47% of all insecticides used on farms were used on
 cotton, 17% on corn, and 11% on field crops such as wheat, sorghum, rice,
 peanuts, etc.  Only about 7% was used on vegetables.

     Although the compounds which are used most have changed sin.  >.
 1971 as a result of the substitution of carbamates and phosphates for organo-
 chlorine insecticides, the general use of pesticides, in terms of their
 distribution throughout the country and the major crops for which they
 are used, remained about the same.

     Use statistics for many states are not available.  Less than half of
 the states require adequate records of pesticide sales and use.  Table 2
 indicates the diversity in pesticide usage among several states
von Rumker,  et al., 1974). These data were collected by a variety of
 methods from several states; probably the most reliable of the data comes
 from California where the usage for practically all pesticides is carefully
 recorded.  (Available data on pesticide use in the states surveyed in this
 project are given later in the report under the appropriate section.)
                                      15

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                       Table 2.  Typical Pesticide Use
STATE/COUNTY
Arizona
California
Illinois
Indiana
Michigan
Minnesota
Utah
Wisconsin
Canyon County,
Idaho
Johnson County,
Iowa
Washington, Bolivar
and Sunflower County,
Mississippi
(Quantity 1000
YEAR INSECTICIDES FUNGICIDES
1972
1972
1972
1970
1970
1972
1971
1970
1972
1973
1972
9,353 144
28,622 2,965
5,544
2,688
509
1,956 249
364
574
251 76
22 14
11,625 1,385
(17.827)2 (1,809)
Ib AI)
HERBICIDES OTHER
838
16,091
20,566 10.9381
7,298
2,833
13 , 116
788
5,124
458
98
3,343
(3,835)
Includes 28,000 petroleum hydrocarbons, 27,082 petroleum oil,
 16,591 sulfur, 16,584 mercury-treated seed.
2
I
'Values are estimated by county agents—values in parenthesis
are farmers' estimates.
  Source:  von Ru'mker,  et al. (1974)
                                       16

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D.   PESTICIDE CONTAINERS

     Pesticides are distributed in a number of different types and sizes
of containers.  Heavy metal drums, in fifty-five, fifty, forty, thirty,
and twenty-eight gallon sizes, are common for shipments of pesticides
to large dealers, distributors and commercial applicators.  Five-gallon
metal containers seem to be one of the most popular sizes.  They are
purchased by distributors, dealers, applicators, and farmers.  With the
currently used rates of application of chemicals, the 5-gallon container
may cover anywhere from 2 1/2 to 75 acres under normal conditions.  It
is a convenient size for the farmer to use; he can mix the chemical and
not leave many containers partially filled.  Smaller containers are
primarily 2-gallon and 1-gallon containers of liquids, and occasionally
even smaller containers primarily for the home and garden market.  There
are a large number of pesticides which are distributed in aerosol type
cans.  Granular or dry chemical pesticides are normally distributed in
large bags of 50-pound size, usually paper or plastic impregnated.  A
large number of pesticides of wettable powder formulation are distributed
in boxes, each of which contain a total of about 50 pounds divided
individually into five or more small paper containers with from 5 to 10
pounds each.  There is a current trend to move liquid pesticides by bulk
shipment, i.e., large tanks containing pesticides from which dealers or
distributors can refill containers specially designed for the purpose.

     The most extensive information on the types of containers which are
used and must be disposed of is the work of Fox and Delvo (1972) at the
Dept. of Agriculture.  Portions of their data are given in Table 3.
These were collected from about 1500 farmers in 1971 whose responses were
used to determine the size of containers used, container material and
methods of disposal.  As seen in the table, most liquid pesticides  (82%)
are purchased in 1-gallon or 5-gallon containers.  Small containers, 1
quart or less, account for about 9% of liquid pesticides.  The percentage
of liquids in 29- to 55-gallon containers  (about 8%) may be low because
the sampling was primarily oriented to farmers rather than commercial
applicators.  Dry pesticides generally were purchased in 5-pound packages
or 50-pound packages (85%) which is the way most dry pesticides are
currently marketed.  Of the total number of containers 71% are either
paper or metal, with a relatively small amount (15%) of plastic and glass
containers.  There is some variation in the percentage of container
materials among insecticides, herbicides and fungicides.  Most of the
insecticides (59.8%) are found in paper containers, while herbicides are
split between metal (44%) and paper (42%) containers.  Fungicides are
almost entirely contained in paper (84%).

     In addition to this national survey, there are several surveys in
states and counties which describe the types of containers and numbers of
containers which must be disposed of.  Tables 4  to  8 present  the
information on numbers and types of containers from some of these states.
(Additional information is given in Section IV under state site visits.)
                                   17

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      Table 3.    Sizes and Types of Containers Used  by Farmers


       Percentage distribution of farmer  responses to pesticide
       container aupsi-tnns. tTn-tf-gfl  St-a«-oc  1Q71
Item
Size of Containers:
Liquid containers
1-pint or less
1-quart
1-gallon
5-gallons
29 to 30 gallons
50 to 55 gallons
Total liquid
Dry Containers:
3 or less pounds
4 to 5 pounds
20 to 25 pounds
50 pounds and over
Total dry
Other Containers
Total containers
Container Material:
Glass
Metal
Paper
Plastic
Other
Total
Number of responses
Insecticides


1.0
3.9
14.0
10.1
0.7
1.6
31.3

7.2
19.1
9.0
27.8
63.1
5.6
100.0

10.2
16.2
59.8
10.1
3.7
100.0
666
Herbicides


1.4
2.6
18.5
24.5
3.6
.1
50.7

.9
30.2
2.6
13.9
47.6
1.7
100.0

2.5
44.0
42.5
8.4
2.6
100.0
1,373
Fungicides


	
1.0
5.1
2.0
2.0
	
10.1

13.3
30.6
4.1
25.5
73.5
16.4
100.0

1.0
8.2
83.7
5.1
2.0
100.0
98
All
Pesticides


1.5
3.3
19.7
18.4
2.8
.8
46.5

3.3
24.8
4.4
17.6
50.1
3.4
100.0

5.0
34.8
46.5
10.9
2.8
100.0
2,357
Source:  Fox and Delvo  (1972)
                                     18

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   Table  4. Estimates of Pesticide Containers in Mississippi - 1972*
               55 gallon drums                 61,902


               30 gallon drums                  8,342


               5 gallon metal                 169,498


               5 gallon plastic                32,443


               1 gallon plastic               995,217


               1 gallon glass                  25,558


               1/2 gallon glass                 3,525


               1 quart or smaller               5,672

                           Total            1,302,157
*
 These numbers differ significantly from those reported in
 other years—see Section IV.
  Source:  University of Florida  (1974)
                                  19

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 Table   5.    Estimates of Containers in California - 1970


            55 gallon drums               8,000
            30 gallon drums              98,000
            small metal containers      346,000
            paper containers          3,239,000
            glass containers             91,000
            plastic containers           81,000
                           Total      3,863,000


Source:  Rogers and Cornelius (1970)
   Table  6. Estimates of Containers in Montana - 1971
           30-55 gal. drums               5,971
           5 gal. metal                  99,026
           5 gal. plastic                    30
           1 gal. glass                      80
           1 gal. metal                    2606
           1/2 gal. glass                   900
           1/2 gal. metal                  1655
           30-50 Ibs paper bags            5946
           30-50 Ib metal                  3910
           5 Ib metal                      2055
           5 Ib bags                        541
           200 Ib fiber drums               328
           20-25 Ib fiber drums           4026
           10-25 Ib paper bags           15351
           2-5 Ib plastic                 1300
                           Total       143,725
 Source:  University of Florida  (1974)
                              20

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 Table  7.  Estimates of Containers in Oregon - 1972
   Containers for Liquid

       30-55 gallon drums           14,800

       5 gallon or less (metal,    998,000
       glass, etc.)


   Containers for Dry Materials

       >20 Ib                      215,000
       <20 Ib                      975,000*
   *
    includes pest strips, flea collars, etc.
  Source:  Univ. of Florida  (1974)
  Table   8.  Types of Containers in Tennessee
and Utah
Metal drums
Metal cans
Paper bags
Glass containers
Plastic containers
- 1970
% of
Tenn.
11%
24%
59%
1%
5%
total
Utah
3%
31%
56%
6%
4%
Source:  Tenn.  Dept.  of Agriculture (1970)
         Univ.  of Florida (1974)
                         21

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Data from Mississippi, obtained through surveys of farmers located
throughout the State,  indicate that about 76% of the total con-
tainers are 1-gallon plastic containers and 13% are 5-gallon metal
containers.  Data from Montana, estimated by State personnel in 1971»
indicate that about 69% of all containers are 5-gallon metal containers.
In Oregon, data were obtained through surveys of major pesticide suppliers
in 1972; because of the number of household containers included, percentages
of types of agricultural containers cannot be determined.  Data from
Tennessee encompassed approximately 90% of pesticides used on the cultivated
acreage in the State, showing the percentage of paper bags to be 59% and
the percentage of metal cans to be 24%.  Data from Utah represent pesticide
applicators only.  The percentage of paper bags from this survey is 56%,
while the percentage of metal cans, 31%.

     A report by Jansen (1970) estimates the total number of containers
used for pesticides in the years 1964 and 1966 (Table 9).  He derived
these estimates through production figures reported by the U.S. Tariff
Commission on Pesticide Review.  He first selected 14 major pesticides
as representative of the classes or groups to which they belong, whether
these were averaged by type, i.e., liquid, dry or aerosol.  He then
estimated the quantity of active ingredient per gallon of formulation or
per pound of formulation and the relative proportions of the representative
pesticides packaged in different size containers.  Combining this infor-
mation with the production figures, he derived numbers of containers.  He
then estimated the number of containers used by farmers as opposed to other
consumers, using the estimates of farm usage of pesticides.

     As the above discussion indicates, most of the studies to estimate the
numbers of containers in various states and counties are done on different
bases.  As a result, there is insufficient information for detailed
comparison  or  for estimating the total numbers of containers based upon
the type of agriculture and estimates of pesticide production and use.

E.  METHODS OF DISPOSAL OF PESTICIDES AND CONTAINERS              *

     Along with the surveys of numbers of containers and pesticides for
disposal, several surveys have been conducted on the methods actually used
for disposal of pesticides and containers.  (Our discussion of  site visits
contains more detailed and up-to-date information.)

     In 1972, the EPA conducted a pesticide study in five mid-western
states—Illinois, Iowa, Kansas, Minnesota and Missouri.   (von Rumker, 1972.)
Methods of disposal in this five-state area, are shown in Table 10.
The most prevalent method of disposal is burning of bags.  In four of the
states 10-35% of the containers were washed and reused as containers,
presumably on the farm.

     A study conducted by Tennessee Dept. of Agriculture  (1970) also
determined the methods used for pesticide container disposal.   The results
of this study reported in Table 11 indicate that apparently most of
                                    22

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  Table 9.   Estimates of Total Liquid and Dry
             Containers Used by U.S. Farmers
                           Thousands of Containers

                           1964            1966

Liquid Containers
55-gallon
5-gallon
1-gallon
574
5,646
11,865
605
6,193
12,773
Dry Containers

   50-pound               9,342           10,465
    4-pound              92,600           97,543

Aerosol Containers        6,101            6,141

TOTAL                   126,128          133,720
Source:  Jansen (1970)
                        23

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 Table   10. Methods of Empty Pesticide Container Disposal in the
            5-State Area of Illinois, Iowa, Kansas, Minnesota and
            Missouri
Methods Used Illinois
1.
2.
3.
4.
5.
6.
7.
Throw in trash for
pickup
Burn
Wash and store
Wash and use as container
Dump in ditch or field edge
Bury
Other
14%
65%
40%
10%
8%
12%
24%
Iowa Kansas Minnesota
20% 22%
70% 51%
8% 9%
3% 11%
8% 13"%
5% 11%
21% 29%
26%
85%
17%
17%
4%
9%
9%
Missouri
17%
70%
15%
35%
9%
13%
—
Source: von Rumker  (1972).
                                     24

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the paper containers are burned, a large number of the metal and glass
containers are thrown in the trash and a sizrble mmber of containers,
mostly metal drums and glass, are washed and used in the farm or at aome.

     The results of a pesticide usage study conducted in Adams County,
Penn. (Pennsylvania Dept. of Health, 1971) in 1970, indicate that approx-
imately 62% of those responding to the survey disposed of containers in
landfills, 16% burned on the premise, and another 16% buried on the premise.
The remainder of the responses indicated disposal in municipal incinerators,
other dumps, etc.  This survey did not study the number of containers which
were disposed of by these methods.  The study also determined that less
than 10% of those responding rinsed out their pesticide containers, whereas
approximately 25% rinsed equipment.  The wastewater was disposed of on the
ground in practically all cases.

     A study conducted by the Institute of Agricultural Medicine in an
Iowa community (Iowa Community Pesticide Survey, 1972) indicated that of
the farmers having leftover pesticides, 63% store them for further use,
22% return them to the dealer, 9% bury them on the farm, 6% discard
them on unused land, and the remainder discard them in sanitary landfills.
The survey also found that some 42% of the respondents indicated they
would be willing to return unwanted pesticides and empty containers to a
local dealer and pay a fee for safe disposal.  About 82% would be willing
to pay up to $5 per year; 15%, $10 per year; and 2% would be willing to
pay more than $20 per year.

     In another Iowa study, the Farm Bureau in 1970 surveyed their members
to determine container  disposal methods.   (Ryan, 1974)  Some 72% of those
responding to the survey burned empty pesticide containers, 12% returned
them to pesticide dealers, 34% indicated they either burned them or took
them to the dump.  Thirty-four percent of those responding had leftover
pesticides.  Forty-four percent of those responding would be willing to
pay a fee to have their pesticide containers disposed of safely.  Fifty-
six percent indicated they would pay $5 per year; 40%, $10 per year; and
4%, $20 per year.

     The results of the study by Fox and Delvo  (1970) showing the methods
of disposal are given in Table 12.   Most pesticide containers are
burned, almost 20% are disposed of in a private dump, 11% are retained
for unknown purposes, and the remainder are disposed of by a variety of
means.  Although only 11% of the respondents indicated that the containers
were returned to the dealer or delivered to a commercial dump, 52% of the
respondents indicate that they would dispose or bring containers to a
collection point.

     Surveys of applicators in Oregon indicate  that 87% of containers are
disposed of in landfills or are buried on the applicator's property.
(University of Florida, 1974.)  Nine percent of the containers are left
with the applicator's clients for disposal  and  the balance are reused.
                                    26

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 Table  12.  Method  of  Disposal  of  Containers  Used  by  Farmers
   Percentage distribution of  farmer  responses  to  pesticide
   container questions on container disposal, and  collection
   preferences,  United States,  1971.
Item
Insecticides
Herbicides
Fungicides
All
Pesticides
Percent
Method of Disposal:
Returned to dealer
Burned
Buried
Private dump
Commercial dump
Left in field

1.9
61.0
3.7
16.7
7.1
1.3
Left where sprayer filled .6
Retained
Other
TOTAL
Would use collection
points :
Yes
No
TOTAL

Number of responses
6.9
.8
100.0


52.3
47.7
100.0

666

3.1
45.0
6.6
18.4
9.6
.7
1.5
13.3
1.8
100.0


51.3
48.7
100.0
Number
1373

4.1
71.4
7.1
2.0
8.2
—
—
4.1
3.1
100.0


46.9
53.1
100.0

98

3.1
49.2
5.8
18.9
8.4
.9
1.1
11.0
1.6
100.0


51.6
48.4
100.0

2357
Source:   Fox and Delvo (1972)
                                 27

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     The recent study of pesticide disposal practices in Iowa done by
Ryan (1974) provided information on the methods of disposal of pesticides
leftover in the application equipment, methods of disposal of empty
pesticide containers, and of unwanted pesticides.  The results of this
survey for pesticide applicators, and farmers, are shown in Table 13.
The results indicate that both farmers and applicators burn most containers
(presumably bags) on the property, and either bury or take to landfills
or dump  the remainder of their containers.  Most applicators and farmers
apply pesticides which are leftover as originally intended, or else store
them for future use.  Dealers generally bury unwanted pesticides, take
them to landfills, or return them to distributors.  Some pesticides are
stored or given to others for use.  Applicators follow essentially the
same practices, with some being returned to dealers.   Only 28% of the
farmers, 32% of the applicators, and 58% of the pesticide dealers, indi-
cated they had excess waste pesticides.  As discussed in later sections,
some of the reports of individual farmers and applicators in our Iowa
field study differ from results of Ryan's mail survey.

     It is not surprising that  there  is little published information on
the quantities and  types of pesticides which  require disposal.  Unless
a specific survey has been conducted  by state and agricultural depart-
ments or other organizations, this information is generally lacking.  Most
pesticides which require disposal are  those which are outdated, have
been removed from the market or are prohibited from use, those which do
not meet specifications for the product, and  those which have been sold
or given to dealers  and retailers who  no longer can find the retail
market  for these pesticides.  In general,  farmers who have pesticides
available will use  them rather  than dispose of them and see "money wasted."
Dealers also may give some pesticides  away to farmers rather than be
responsible for disposal.  Practically all dealers have several barrels
or containers  of pesticides which they can no longer sell and must find
a means of disposal.  Most farm personnel, we believe, store, from year
to year, those unused pesticides which can be effectively used on their
own property.  DDT  and others which are no longer usable, however, may
be located on  the farm and need to be  disposed.   In general, most
of the pesticides requiring disposal will  occur at dealers, distributors
and major farm operations, as well as  industrial  locations.

     The EPA study  conducted in 1973  summarized some quantities of
pesticides stored at various locations (Environmental Protection Agency,
1973).  For example, in Alaska  some 300 containers ranging in size from
5-gallon to 55-gallon drums containing pesticides were considered excess
and needed disposal.  In addition, a  considerable amount of DDT and
copper-chromium-arsenic compounds were ready  for disposal.  In Florida,
a collection and disposal program resulted in some 93,000 pounds of  mixed
pesticides being stored in 1970 awaiting disposal.  A similar program in
Georgia for picking up pesticides resulted in considerable amount of DDT
and other mixtures  ready for disposal.  Considerable amounts of DDT  and
                                  28

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dieldrin are also ready for disposal in Kentucky.  Other states such as
Maine, Massachusetts, Michigan, have a considerable amount of DDT and
other pesticides stored for disposal.  The State of Montana has collected
a large number of different types and quantities of pesticides for disposal
and store the material in an ammunition bunker.  Over 20,000 pounds of
pesticides are stored pending disposal in that state.  In New Hampshire
about 5 tons of pesticides are being stored in the State and there are an
estimated 1 million pounds of pesticides to be disposed of in New York.
The State of Washington also has considerable quantities of pesticides for
disposal.

     Data such as these are quite sporadic and are not considered to be
very up to date.  Periodically, some in-depth surveys are conducted  by
state and federal agencies to determine quantities of pesticides awaiting
disposal.  Surveys of farmers taken by mail or telephone frequently
indicate that there are excess pesticides stored and ready for disposal,
although some people are not willing to admit to the fact that they have
material which might be outdated, adulterated, or not suitable for applica-
tion.

F.   STATUS OF REGULATIONS ON PESTICIDE AND CONTAINER DISPOSAL

     1.  Federal Regulations

     As mentioned in the introduction, recommended procedures for the
disposal and storage of pesticides and pesticide containers were published
in the Federal Register, Vol. 39, No. 85—May 1, 1974.  The recommended
procedures for the disposal of pesticides and pesticide containers given
in these rules and regulations apply to all pesticides which may be
registered for general or restricted use or covered under an experimental
use permit, with certain exceptions including pesticides for home and
garden use.  The disposal procedures are to be used by the Environmental
Protection Agency in carrying out its pesticides and pesticide container
operations.  These procedures are recommended for all others who wish to
dispose of pesticides or pesticide containers.

     Several procedures were not recommended.  These include disposal or
storage of pesticides, pesticide containers and container residues in
a manner inconsistent with the pesticide label, or applicable state or
federal pollution control standards.  Open dumping was prohibited (FR Vol.
39, No. 200) and open burning was prohibited only for small quantities when
allowed by state and local regulations.  Water dumping or ocean dumping
was also not prohibited except in conformance with appropriate regulations.

     Disposal of Pesticides

     Recommended procedures for disposal of organic pesticides include
incineration and, if incineration facilities are not available, burial
in specially designated landfills.  Soil injection, chemical degradation,
and well injection were not recommended unless specific guidance is
obtained from appropriate authorities and cautions taken to
avoid environmental effects. Metallo-organic pesticides should be


                                   30

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disposed of by incineration or burial in specially designated landfills.
Disposal of these materials by soil injection, chemical degradation, and
well injection again are not recommended without specific guidance and
adequate demonstration that safety and environmental quality are maintained.
Organic mercury, lead, cadmium, arsenic, and inorganic pesticides are to be
disposed of by chemical deactivation or conversion to non-hazardous compounds,
If chemical deactivation facilities are not available, these pesticides
should be tenroorarily stored or encapsulated ?nd buried in specially
designed landfills.  In addition, no pesticide or pesticide-related waste
shall be disposed of or stored near or in such a way as to contaminate food,
feed, or feed packing materials.

     Disposal of Pesticide Containers

     The following is an excerpt from the recommended procedures published
in the Federal Register, Vol. 39, No. 85.

           (a) Group I Containers.  Combustible containers which
     formerly contained organic or metallo-organic pesticides,
     should be disposed of in a pesticide incinerator, or buried
     in a  specially designated landfill, except that small quantities
     of such containers may be burned in open fields by the user
     of the pesticide when such open burning is permitted by State
     and local regulations, or buried singly by the user in open
     fields with due regard for protection of surface and sub-
     surface water.

         (b) Group II Containers.  Non-combustible containers
     which formerly contained organic or metallo-organic pesticides,
     should first be triple-rinsed.  Containers in good condition
     may then be returned to the pesticide manufacturer or formulator
     or drum reconditioner for reuse.  Other rinsed metal containers
     should be punctured to facilitate drainage prior to transport
     to a  facility for recycle as scrap metal or for disposal.  All
     rinsed containers may be crushed and disposed of by burial in
     a sanitary landfill, in conformance with State and local
     standards or buried in the field by the user of the pesticide,
     Unrinsed containers should be disposed of in a specially
     designated landfill, or subjected to incineration in a
     pesticide incinerator.

         (c) Group III Containers.  Containers (both combustible
     and noncombustible) which formerly contained organic mercury,
     lead, cadmium, or arsenic or inorganic pesticides and which
     have  been triple-rinsed and punctured to facilitate drainage,
     may be disposed of in a sanitary landfill.  Such containers
     which are not rinsed should be encapsulated and buried in a
     specially designated landfill.

Residues and rinsed liquids should be disposed of through use in spraying
operation  in the field or otherwise disposed of in accordance with the
methods described above for individual pesticides.
                                 31

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      2.  State Regulations

      State regulations vary from being "non-existent" with respect to
pesticides and pesticide containers, to very specific and complex regula-
tions and procedures for disposal of pesticides and pesticide containers.
A recent study (University of Florida 1974) summarized current state
laws.  In about 15 states, there are no specific laws applicable to
pesticide and pesticide container disposal.  In other states legislation
was being formulated at the time this report was prepared.  In several
states, environmental regulations prohibit the disposal of pesticides or
containers in such a way as to cause injury to persons, wildlife, or the
environment but no specific recommendations for disposal are given.
Specific regulations and laws pertaining to pesticide and pesticide con-
tainer disposal exist in a few agricultural states which have been leaders
in environmental regulation.  Some examples of status of state regulations
in March 1975 are given below.  Details of regulations in the states
visited in our field survey will be given in Section IV.

     North Dakota

     The regulations for pesticide use and disposal are to be ready for
enactment by July 1, 1975.  The anticipated regulations will be  similar
to current EPA regulations.  The regulations are being developed by the
newly formed Pesticide Division of the State Department of Agriculture.

     North Carolina

     Draft regulations for pesticide and pesticide container disposal
were prepared in August of 1974.  In accordance with the North Carolina
Pesticide Law of 1971, the North Carolina Pesticide Board is authorized
to establish regulations concerning the disposal of pesticides and
pesticide containers.  The proposed recommended disposal methods for
pesticides parallel those of federal regulations.  With respect  to
containers, the state recommends that combustible containers normally
containing organic or most metallo-organic pesticides be disposed of in
a pesticide incinerator or buried in an approved landfill.  Non-combustible
containers of less than 30 gallons which contained organic or most metallo-
organic pesticides should be triple rinsed, drained and transported to a
disposal facility—an approved sanitary landfill.  Unrinsed containers
should be disposed of in a specially designated landfill or incinerated.
Containers of less than 30-gallon capacity which contained organic mercury,
lead, cadmium, arsenic, or inorganic pesticides, should be triple rinsed
and disposed of in an approved sanitary landfill; non-rinsed containers
should be disposed of in a specially designated landfill.  Containers
larger  than 30-gallon capacity may be disposed of, after triple rinsing, in
approved landfills through  September 1, 1975.  Another part of
the proposed regulations will require that all manufacturers and dealers
offering pesticides for sale  in containers of more than 30-gallon capacity
shall be required to impose a container return deposit  of at least  $5
but not more than $25 upon  each purchaser.  The required deposit will be
returned to the purchaser upon return of the container  to the seller,
                                   32

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provided the containers returned have been triple rinsed and all bungs,
lids or openings closed.  North Carolina also has regulations pertaining
to the use and storage of pesticides in bulk containers; however, they
do not contain specific regulations on the disposal of these bulk containers,

     Oklahoma

     The State of Oklahoma has proposed draft regulations for container
disposal which parallel in practically all respects the federally recom-
mended disposal procedures.  In addition, the State has issued requirements
for sanitary landfills and specially designated landfills for the disposal
of certain pesticide containers.

     Pennsylvania

     The State of Pennsylvania has recommended that small containers such
as aerosol cans and empty bags be brought to a landfill after sealing them
and placing them in newspaper or other wrapping to prevent leakage.
Flammable containers may be burned provided local burning ordinances or
pollution regulations are not violated.  Burning containers of herbicides,
or aerosol containers, is not recommended.  Large non-flammable containers
should be returned to manufacturers.  If this cannot be done, the containers
should be triple rinsed and brought to a landfill or disposed of on the
user's land if suitable conditions exist.  Containers should be punctured
and crushed, if possible.  Considerations for determining the suitability
of the site for land disposal of containers are given in the recommendations.
These include:  distance from streams, water supplies, or livestock feeding
areas, types of soils, and depth of disposal pits.  It is also recommended
that unused pesticides be returned to manufacturers or their representative
or be used by other farmers, pest control firms or agencies.  Where this
is not possible, incineration is recommended.  Commercial firms are to be
contracted if large quantities of waste materials exist.

     Georgia

     The Dept. of Agriculture is charged with the administration of the
Georgia Pesticides Use and Applications Act.  The only current law existing
is that containers should be disposed of in a manner that does not endanger
human life or the environment.  When state laws are promulgated, they will
follow federal laws.

     New York

     New York state laws require that unused pesticides be incinerated or
buried at specially designated sites.  Containers may be buried in
specially designated sites on the farm or returned to the formulator.
When new laws are promulgated, they will conform to federal statutes.
                                    33

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     California

     California has stringent regulations with regard to pesticide and
pesticide container disposal.  A series of landfill sites of several
classes specifically designated for disposal of pesticides, other hazardous
wastes, and pesticide containers has been established.  Criteria for these
landfills have been established.  Pesticide disposal and pesticide container
disposal operations are under the jurisdiction of the Dept. of Agriculture,
appropriate state environmental protection agencies, and county
agricultural commissioners.  A description of the current regulations is
given in Section IV.

     Alabama

     The State of Alabama regulations and guidelines recommend using
normal solid waste disposal channels for disposal of pesticides and for
container disposal.  Where these are not available, a program of specially
developed landfills will be established.  Large numbers of containers or
large concentrations of unused pesticides should be disposed of at Class A
landfills which are specially selected after due consideration of soil
type, water table, surface flow, etc.  Smaller quantities of pesticides
and pesticide containers generated by farm operators, applicators, etc.,
which do not justify transportation to centralized Class A sites may be
disposed of in Class B landfills which are designated areas within existing
sanitary landfills.  Class C landfills are sites for pesticide disposal
and container disposal which are located on the property of farmers,
industrial organizations, etc., who choose to dispose of their own pesti-
cide containers.  Recommendations for these types of landfills are also
proposed.

     In general pesticide and pesticide container disposal regulations
are often proposed by the pesticide control boards and promulgated by
the state environmental, health, or agricultural agencies.  It is expected
that most state regulations will follow the already published federal
regulations.
                                    34

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                           IV.  FIELD STUDIES

A.   INTRODUCTION

     Field studies were conducted to develop information on:

     1.   Currently used pesticide and container disposal methods,
          including reuse or recycle of containers;

     2.   Costs of currently-used disposal methods, including labor,
          handling, transport, facilities, equipment, etc.;

     3.   Availability of disposal sites and/or equipment;

     4.   Relative usefulness of various disposal methods;

     5.   Attitudes of pesticide dealers and users toward disposal
          methods including reuse, recycle and returnable deposit
          systems.

     A number of criteria were used to select states for field studies:
value of agricultural production, types of farms, pesticide use, major
crops, degree of urbanization, status of pesticide and container
legislation and regulations, and geographic location.  For example,
it was desirable to select states which differed in their amounts of
agricultural production because of the expected difference in degree
of pesticide usage, and levels of pesticide and container regulations.
It was desirable to select states which were urbanized as well as rural
agricultural, and to select ones from several geographical regions
because of different major crops, different pest problems, and perhaps
different attitudes toward pesticide and container disposal.

     States initially considered for field studies included:  California,
Texas, Iowa, Minnesota, Nebraska, Colorado, Virginia, New York, Montana,
Illinois, Indiana, Kansas, North Dakota, Alabama, Georgia, North
Carolina, Wisconsin, Florida and Washington.  Based upon a brief
literature review, telephone contacts with agricultural and environmental
staff in these states, and review of the criteria mentioned above, we
selected Iowa, California, Mississippi and New York for the field
studies.  A fifth state was to be selected, if necessary, based upon the
results of the initial four studies.   It was subsequently concluded that
it would be more effective to continue and expand telephone contacts
with several states to assess the types of environmental and health
problems encountered with pesticide and container disposal and to identify
any new techniques or information on disposal, rather than conduct a
fifth in-depth field study.
                                   35

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     Prior to each field study and where readily available, we developed
background information on each state including:  agricultural production,
pesticide usage, major pesticide distributors, formulators, and dealers,
cognizant agricultural and environmental agencies, and other potential
companies and disposal contractors.  A series of questions or discussion
topics for major participants in the field studies—state agencies,
dealers, farmers, etc.—was prepared.

     In each field study we attempted to meet with:  regulatory and
administrative agencies—state and local agricultural and environmental
agency staff, university extension services staff; companies or persons
involved in pesticide distribution and sale—pesticide formulators,
distributors, dealers; pesticide users—ground and aerial applicators,
farmers; persons involved with pesticide and container disposal—
disposal contractors, cooperage firms, drum reconditioners, landfill
operators; and other interested parties—agricultural chemical
associations, equipment manufacturers, etc.

     All persons contacted were very cooperative in providing available
information and expressing their attitudes on pesticide and container
disposal.  We were somewhat disappointed at the apparent lack of hard
data on pesticide and container usage, numbers of containers disposed
of by alternative methods, costs of actual disposal operations, and
documented evidence of health or environmental damage caused by improper
pesticide or container disposal.

B.   IOWA FIELD STUDY

     1.  Overview of Agriculture in Iowa

     Iowa's economy is dominated by agriculture and industry related to
agriculture.  Approximately 18% of Iowa's total labor force (about
210,000 persons) is employed on the farm.  Another 16% of the labor
force is employed by enterprises directly related to agriculture, while
another 46% of the labor force hold jobs that are indirectly related to
farming.  Thus, 80% of Iowa's total employment is directly or indirectly
related to agriculture.  Approximately 95% of Iowa's total land area is
devoted to farmland; the production of crops accounts for about 55% of
total land use in the state.  Thus, from the perspective of employment,
land use, and personal income, agriculture is very significant in the
economy of Iowa.

     The agriculture of Iowa revolves around the feeding of hogs and
cattle.  Iowa ranks number 1 in the nation as a producer of hogs, and
number 2 or 3 as a producer of cattle.  During 1971-1973, Iowa accounted
for approximately 22.5% of the U.S. hog production and approximately 7%
of the U.S. cattle production.  Iowa also ranks number 1 as the nation's
producer of corn and number 2 as the nation's producer of soybeans.
Table 14 shows the major crops grown in Iowa, the 1971-1973 average number
of acres harvested for each crop, total production, and total farm value.
                                 36

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           Table 14.  Acreage Harvested, Total Production and Farm
Crop
Corn (for grain)
Soybeans
Hay (all varieties)
Oats
Corn (for silage)
Grain Sorghum
Winter Wheat
Sorghum (for silage)
Irish Potatoes
Apples
Sweet Corn
Pop Corn
Value of Iowa's Major Crops,
Acreage
Harvested
1,000 acres
11,100
6,467
2,377
1,375
605
52
32
17
3.0
N.A.
9.2
39.0
1971-73 Average
Production
1,000 units
1,203,933 bu.
221,117 bu.
6,996 tons
75,433 bu.
9,171 tons
4,353 bu.
1,154 bu.
234 tons
598 cwt.
11,400 Ibs
8,950 cwt.
126,517 Ibs.
Farm Value
1,000 dollars
1,823,413
998,163
167,672
60,472
N. A.
4,923
2,098
N. A.
1,691
1,225
983
N. A.
N. A.   Not Available
Source:  U.S. Department of Agriculture
                                      37

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During this period Iowa accounted for 18% of U.S. corn acreage and
21% of U.S. corn production; 13% of U.S. soybean acreage and 16% of
U.S. soybean production; and 4% of U.S. hay acreage and 5% of U.S. hay
production.  Much of Iowa's corn and soybean production is fed to Iowa's
hogs and cattle.

     2.   Pesticide Use in Iowa

     The state of Iowa does not require pesticide distributors or farmers
to report on the quantities of pesticides sold or used each year.
However, von Rvimker  (1972) has estimated on a regional basis the quantities
of major chemical pesticides used on corn, soybeans, and small grains in
the five state area of Illinois, Iowa, Kansas, Minnesota, and Missouri
for the 1971 growing season.  Her estimates for  the five state region
appear in Table 15.     In 1971, Iowa accounted for 36% of the corn
acreage and 28% of the soybean acreage in those  five states. Assuming
that the pesticide usage patterns are roughly the same in these five
states for  the major crops of corn and soybeans, Iowa farmers applied
approximately 20.5 million pounds of herbicides  on corn, 6.9 million
pounds of herbicides on soybeans, and 8.3 million pounds of insecticides
on corn during 1971.

     Ryan  conducted a  survey of  farmers, pesticide dealers, commercial
applicators, and householders in Iowa  to determine the attitudes  of
pesticide  users and handlers.  As a part of this survey he  asked
farmers what basic type of pesticides  they used  during 1972.  Of  the
1974 farmers responding, 153 (87.9%) indicated thev used pesticides
in  1972.   Table 16 indicates the types of pesticides used as the
percentage of responding farmers who used these  pesticides.

     Wallace's  Farmer  (WF) is an Iowa  farm publication which periodically
conducts a random survey of its  subscribers to determine  the use  of
agricultural chemicals  and  fertilizers among  its readership.  A question-
naire was  mailed by WF  in 1972  to which 696 farmers responded.

      According to the  returned  questionnaires,  87% of all  the respondents
used some  kind  of herbicide during 1972.  Table  17 indicates the  principal
weeds for  which the herbicides were applied and  the percentage of farmers
who used herbicides.

      Of all the respondents who raised corn, approximately 86% used  a
herbicide  on their corn crop.  Eighty-eight  (88%) percent applied the
herbicide  only  once, while 10% applied a herbicide twice.   Table  18
indicates  the herbicides most commonly used on corn and the type  of
formulation applied.

      Of the respondents who raised soybeans, 81% of them used a  herbicide
on  this  crop.  Ninety-six  (96%)  percent of these treated only one time
while the  remainder treated twice.  Table 19  indicates the  herbicides
most commonly used on  soybeans and the  type of formulation  applied.
                                 38

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  Table 15.   Estimated Quantities of Herbicides and Insecticides Used in
      the Five-State Area of Illinois, Iowa, Kansas, Minnesota and
         Missouri on Corn, Soybeans, and Small Grains in 1971
Insecticides
                 Chemical Name
Adlrin
Bux
Heptachlor
Phorate
Toxaphene
Carbaryl
Diazinon
DDT
Parathion
                          Crop
                                        corn
                                        corn
                                        corn
                                        corn
                                        corn
                                        corn
                                        corn
                                        corn
                                        corn
                                                   Total
   1000 Ib  of
Active Ingredient
Herbicides Atrazine
Propachlor
Amiben
Alachlor
Alachlor
2,4-D Type
2,4-D Type
Trifluralin

corn
corn
soybeans
soybeans
corn
corn
small grains
soybeans
Total
30,000
18,700
13,600
7,100
4,350
3,825
3,200
3,970
84,745
                                             Grand Total
 11,000
  2,800
  2,660
  2,364
  2,000
  1,200
    662
    200
 	80
 22,966

107,711
Source: von Riimker, 1972.
                                  39

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     Table 16.   Percentage of Iowa Farmers Responding to Survey
       Questionnaire Who Applied Various Types of Pesticides
Type of Pesticide                              Percentage of Use

Herbicides                                            87
Crop Insecticides                                     63
Seed Pesticides                                       19
Stored grain insecticides                              1
Livestock or poultry insecticides                     54
   (applied on animals)
Food additive insecticides                            16
Fly control insecticides                              54
   (not applied on animals)
Crop fungicides                                        1
Rodenticides                                          28
Other pesticides                                       1

Source:  Ryan, 1974
       Table 17.  Principal Weeds for Which Chemical Herbicides
                          Were Applied - Iowa
                                                         *
     Weed                                         Percent

     Foxtail                                        54.2
     Thistle                                        36.2
     Smartweed                                      29.6
     Butterprint (Buttonweed)                       26.7
     Cocklebur                                      20.0
     Pigweed                                         9.0
     Sunflower                                       8.6
     Quackgrass                                      8.1
     Broadleaf weeds                                 7.5

     *
      Percentages are based on the respondents who used herbicides
      on their farm.

     Source:  Wallace's Farmer Agricultural Chemical and
              Fertilizer Survey, 1972.
                                   40

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  Table 18.  Principal Herbicides and Formulations Used on
                         Corn - Iowa
                      Principal Herbicides
AAtrex

2,4-D

Ramrod

Lasso

Banvel

Sutan

Atrazine/Lorox

Bladex

Ramrod/Atrazine
Percent

 49.6

 28.6

 25.2

 19.2

  6.7

  6.5

  4.7

  4.7

  3.3
                         Formulations
Liquid

Wettable powder

Granular
 58.4

 44.0

 29.0
 Percentages are based on the respondents who used herbicides
 on their farm/
Source:  Wallace's Farmer Agricultural Chemical and Fertilizer
         Survey, 1972.
                                41

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   Table 19.   Principal  Herbicides  and  Formulations  Used  on
                       Soybeans  - Iowa
                       Principal Herbicides
                                                               *
                                                        Percent

 Amiben                                                  43.8
 Treflan                                                 40.0
 Lasso                                                   21.0
 C.I.P.C.                                                  4.3
 Preforan                                                  2.7
 Lorox                                                    2.5

                         Formulations
 Liquid                                                  60.2
 Granular                                                 39.8
 Wettable  powder                                           4.3
  Table 20. 	Principal Types  of  Soil Insects  Treated  and
   Principal Chemicals Used  for Control of  SoilUnseats
                         Soil Insects
                                                               **
                                                        Percent

 Rootworms                                               84.9
 Cut worms                                               34.5
 Wire worms                                              26.3
 Maggots and beetles                                     11.2
 Root lice                                                8.2
 Grubs                                                    7.7

                     Principal Chemicals

 Aldrin                                                  34.9
 Bux                                                     31.5
 Thimet                                                  28.8
 Furadan                                                 14.7
 Heptachlor                                               8.3
 Dyfonate                                                 6.9
 Diazinon                                                 4.0
 Aldrex                                                   2.7
 Dasanit                                                  2.4


  Percentages are based on respondents who raised corn.
**
  Percentages are based on respondents who treated for soil insects.

 Source:  Wallace's Farmer Agricultural Chemical and Fertilizer
          Survey, 1972

                                 42

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      Of the farmers who raised corn, 57% of them indicated that they
used a soil insecticide on their corn crop.  The most common target
insects are shown in Table 20.  Of these farmers, 99% applied a soil
insecticide once, while the other 1% applied it twice.  Table 20 also
shows the chemicals commonly used as a soil insecticide for corn.

     3.  Pesticide Distribution System

     The pesticide distributon system in  Iowa  can be  described  as having
 five levels as shown  in  Figure 2.   The  arrows  indicate  the typical
 flow of chemicals.  There  are several exceptions to the  flow indicated
 in  the figure.   Local co-ops  occasionally purchase from an independent
 distibutor; similarly an independent  dealer may  purchase from a regional
 co-op.  Chemicals will sometimes be transported  from  a  producer directly
 to  a local co-op with the  regional  co-op  serving as an  ordering house
 and transportation coordinator.

     Some firms  perform  more  than one function in the system.   For
 example, some local co-ops in Iowa  also serve  as commercial applicators
 for their farmers.  Some independent  dealers are also commercial applic-
 ators.  Farmers  often serve as applicators for their  farmer neighbors.
 Several private  firms both wholesale  and  retail  pesticides.

     Table 21 indicates  the estimated number of  firms in the pesticide
 distribution system in Iowa.  These estimates  are based  on a synthesis
 of  conversations with government and  industry  personnel in the  State,
 and are intended only to indicate the rough number of participants  in the
 distribution channels.

     4.  Magnitude of the  Pesticide and Container Disposal Problem

     In addition to determining  the attitudes  toward  pesticide  container
 disposal on the  part  of  farmers, dealers,  commercial  applicators and
 householders, Ryan  (1974)  also attempted  to ascertain the magnitude of
 the disposal problem. Based  on  responses from 174 farmers, 87  applicators
 and 204 householders, Ryan estimated  the  number  of pesticide containers
 that required disposal in  1972 as shown in Table 22.

     Ryan's questionnaire  also asked  pesticide users  if  they had any
 empty  containers on hand at the  time  for  disposal.  Table 23 indicates
 the percentage of  each group  of  respondents who  said  they did have  empty
 containers requiring  disposal along with  an estimate  of  the number  of
 such containers  held  in  the State.    Unfortunately, Ryan did not estimate
 the number of pesticide  containers  by type, i.e., paper bags, 5-gallon
 metal  cans, glass  or  plastic  containers,  or 30 or 55  metal drums.

     Table 24 shows the  typical  types of  containers for  the more
 common pesticides used in  Iowa.  Discussions with industry personnel
 indicate that approximately 50-60%  of pesticides used in Iowa are market-
 ed  in  paper bags or cartons.  The remainder are  sold  in 1-gallon or 5-
 gallon metal cans, with  few 30-gallon or  55-gallon netal drums, 1-gallon
                                  43

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      Figure 2.   Pesticide Distribution System in Iowa
REGIONAL

COOPERATIVES
LOCAL
COOPERATIVES
                     PRODUCER
                       (Formulator)
                    FORMULATOR
COMMERCIAL
APPLICATORS
                    INDEPENDENT

                    DISTRIBUTORS
INDEPENDENT
DEALERS
                       FARMERS
                            44

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   Table 21.   Type and Estimated Number of Firms in the Pesticide
                  Distribution System in Iowa
Type of Firm                                           Number

Formulator                                                  2
Regional Cooperatives                                       3
Independent Distributors                                 25-50
Local Co-ops                                           550-600
Independent Dealers                                       >500
Aerial Applicators                                      50-100
Ground Applicators                                     800-900
Farmers                                                137,000

Source:  Arthur D. Little, Inc. estimates
         based upon discussions with state
         and industry groups.
   Table 22.   Estimated Number of Empty Pesticide Containers
                    Disposed of in Iowa During 1972
User                                           No. of Containers

Farmer                                            3,050,000

Commercial applicator                               480,000

Householder                                       1,940,000


Source:  Ryan, 1974
                               45

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Table 23.  Percentage of Questionnaire Respondents in Iowa Who
           Possessed Containers Requiring Disposal, and the
           Estimated Number of Such Containers in Iowa in 1972
                      Percentage  of Respondents      Estimated Number  of
  User                 Having Empty Containers      Empty  Containers  in Iowa
  Farmer                          7.5                       94,000
  Commercial Applicator          14.0                       11,300
  Pesticide Dealer              17.1                       48,100
  Householder                    3.5                       18.600
     Total                                               172,000

  Source:   Ryan,  1974
     Table 24.   Typical Containers for Pesticides Commonly Used in
                               Iowa
  Name of Pesticide                  Type of Container

  AAtrex                             paper bags and metal cans
  2,4-D                              paper bags and metal cans
  Ramrod                             paper bags
  Lasso                              paper bags and metal cans
  Amiben                             paper bags
  Treflan                            metal cans
  Aldrin                             paper bags and metal cans
  Bux                                paper bags and metal cans
  Thimet                             paper bags
  Furadan                            paper bags

  Source: Personal communication, Mr. Everret Leach, Land 0'Lakes,
           inc., Fort Dodge, Iowa
                               46

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or 5-gallon plastic containers, and glass bottles.  Thus, of the three
million containers disposed of by farmers, almost two million are paper
bags or cartons, and perhaps 700,000-800,000 are metal containers, if
Ryan's estimates are correct.

     As discussed earlier, a typical Iowa farmer grows primarily corn and
soybeans and feeds cattle and hogs.  A typical farm would be about 250 acres
with 120 acres devoted to corn production and 70 acres devoted to soybean
production.  Some of the remaining land would be used to produce alfalfa
or small grains and a small portion would be used for farm buildings.

     Normally one application of a herbicide, such as AAtrex, would be
applied to the corn acreage after planting but before plant emergence.
The farmer might use 90 small paper bags of AAtrex.  The empty bags
would typically be burned in the field at application time.  Usually one
application of a herbicide, such as Amiben, would be applied to the soybean
crop—between planting and preemergence.  From this application the
farmer may have about fifteen 5-gallon cans requiring disposal.  From
the application of a soil insecticide on the corn acreage, the typical
farmer might be left with ten 5-gallon empty containers or he might apply
in granular form which uses paper bags.

      Pesticide control on the smaller crops and fly control in the
cattle operation would typically result in several more empty containers.
Thus the typical farmer might end up with twenty to thirty 5-gallon con-
tainers to be disposed of each year and perhaps 100 empty bags of other
chemicals.  These estimates would give a somewhat higher total than
Ryan's estimates.

      Ryan also investigated the magnitude of the problem of unwanted,
illegal, or obsolete pesticides.  Table 25 indicates the percentage of
respondents who currently had unwanted pesticides, and an estimate of
the statewide quantities of unwanted pesticide in 1972.


      5.   Status of  Regulations and State Policies on Pesticide Disposal

     In 1975, the State of Iowa had no regulations or policies  specifically
 pertaining to the disposal of  pesticides and pesticide containers.   It is
 illegal to burn pesticide containers  (bags,  and cardboard boxes)  but a
 farmer may dispose  of  them on  his own property, provided he does  not en-
 danger the public health and welfare.

      The  Deparmtent of  Environmental  Quality,  Solid  Waste Division, was
 preparing legislation  for the  1975 state legislature.   These laws will
 follow EPA guidelines  concerning pesticide and container disposal.

      As of July 1,  1975 all open dumps will be closed.   Only approved
 sanitary  landfills  will be allowed to accept pesticide containers.   How-
 ever,  there are no  approved sites for sanitary landfills at present  nor
 have criteria for approving these sites been established.
                                 47

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     6.  Current Disposal Practices

     The methods for pesticide and container disposal currently practiced
in Iowa are very loosely structured.  This is due in part to the lack of
specific regulations and part due to the relatively low significance given
to the disposal problem.  In general, the comments we obtained on the
disposal of specific types of containers were substantially the same from
most of those people interviewed.  Views of various persons directly con-
nected with or interested in this disposal problem are given below.

     The Chemical Technology Commission of the Land Division of the
Department of Environmental Quality (DEQ) is responsible for the develop-
ment of the laws and programs pertaining to pesticide and container
disposal.  Although there is currently no official policy regarding con-
tainer disposal, as of July 1, 1975, all open dumps in the State will be
closed and any remaining landfills will have to be managed.  The require-
ments of a "properly managed dump," if enforced, will make it more
difficult for most people to dispose of containers.

     The State environmental and agricultural staff feel that some pesticide
containers are taken to landfills, but that a farmer who has only a few
containers probably buries (or burns) them on this property.  State staff
believe that burial on private property does not generally create a hazard
to public health and may be more desirable than concentrating the
materials at one location, such as a landfill.  The containers that
eventually reach a landfill are not likely to have been rinsed or punctured.
Farmers most often burn their pesticide bags along with their seed and
fertilizer bags.  Although it is illegal to burn pesticide bags or card-
board cartons in the field, the DEQ recognizes that most farmers burn
them anyway and the regulation is not enforced.  State staff believed that
most distributors did not "want to be bothered" with the disposal
problem and that chemical companies are becoming increasingly interested
in bulk deliveries to distributors and dealers.

      With regard  to unused pesticides,  the view of  the  State  staff  is
 that  the problem  and  its  solution is mainly with the dealer.  The  reasons
 for quantities  of  unwanted pesticides remaining on  hand were:

      1.   A chemical being banned  or suspended;
      2.   A chemical becoming  unpopular  with farmers;
      3.   A carton, bag, or can of  pesticide becoming adulterated;
      4.   Containers beginning to  leak;
      5.   Stockpiling  for  various  reasons; or
      6.   A sudden  increase in an  insect's resistance to a  particular
          pesticide.

While  they felt that  the  farmers usually have  small quantities of unused
pesticides which  they usually apply as  directed,  they were unsure as to
what dealers did with unwanted pesticides.  The consensus  was that  the
manufacturer and/or the distributors/dealers should assume some responsi-
bility for  disposal of unused pesticides.
                                  49

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     The Iowa Fertilizer and Chemical Association is concerned with the
container disposal problem.   They have printed and distributed about
35,000 brochures which outline their recommended procedures—triple
rinsing the 5-gallon can and draining it before puncturing and disposing
of it by burial.  They believe that farmers are better at following
these guidelines than are commercial applicators, because applicators
are often working under great time pressure and do not have the time to
triple rinse during their application process.

     The association staff felt that most landfill operators in the State
do not want agricultural chemical containers to be disposed of in these
sites.  Thus, they believe that most farmers simply throw their empty
containers in the ditch or pile them in a grove somewhere, rather than
dispose of them in a more satisfactory manner.

     They believe that producers and formulators do not wish to refill
empty or reconditioned containers because of the cross-contamination
problem.  There are, however, two drum reconditioners in the State—
Des Moines Barrel and Drum Co., and Scott Drum Co.

     The Des Moines Barrel and Drum Co. no longer desires to recondition
pesticide drums since two of their employees became very sick several
years ago after cleaning out some pesticide drums without taking the
proper precautions.  They are willing to accept drums of "non-toxic"
pesticides, mostly herbicides.  Drum reconditioning is not widespread,
however.

      Several individuals at Iowa State University have been interested
in the  pesticide and container disposal problem.  Ryan's study (using a
mailed  questionnaire) asked the question, "How do you most frequently
dispose of your empty pesticide containers?"  The results are summarized
in Table  26 for farmers and commercial applicators.  The general
range of  responses to these questions is about the same as we obtained
through the limited sample of farmers and dealers we contacted in person
in this study.  Most farmers bury or burn containers; few take them to
landfills or dumps.  Most applicators burn paper containers and bring
metal or  plastic ones to landfills or dumps.  The methods most frequently
used  for  disposal of unwanted pesticides, found by Ryan, are shown in
Table 27.

      Ryan's major  conclusions  concerning  the  disposal problem is  that
"unwanted pesticides and  containers  are being primarily disposed  of  in
ways  that can  be  considered unsafe."  Ryan  believes  that  the  farmer  is
the  principal  problem  in  the disposal  situation  and  the  one who  is  least
committed to safe and  correct  disposal.   He also feels  that  too many
individuals  are involved  in the distribution  and use of  pesticides  and
recommends stricter  licensing  procedures.
                                   50

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                 Table 26>   Disposal Methods for Container
METHOD
Burn on private property
Bury on private property
Take to landfill
Take to dump
Burn in city incinerator
Leave in field where used
Put in ditch or ravine
Return to dealer
Use for storing pesticides
Use for storing other substances
Throw in trash pickup
Take to cooperage or
reconditioning firm
Store
% RESPONDENTS
COMMERCIAL
APPLICATOR
44.2
12.8
57.0
24.4
0
4.6
0
4.7
1.2
7.0
5.8
3.4
4.7
USING METHODS
FARMER
83.6
24.0
26.0
17.8
0.7
2.1
6.2
6.7
2.7
2.1
2.7
1.4
1.4
Source:   Ryan,  1974
                                    51

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               Table 27.  Disposal  of Unwanted Pesticides

% OF RESPONDENTS USING METHOD
METHOD
Pour on ground
Pour over area designed
for hazardous waste
Apply as intended
Bury
Burn
Take to landfill
Take to dump
Place in ditch or ravine
Return to dealer or distributor
Throw in trash pickup
Give to someone who needs it
Store
Other
Note: One farmer reported pouring
septic system.
COMMERCIAL
APPLICATORS
0
0
18.5
44.4
7.4
33.3
0
0
40.7
0
18.5
11.1
0
the pesticide
DEALER
9.8
6.6
32.8
39.3
18.0
39.3
18.0
1.6
31.1
1.6
27.9
26.2
1.6
down the
FARMERS
12.2
0
39.0
26.8
26.8
31.7
14.6
2.4
19.5
2.4
9.8
24.4
0
drain to a
Source:  Ryan,  1974
                                  52

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     Other individuals at the University have dealt with the disposal
of pesticides. At one time extension service staff sent all of their
material to the Dow Company incinerator in Midland, Michigan.  Dow will
no longer accept unused pesticides, however.  Following this, they sent
about 100 barrels of unused pesticides to an AEC disposal site in Illinois.
This site is no longer accepting material either.  Now a sizable quantity
of pesticide is stored in an old bunker within the State and the University
staff continue to store material rather than dispose of it in any way.
The feasibility of disposing of pesticides in an incinerator is being
studied.  Plans are to "update" an existing incinerator and conduct a
test program.

     We interviewed two of the three major regional co-ops which operate
in Iowa.  The staff at one co-op believe that most farmers triple rinse
and drain the cans and then either throw the containers away in the field
or bring them to a landfill or dump, if one is close to their farm.  Bags
are generally burned in the field or at the mixing site.

     With regard to commercial applicators, this co-op staff believe that
the operators have less of a problem than the farmers.  The commercial
applicators usually have a fenced-off area to store containers and most
of the empty containers are disposed of in a landfill.  They feel that
commercial applicators either burn bags in the field o'r bring them back
to the applicator's property to be burned.

     The co-op's policy is that damaged bags can be returned but they try
to avoid accepting any partial containers or damaged bags.  They will
usually give a price break to the local co-op and ask them to dispose of
it or give it to a good customer.

     The people at another regional co-op had a slightly different im-
pression of the disposal practices.  They believe that paper bags and
cartons are generally burned in the field immediately after use and very
few farmers bother to bury these containers.  The 5-gallon metal containers
are typically thrown in the farm dump, stored in a shed or just deserted
along the edge of the field.  In a few cases, they said farmers might try
to take them to a local dump, but this is probably a very small portion of
farmers in the State.  Plastic containers, they believe, are burned in the
field or deserted the way metal containers are deserted.  Larger containers
(drums), which commercial applicators have, are likely sold to a
reconditioner or to various other people for unspecified uses.

     The co-op staff felt that the major disposal problems fall into two
basic categories:

     1.  Pesticide containers—mainly a farmer's problem; commercial
         applicators probably can "afford" to go to a landfill because
         of the large numbers they have; and

     2.  Unwanted pesticides—resides with the pesticide dealer;
         they do not know how to handle this problem.
                                    53

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     The local co-ops who are distributors, and sometimes commercial
applicators, are closer to the user than are the regional co-ops and
have a different perspective on the disposal problem.

     One local co-op which operates a commercial application service,
said that the employees bring cans back to the co-op and when a large
number is collected, the containers are taken to a dump.  At the dump,
the containers are run over by a tractor and buried.  This is said to
be atypical of most dumps in Iowa.  Sometimes applicators bury the cans
on the farmer's property, if the owner gives permission.  The other
alternative is to dig a pit on the applicator's own property and dump
the cans in it after crushing them with a tractor.  Bags are generally
burned in the field.  Triple rinsing is not done because it is too time-
consuming .

     Another local co-op commercial applicator generally rinses the cans
and lets them drain.  He then takes them to a nearby sanitation service
(for dumping).  Bags are burned in the field or brought back to the
co-op.

     Another local co-op occasionally has unwanted pesticides which they
either sell at a reduced price or price or may ask a farmer to spread on
field free of charge.  The containers from their commercial application
service are disposed of in a nearby municipal sanitary landfill, which
covers and packs every day.  Bags and cartons are burned in the field.

     Independent dealers, many of whom operate commercial application
services, gave us their views of the farmers' practices and their own.
One independent dealer was unsure how many containers actually are rinsed
but he does feel that most containers are taken to a landfill.  Bags are
burned in the field.

     Three other independent dealers we interviewed  (who are also commercial
applicators) indicated that they do not rinse cans because of the time
factor.  All brought their containers to a landfill.  Two of them also
brought paper bags, the other dealer burns the bags  in the field.  They
believe that very few farmers rinse the cans.  Most  farmers, they thought,
burn bags and dump cans in the field or on the farm  trash pile.  One of
the dealer-applicators indicated that farmers may also use the cans for
other purposes on the farm.

     Dealers' comments on the fate of unwanted pesticides included:

     •  Pouring on ground,
     •  Applying in recommended manner,
     •  Burning, and
     •  Landfilling.
                                   54

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     One aerial applicator interviewed indicated that he may rinse some
of the containers at the end of the day and use the rinse water for mak-
ing up the next day's batch of pesticides.   He brings his containers to
the county dump.  Bags are usually burned in an old 55-gallon drum on
the airport property.

     With respect to existing disposal facilities, there is no suitable
incinerator for pesticides in Iowa.  There are two drum reconditioners
who accept a small number of containers for reconditioning.  There are
no approved landfills for pesticide disposal; a large number of local
dumps have been used for disposal of containers and pesticides.  There
is one storage area used by State University staff for unwanted or excess
pesticides; this is not suitable for increased use by others in the
State.

     7.  Cost of Disposal Practices

     Information on the cost of disposal in Iowa was limited due to
the lack of structured, formal disposal operations.  The economic data
that were obtained in interviews is summarized below.

     •  Typical dealer/applicator pays "about $4 per truckload" to
        dispose of unrinsed, uncrushed containers in the local dump.

     •  A disposal company in a nearby state will incinerate containers
        based on the type of material which the container held.  For
        30- to 50-gallon drums, the charges per container are:

           $13.00-$20.00—halogenated liquids
           $ 8.50-$15.00—flammable materials
           $11.00-$18.00—semi-solid materials
           $18.00-$25.00—solidified material

        All prices are based on a concentration of 20% or less.  An
        increased concentration will increase the disposal cost.

     •  At one cooperative there is a deposit system in effect for
        oil drums.  The charges are:  15-gallon -  $5.00; 30-gallon -
        $8.00; 55-gallon - $10.00.

     •  A reconditioned drum sells for about $5.50, but the purchase
        price for drums to be reconditioned could not be determined.

     8.  Attitudes Toward and Acceptance of Disposal Methods

     In our discussions with distributors, dealers, applicators and others
contacted in this study, we inquired about the methods they thought were
most feasible and desirable, those they thought were not useful, and
their general attitude and acceptance of various methods of container
and pesticide disposal.  Following is a discussion of general attitudes
and acceptance of disposal methods and comments of those we interviewed
on specific methods.
                                 55

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     a.  General Attitudes and Acceptance

     There are considerable differences in the general attitudes of
distributors and users regarding disposal of pesticides and con-
tainers.  For example, the study by Ryan (1974) indicated that a number
of farmers, applicators, and dealers would be willing to pay for pesti-
cide and container disposal.  In Ryan's survey, 75% of the applicators,
85% of the pesticide dealers, and 71% of farmers indicated that there
was a need for a disposal system in Iowa for unwanted pesticides and
pesticide containers.  Sixty-one percent of the applicators, 82% of the
dealers, and 48% of the farmers indicated they would be willing to pay
a fee for disposal of empty pesticide containers and unwanted pesticides.
Applicators were generally willing to pay $20-50 or more per year;
pesticide dealers were also willing to pay similar amounts.  No farmer,
on the other hand, felt it would be worth paying more than $10 per year
for a disposal service.  Sixty percent of the applicators, 50% of the
dealers, and 68%  of the farmers indicated that any disposal fees should
be included in the pesticide purchase price.  Eighty-nine percent of the
applicators, 90% of the dealers, and 82% of the farmers indicated they
would be willing to deliver pesticides and containers to a safe disposal
site at their own expense.  Applicators generally were willing to travel
up to 50 miles for disposal; pesticide dealers were willing to travel
50 or more miles, but farmers generally were not willing to travel more
than 25 miles for safe disposal.

     We obtained a mixed reaction from distributors and dealers on their
role in the disposal process.  For example, one dealer believed that
most dealers, applicators and distributors would cooperate and participate
in any organized disposal practices.  He felt that the weakest link
would be to get the small farmer to return pesticide containers to a
place where they could be properly handled.  Another pesticide dealer
indicated that he would like to operate a service whereby farmers could
return empty containers when they want full ones or when they buy
present time because he has no place to store pesticide containers and
no easy way to dispose of them.  He believed that if he offered the
service, farmers would of their own accord bring the cans because
farmers are concerned with the hazards involved and the appearance of
their farms.

     One regional cooperative indicated that 4 or 5 of the cooperatives
have encouraged farmers to bring containers back to the local co-op for
disposal.  This was done primarily for "good will" to encourage the
farmer to buy the co-op products.  It was felt that if a sufficient
number of acceptable sites could be established for disposal, more local
co-ops would be willing to participate in such a disposal system.

     On the other hand, several distributors and dealers felt that
they do not want to get into the disposal business and that  someone else
should specialize in it.  Some felt that the most practical  solution
was to have a state agency or disposal system contractor operate
                                 56

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disposal sites and a collection system.  The basic point made by some
was to reduce the number of transfers of empty containers from farmers
to dealers to co-ops to disposal site and to make the disposal process
as direct as possible.  This was felt to be particularly important in
a state such as Iowa where containers are well distributed throughout
the State and the logistics of the disposal system are important.

     One dealer/applicator indicated that a 25-50 mile trip for disposal
of containers would be acceptable to him since he has several hundred
containers to dispose of each spring.  However, he felt that the farmer
would not return containers to him nor would he like to accumulate
the cans or dispose of them.

     A different viewpoint was expressed by a commercial applicator
who indicated the manufacturers should bear some of the costs of the
disposal of containers.

     In general, most people interviewed were concerned about the
disposal of containers and were seeking a solution.  A potential solu-
tion offered by regional co-ops was to have a larger percentage of
pesticides delivered in bulk.  They expected that the amount of pesti-
cides applied by commercial applicators will increase, and as a result,
there would be a greater need and opportunity to have more chemicals
delivered in bulk tanks.  This would eliminate part of the need for
disposing of empty containers,  however  it would not affect  the  disposal
problems of the smaller farmers and those who do not use commercial
applicators.

     A suggestion proposed for 5-gallon metal containers was to make
the container of even thinner stock than now used so that there would
be little likelihood for farmers,or anyone else to reuse the container
for other purposes after the pesticides had been applied.  This
alternative does not seem very practical since many dealers and distri-
butors already claim problems with leaking cans and cans damaged in
transit.

     With regard  to pesticide disposal, most people felt that, except
for pesticides  that were no  longer registered,  there was little problem
with unused or  unwanted pesticides.  Most believed that the best way
to handle excess  pesticides was to have farmers use them as they
originally  intended.   Several people felt that  as  a result of pesticide
shortages and the increase  in costs of pesticides  there were far fewer
excess  pesticides left  on the farm, and as a result, there are fewer
problems of pesticide disposal.

     b.  On the Farm Disposal

     Several regional  cooperatives believe that the farmer now has an
acceptable, safe  and economical way to dispose  of  containers on or close
to his  farm.  The best  way  was to burn bags and to put containers in
a "safe" location on the farm or bring to a local  dump.  A common
                               57

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concept of "safe" location on the farm is not accepted by many;  t D the
farmer it may mean the trash pile or a back lot;  to others it may be
an approved, fenced location away from sv face vater; still others would
require the equivalent of an approved sanitary landfill.

     c.  Burning

     The general attitude of all persons interviewed was  that burning
of bags and cartons was an adequate and acceptable method of disposal
for paper containers.  The only precautions stressed were:  not too many
should be burned at one time*, people should stay out of the smoke; and
plastic coated bags might be rinsed and brought to landfills.  Several
people objected to bringing bags to landfills because they blew all
over and were a hazard.

     d.  Rinsing of Containers

     Although the triple rinse program has been emphasized by dealers, the
extension service, trade associations and state agricultural staff,
there is some question of its acceptance.  As mentioned in earlier
sections, commercial applicators often do not "have the time" to rinse
containers.

     Staff at the extension service have attempted to get farmers to
rinse containers by emphasizing the economics of the situation,  i.e.,
indicating that there are 5 or 6 ounces of good pesticide left in the
container which, if properly rinsed, can be used.  They believe, as do
several pesticide dealers, that redesign of containers would be very
useful so that little active ingredients will remain in the container
and that triple rinsing may not be necessary.

     Several regional and local cooperatives believe that less than 5%
of the farmers triple rinse containers at the present time.  As a result,
there could be toxic hazards in local dumps or county disposal sites.

      e.   Landfills

      In general,  state environmental and agricultural people believe
 the best procedure for the farmer in handling metal containers  is  to
 triple rinse and  puncture the containers and bring to an approved
 disposal site when they are set up.   If there are sufficient sites,
 both farmers and  commercial applicators should bring their containers
 to landfills.  Several dealers felt that landfills were  an acceptable
 practice and that portable crushing equipment should be  located at the
 landfill.

      On the other hand, there was opposition to  disposal of containers
 in landfills from several persons because:
                                 58

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     •  There was insufficient deterioration of containers and
        pesticides;

     •  There was insufficient space for good landfills;

     •  Landfills tend to concentrate the pesticides instead of
        having them distributed over farms; and

     •  Landfills were wasteful of the metal resource of most
        containers.

     f.  Incineration

     Practically all those contacted believed that incineration was an
acceptable means of disposal of pesticides provided that air pollution
problems did not result.  Several felt that incineration was the best
means for removal of residues from containers prior to their recycle or
reclamation.  Most people, however, felt that incineration was too
expensive a technique to use for routine disposal of containers (some
felt it uneconomical even for pesticides).  Only one person we contact-
ed suggested building one or more incinerators in the State.

     g.  Reuse and Recycling

     Most of those interviewed believed that reuse of containers was
practical only for 30-gallon and larger metal drums.  Several dealers
felt that this was an acceptable and needed practice and they would be
willing to participate.  However, they felt that there were inadequate
drum reconditioning facilities available.  (In Iowa, large containers
are not a popular size in the distribution system.)  Several felt that
direct reuse would be a problem as a result of labeling, safety, and
cross contamination.  Others thought that insecticide containers should
be reused because they were more dangerous, but that other containers
could be disposed of in the local dump or sold as scrap.

     There  was considerable  interest  in  the recycling—as  scrap—of
 smaller metal containers.  For  example,  one person  indicated  that
 crushing and recycling  of metal pesticide  containers was probably  the
 best solution to  the disposal problem since it would conserve resources.
 He  indicated that  portable crushing units may be useful but believed
 that the transportation costs would be prohibitive.  He suggested
 centralized collection  points to which crushed units could be delivered,
 even though this would  place a  greater burden on the farmer to transport
 empty  containers.   He believed  that the  basic problem was  one of
 logistics;  technology was already available.

     The staff of  a regional cooperative felt that  recycling  as scrap
 was probably the most economical and best way to proceed.  They also
 indicated the possibility of portable shredders at  dumps and  recycling
 combined with a deposit system  might be  the best alternative.  For
                                 59

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example, the recycle operation could be at a local landfill and provide
a return of 25<: per 5-gallon can to the farmer.  (Unless the price of
scrap increases significantly, the recycle operator could not afford
to pay so much per can.)  The regional co-op staff felt it would be
best to have an industrial organization operate the recycling process
and that the state or local government should not be involved in the
system.  They did not believe either a regional or local co-op should
operate landfills or a recycling process but indicated that they would
cooperate with whatever systems eventually evolve.

     Another co-op expressed interest in operating a pilot project in
which they would collect empty containers and pass them on to whomever
would clean and recycle the metal in an attempt to determine how well
the farmer would cooperate with the system.  The co-op operator express-
ed confidence that most farmers would return the cans, especially those
who used significant quantities of pesticides.  He indicated that farmers
who only used a few 5-gallon cans per year would not be very willing
to cooperate.

     Another regional cooperative indicated that it would be willing
to work with member co-ops to return containers or exchange them in a
recycle return process. They believe a large majority of farmers would
cooperate.  They do not believe that farmers like to litter their fields
or place pesticide containers in a location where hazards might result.
They believe that most farmers would be willing to cooperate with a
recycle or return system just on the basis of economics.  Such a system
seems to make sense to the farmers, and if the logistics and costs of
collection and return could be reduced, farmers would be willing to
participate.  An independent pesticide dealer believed that scraping
of cans would be the most effective way of disposal.  He thought that
it was a waste of resources to have the metal cans disposed of in a
landfill, but admitted that no present scheme for reuse and collection
could be profitable in view of the present price of scrap metal.  This
dealer believed that at some time, scrap metal costs may get to a point
where  it will become profitable for someone to collect cans.

      h.   Deposit Systems

      In general, dealers, cooperatives and applicators believed that a
 returnable deposit system—with the containers reused or recycled—
 might be acceptable.   Some felt it would only be acceptable for large
 metal containers; others  felt that small containers should also have a
 deposit.  From the general comments,  it was clear that little serious
 consideration had been given to a deposit system, how it would work,
 how much it would cost, and how the system would be financed.

      For example, a distributor felt that a returnable deposit system
 would be quite  feasible  but that the associated disposal activity would
 probably have to be subsidized to be economically attractive.   Typical
 deposits he suggested were in the order of 15c for 1-gallon containers,
 50c to $1 for a 5-gallon container, and $2.50 for a 30- or 50-gallon
 drum.
                                 60

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     One representative co-op indicated its willingness to cooperate
with a disposal system in which farmers would return empty containers
to the co-op for a deposit.  They felt that it would be advisable to
have a deposit for a 5-gallon or larger container of $1 to $3.  The
local co-op indicated that a deposit system was operating on containers
used for selling oil—the deposit for a 15-gallon oil container was $5,
$8 for 30-gallon containers, and $10 for 55-gallon drums.

     A commercial applicator believed that a deposit of 500 would not
be acceptable to a farmer; however a commercial applicator would accept
a 50£ deposit or even a 25
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     4.  Incineration of pesticides and/or containers was felt to be
         acceptable technically but probably too expensive to use except
         for disposal of large quantities of pesticides.

     5.  Rinsing of containers is not as well accepted as desired.

     6.  Other processes such as biodegradation, encapsulation, etc.,
         were not considered practical or feasible in Iowa.

     7.  Returnable deposit systems, particularly for larger containers,
         were considered to be acceptable to most people, provided
         farmers did not have to travel far to return containers and
         a reasonable deposit was offered.  Insufficient consideration
         has been given to the operation and costs of container deposit
         systems for their proper evaluation.

     9.  Environmental Effects

     The State of Iowa had  been tabulating incidents relating to
pesticide and container disposal for less than a year.  The following
four incidents were reported during the time period July 1, 1974 to
January 1, 1975.

     •  Several empty bags, and one which still contained one-third
        Dyfonate were disposed of on a brush pile in a pasture.  Cattle
        found these bags, and after licking them, five cattle became
        sick and two died.

     •  A mixing barrel of  Dioxathion was left in a cattle yard.
        Although the route  of exposure is not known, three cattle
        died from poisoning by this material and eight showed
        symptoms of subacute poisoning.

     •  A bag of lindane had been disposed of on a junk pile surrounded
        by a fence.  Cattle broke through this fence and ingested some
        lindane, resulting in four dead.  Laboratory tests showed
        residue of 440 ppm lindane in the rumen contents of some of
        the animals.

     •  A partially filled bag of Thimet was left in a grove.  After
        ingesting the material, four cattle died and two others showed
        symptoms of subacute poisoning.

     No incidents of health effects to humans were reported.
                                 62

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C.   CALIFORNIA—FIELD STUDY

     1.  Overview of Agriculture in California

     The importance of agriculture in California cannot be overemphasized.
California farmers produced $7.2 billion in agricultural commodities dur-
ing 1973; which was 8% of U.S. agricultural production and 6% of the state
income.  Recent farm income gains have been the result of sharply higher
prices, increased production for several major crops, and the addition
of nearly 350,000 acres to crop production.

     In 1972 approximately 281,000 persons were employed in California
agriculture (3.7% of total state employment and 6.4% of total U.S. farm
labor), although one job out of every three in the State depended on
agriculture either directly or indirectly.  Hired labor in California
comprises 75% of the total agricultural labor force, while for U.S. agri-
culture, hired labor is only 26%.

     Approximately 36 million acres or 36% of California's total land
area is in farms.  Of this, 8.4 million acres was under crop production
in 1973 and another 25.5 million was in permanent or temporary pasture.
While only 12% of U.S. cropland was irrigated in 1969, more than 7.2
million acres, or 88%, of land planted to crops in California was irrigated
that year.  California has 63,000 farms with an average size of 575 acres
in 1973 and an average valuation of $277,000 including buildings.
(Nationally, the average farm size in 1973 was 383 acres with an average
valuation of $90,960 including buildings.)  It is interesting to note
that California's 8% of U.S. farm production is produced on only 2% of
the nation's farms and on about 3% of the nation's farmland.  D"e to the high
level of mechanization and the wide use of irrigation, many large farms
specialize in one or two crops, usually high value crops such as vegetables
and fruits rather than the lower value commodities like grain or oilseeds.

     Of the over 200 crops produced in California, including seed, flowers
and ornamentals, more than 40 are commodities in which California leads
the nation in production.  A large number of these are specialty crops
(e.g., almonds, olives, artichokes, figs, garlic, etc.).  Table 28 shows
principal California crop production and value.  Almonds grow north of
Sacramento; cotton, forage crops, grapes, and figs near Fresno in the
San Joanquin Valley; and in the wet delta, asparagus, tomatoes, rice,
safflower, and sugar beets.  Premium wine grapes grow in the Napa and
Sonoma valleys north of San Francisco and in adjacent areas.  The Imperial
Valley in the Colorado Desert in the extreme south, though smaller than
the Central Valley, has about 500,000 irrigated acres, much of it devoted
to vegetables, barley, and certain fruits.  Other major farming areas
include the Coachella Valley near Palm Springs, where grapefruit and dates
are grown, and the Salinas Valley and Monterey Bay region, noted especially
for vegetable production.  Oranges are grown primarily from Los Angeles-
Riverside north to Fresno.
                                  63

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                   Table  28.
Grapes
Cotton Lint
Hay

Rice
Lettuce
Nursery Products
Tomatoes, Processing
Almonds
Oranges

Potatoes
Sugarbeets
Barley
Tomatoes, Fresh
Cut Flowers
Wheat
Walnuts
Prunes
Dry Beans
Peaches
Cottonseed
Strawberries
Lemons
Acreage, Production, Value. Share of
U.S.
Harvested
Acreage
(1000 acres)
453.4
942.2
1,725.0
401.0
141.6
NA
ig 218.0
213.7
188.8
68.2
265.0
940.0
30.8
NA
572.0
161.6
81.4
161.0
71.2
NA
8.1
41.1
Production, National Ranking 1973

Production
(1000 tons)
3,912.0
420.0
7,865.0
1,129.0
1,746.7
NA
4,861.4
134.0
1,578.8
1,060.4
6,440.0
1,150.6
343.0
NA
926.4
168.0
203.0
135.4
857.0
753.0
160.0
668.8

Value
(millions)
609
395
385
260
258
243
200
193
133
116
116
110
109
106
100
97
96
95
91
88
84
84
Share of U.S.
Production
(%)
90.8
13.5
5.8
24.3
70.1
18.7
81.9
99.9
16.1
6.2
26.2
11.3
35.4
22.5
1.8
99.5
98.8
16.1
65.1
14.4
67.0
79.3
                                                                             Production
                                                                             National
                                                                             Ranking	
 1
 3
 3

 2
 1
 1
 1
 1
 2

 4
 1
 3
 1
 1
14
 1
 1
 2
 1
 2
 1
 1
 Source:   Department  of  Food  and Agriculture, 1974, "California Agriculture:
          California's Principal Crop and Livestock Commodities, 1973,"  Sacramento,
          California.
                                          64

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     Cattle and calves and dairy productions are the two major agricultural
commodities in California in terms of value ($1,725 million and $694
million respectively), exceeding any of the field, fruit, or vegetable
crops produced in California in this respect.  Except for egg production,
California's livestock industry does not dominate the national scene as
it does for so many of the other agricultural commodities which it produces.

     The major cattle producing areas  of the State  are  the  Imperial
Valley  in  the south and  in Merced,  Fresno,  Tulare,  and  Kern counties
in the  Central Valley.   Major dairy producing regions are the  counties
west of Los Angeles and  the central and northern  counties of  the  San
Joaquin Valley.  The coastal counties  north of  San  Francisco  and  the
northern counties  of both the San Joaquin and Sacramento Valleys  are  the
principal  areas  of sheep husbandry,  while poultry products  tend to be
produced primarily in those areas near the  major  urban  areas  of the
State such as San  Francisco, Los Angeles, and San Diego.

     2.  Pesticide Use in California

     As expected from the size and  diversity of California  agriculture,
the use of pesticides in California is extremely  widespread and the
volume  applied is  quite  large.  In  1973 California's Pesticide Use
Report  indicates  that 183.7 million pounds of  pesticides of  all  varieties
were used  in the State.  This figure includes both  agricultural and non-
agricultural uses; however, it does not include those quantities  of
non-restricted materials which were applied by  farmers  rather  than
commercial applicators.   (A large number of chemicals are classified  as
restricted use in  California.  Permits are  required for the possession
and use of these materials.)  Consequently, total usage in  California
in 1973 is estimated between 200 and 220 million  pounds.  Chemical
industry representatives indicate that 1974 usage should be similar to
that of 1973.

     In fiscal year 1973-74, the cost  of all pesticides used  in
California was $273,000,000.  However, this includes all home  and garden
pesticides and products  such as Lysol  and Chlorox.  Approximately 47%
of this total, or  $128.3 million, was  used  in California agriculture.
In recent  years, California has typically used  20-22% of all  pesticides
applied for agricultural purposes in the United States  (excluding Puerto
Rico, Hawaii, and Alaska).

     The largest total market for pesticides in California is fruit,
vegetables, and horticultural crops.  However,  on a crop basis, the
biggest single market is cotton.  One chemical industry representative
we contacted felt that nearly half of all agricultural pesticides  used
in California in recent years was applied to cotton.  However, usage
patterns do change from year to year depending on the shifting severity
of various crop pests.
                                   65

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     Approximately 85% of all acreage treated by pesticides  in California
is treated by commercial applicators.  About 60-70% of pesticides are
applied by aerial applicators.   The proportion of aerial treatment is
generally very high on field crops and vegetables.   On the citrus and
other fruit crops, pesticides are generally applied by farmers or commercial
applicators using ground equipment.  There are a large number of aerial
applicators in the State who operate from 1 to 30 planes and/or helicopters.

     Tables 29 and 30 indicate the quantities of restricted pesticides
reported by the California Pesticide Use Report in 1973.

     3.  Pesticide Distribution System

     Although the pesticide distribution system in California may appear
quite complex, there is a basic flow pattern which is quite simple and
atypical of the rest of the U.S.  Figure 3 provides a detailed flow
diagram of the system which moves chemicals from the basic producer to
the end user.

     Of  the  approximately 40 manufacturers  (basic producers)  of  technical
pesticides in the United States,  few actually produce  the materials  in
California.  Several  basic  producers have plants in California which
further  process  technical materials  prior to their formulation.   Both
technical materials and finished  pesticide products are shipped  into
California to the State's formulators.  The  formulators not  only combine
materials into pesticides,  but  frequently act as distributors and
dealers.  Most dealers do not formulate but  simply purchase  finished
products from the formulator and/or  the basic producer  for sale  to
applicator or farmers. Many applicators buy directly from the formulator
 (and occasionally the basic producer), bypassing the dealer  entirely.

     There are several examples in California where the basic producer
controls the flow of  pesticides from manufacture to their ultimate
application  on an agricultural  crop.  Union  Carbide's  Soil Serv,  Inc.,
in  Salinas,  and  Shell Chemical  Company's Western Farm  Service,  Inc.,
in  San Ramon, act as  formulators,  distributors, dealers, pest control
consultants, and applicators.   These firms purchase technical materials
and pesticides from basic producers  other than  their respective  parent
companies as required to meet the varied demand.

     Unlike  many other  states,  cooperatives  do  not play a significant
role in  pesticide distribution  process  in California,   Farm  Bureau has
affiliated outlets handling farm  supply items in most counties.  However,
the quantity of  pesticides  moving through these stores  is limited.
In  citrus growing areas, Fruit  Growers  Supply  Service,  associated with
the Sunkist  marketing cooperative, services  some cooperative members'
citrus groves.   The quantity  of pesticides handled in  this manner also
seems  to be  limited.
                                  66

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          Table 29.  Usage of Restricted Materials1 - California.  1973
                                                                              Quantity
 Restricted Material (Major Uses)                                            (1000 Ibs AT)

 1.   Methyl bromide (lettuce,  tomatoes,  sugarbeets,  alfalfa, cotton)           36,649.1
 2.   Chloropicrin (watermelon, strawberries, fallow ground, non-
     agricultural areas)                                                       10,57J.9
 3.   Toxaphene (cotton,  tomatoes,  beans, lettuce,  alfalfa)                     2,903.9
 4.   Parathion (almonds,  orange,s  peaches,  cotton, lettuce, tomatoes)           1,952.0
 5.   Carbaryl [Sevin]  (tomatoes,  cotton, grapes, corn, sugarbeets, peaches)    1,335.4
 6.   Methyl parathion (almonds, artichokes, tomatoes, cotton, lettuce,
     sugarbeets)                                                                1,204.0
 7.   Chlordane (structural and residential  control,  orchards, grapes)           1,030.0
 8.   Methorny1 (lettuce,  tomatoes,  sugarbeets,  alfalfa, cotton)                   968.5
 9.   Phorate [Thimet]  (wheat,  sorghum, barley, sugarbeets, cotton, corn)         886.3
10.   Lndosulfan [Thiodan] (lettuce, tomatoes,  alfalfa, celery, grapes)           808.3
11.   Paraquat (cotton, non-agricultural areas, fallow ground)                    374.0
12.   Mevinphps (Phosdrin)  (lettuce, alfalfa,  celery, brussel sprouts,
     strawberries)                                                               386.9
13.   Azinphosmethyl (Guthion)   (peaches,  tomatoes,  pears, oranges, potatoes,
     cotton)                                                                     384<7.
14.   Ethion (grapes, melons, apples, oranges,  pears)                             346.5
15.   Disulfoton (Di-Syston) (sorghum, potatoes, cotton, alfalfa, tomatoes,
                                                                                 O ~J O 1
     broccoli)                                                                   2/b'1
16.   Aldicarb (Teraik) (cotton, sugarbeets)                                        213.4
17.   Azodrin  (cotton, potatoes)                                                  211.0
18.   Sodium Arsenite  (grapes,  state agencies)                                     123-?
19.   Dieldrin (structural control, grapes,  tomatoes, wheat, lettuce)             117.3
20.   Carbofuran (Furadan)  (alfalfa, rice)                                        106.6
21.   Carbophenothion  (Trithion) (almonds, grapes,  walnuts)                        82.7
22.   TEPP  (alfalfa, almonds, cotton, grapes)                                      73.9
23.   Monitor  (cotton, potatoes, broccoli, cabbage, cauliflower)                   72.2
24.   Phosphamidon  (walnuts, oranges, turf,  other  citrus)       .                   71.2
25.   Aldrin  (corn, structural  control, sugarbeets)                                57.8
26.   Demeton  (Systox) (grapes, alfalfa, sorghum,  brussel sprouts, cauliflower)    43.6
27.   Sodium Arsenate  (sugarbeets, non-agricultural,  grapes)                       23.0
28.   Lindane  (residential and  structural control)                                 13.9
29.   Strychnine  (alfalfa)                                                         13-2
30.   Endrin  (cotton)                                                              10<7
31.   Eidrin  (cotton,  alfalfa)                                                       9-5
32.   Arsenic  acid  (pears)                                                          8-6
33.   EPN  (beans, alfalfa)                                                          8-°
34.   Supracide (alfalfa)                                                           5-9
35.   Benzine  Hexachloride  (BHC) (residential  cotnrol)                              3.0
36.   Zinc  Phosphide  (sugarbeets,  grapes, non-agricultural)                         1-9
37.   DDT  (citrus)                                                                  1<3
38.   Ueptachlor  (structural and residential control)                               0-8
39.   Arsenic  Trioxide                                                          Minimal

                                         67

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                      Table  29  (Continued)
                                                   Quantity
Restricted Material (Major Uses)                   (1000 Ibs AI)

40.  Avitrol                                       Minimal
41.  Starlicide                                    Minimal
42.  Diaflor [Turak]                               Minimal
43.  Sulfotepp                                     Minimal
 The pesticides included in the table are designated as restricted
 material and their use and possession are subject to special restric-
 tions under regulations of the California State Department of Food
 and Agriculture.  A permit from the County Agricultural Commissioner
 must be obtained for the use and possession of these materials.

Source:  California Department of Food and Agriculture, 1974, Pesticide
         Use Report, 1973.
                                  68

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             Table  30.  Usage of Restricted Herbicides
                             California, 1973
                                                            Quantity
Herbicide  (Majpr__Use_)_                                     (1000  Ibs  AT)


2,4-D (Barley, wheat, sorghum, non-agricultural uses)       1,192.0

MCPA (Rice)                                                   283.3

Propanil (Rice)                                               83.4

2,4-DP (Barley, pasture, non-agricultural uses)               39.7

2,4,5-T (Pasture, rangeland, alfalfa, non-agricultural uses)  38.9

Silvex (non-agricultural uses)                                18.8

Picloram (Non-agricultural uses)                                1.0

Dicamba [Banvel]                                            Minimal
 Source:  California Department of Food and Agriculture, 1974,
          Pesticide Use Report, 1973.
                                  69

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                                                                  70

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     Although most commercial applicators in California do not act as
dealers, in remote areas of the State where the distribution system is
limited, many applicators do sell pesticides to farmers who then apply
the chemicals themselves.  Farmers often purchase pesticides but never
actually take possession of them.  They purchase chemicals from a
formulator and/or dealer who delivers the pesticides to a commercial
applicator contracted by the farmer to treat his crops.

     The wholesale distributor, who simply moves pesticide products be-
tween two levels of the production—distribution chain without actually
altering the pesticide in some way, does not exist in significant numbers
in California.  The creation of this level of the marketing system has
occasionally been attempted, but never with particular success.

     Pest control operators and government agencies generally purchase
pesticides directly from formulators; they buy only small quantities
from dealers.

     In 1974 there were about 1150 formulators, 1350 dealers, and 1550
applicators in California.  There is an overlap between each category
since formulators may be both dealers and applicators, and applicators
may also be dealers, etc.  These numbers were estimated from information
provided by the Western Agriculture Chemical Association and the Agricultural
Chemicals and Feed Branch, California State Department of Food and
Agriculture.

     4.  Magnitude  of  the Pesticide  and Container Disposal Problem

     a.  Number and Types of Containers

     Current  estimates  of the  types  and quantities  of  pesticide containers
used in California  can  be found  in Table 31.  The source of the 1974
estimates  indicated that the estimates should by no means be considered
definitive, but rather  should  be considered rough approximation of  the
number and  type of  containers  existing in California.  Note  that  there are
considerable  differences in the number and  type of  container between  the
two estimates.

     A significant  development in pesticide handling  in California  is
the movement  toward increased  use of plastic containers.  Union Carbide
estimates  that by the end of 1975 as much as 50% of their liquid  pesticides
will be sold  in plastic containers.  This company is  presently test
marketing  to  determine  the acceptance of plastic containers.  Although
most handlers of pesticides may not  object  to plastic  containers, there
are indications that applicators may resist their introduction,
particularly  for restricted materials, since they believe plastic con-
tainers appear to present greater disposal  problems for the  applicator
than do metal or glass  containers.
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  Table 31.  Estimated Number of Pesticide Containers
             in Use. California. 1969 and 1972
                                       1969(1)        1972(2)

55-gallon metal drums                    8,000          8,000

30-gallon metal drums                   98,000         50,000

5-gallon metal containers              346,000        400,000

1-gallon:  metal, glass, plastic       172,000        800,000

1-5 Ibs paper sacks                                  850,000

5-10 Ibs paper sacks                               2,500,000

10-49 Ibs paper sacks                3,247,000        250,000

50 Ibs paper sacks                   	     2.000.000

                        TOTAL        3,871,000      6,858,000

(Small) Home and Garden containers:               10,000,000
1/2 are glass
Source:  (1)  Rogers, P.H. and Cornelius, J.   "Tentative Guidelines
              for Safe Handling and Disposal of Used Pesticides
              in California," Cal. Dept. of Public Health, Cal.
              Dept. of Agriculture (June 1970).

         (2)  Joseph Shumacher, Agricultural Chemicals and
              Feed Branch, California State Department of Food
              and Agriculture, Sacramento, California.
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     b.  Quantities of Pesticides Requiring Disposal

     There has been no definitive investigation of the quantity of unused
or unwanted pesticides requiring disposal in California.  State, industry
and private sources contacted in our field study indicated that they
believed there were only limited quantities for disposal, except for
outdated or recently banned materials.

     c.  Pesticide Application and Container Disposal Problems—
         Case Examples from Different Agricultural Sectors

     Pesticide application practices vary widely in California depending
on the crop (or animal) being treated, the size of the farm, the location
of the farm in the State, and the nature and severity of the pest being
treated.  Because of these widely divergent practices, the quantity and
type of pesticide containers or unused pesticides requiring  disposal
also varies considerably.  Although a description of one or even several
application/disposal situations could not cover all the practices and
conditions found in California, a descriptive summarization of several
actual pesticide application "operations" in California is useful to
understand the pesticide and container disposal problems.

     Small Farmers

     Small farmers (less than 100 acres) in California tend to apply
their own pesticides.  Although this may vary from crop to crop and
between regions, most pesticides not applied by commercial applicators
are applied by small farmers.  Normally the small farmer purchases his
liquid  chemicals from a  local dealer  in t and 5-gallon containers.  Seldom
does he handle more than 40 to 50 pesticide containers in a year  (exclud-
ing oil containers and containers for other non-toxic materials).  With
this small volume of hazardous materials, his storage and disposal problems
do not—on the surface—appear  great.  However, the small farmer probably
causes  a large number of pesticide handling and disposal problems which
are neither detected nor prosecuted.

    Owner/Applicator

    The pesticide "operation" described below represents a corporation
which owns and manages approximately 2400 acres of citrus in southern
California.  They perform all their own pesticide application work and
work for various "member owners" who have citrus acreage not considered
part of  the corporation.  The firm is also a licensed pesticide dealer,
but the only chemicals sold are those used to spray the "member owners'"
groves.  The company purchases their chemicals from several formulator/
dealers in the area.  They use large quantities of Parathion and
Dimethoate.
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    The firm uses five ground rigs for spraying, operated by seven men
plus one foreman at two locations approximately 75 miles apart.  The
firm annually handles approximately 300, 50-gallon containers and 50 to 75,
30-gallon drums.  Additionally they use numerous paper sacks and one-gallon
plastic and glass jugs.

    The corporation typically has only a very small amount of unused
pesticides for disposal.  Normally if a pesticide becomes "obsolete" for
their  operation, someone can usually be found who has a use for the
chemical.  Thus, the unwanted pesticide is sold or traded to this person
or firm.  Rinse water from containers may or may not be emptied into
spray tanks for eventual use.  However, if the chemical is expensive,
draining racks are employed before rinsing of the containers takes place.
The material collected in this manner is then used as any other pesticide.
    Commercial Applicator

    The firm represented in this section is a commercial applicator
specifically treating only citrus.  The company is a licensed pest manage-
ment advisor, pesticide dealer, and applicator.  It is responsible for
pest management on 3-5,000 acres including 400 acres which belong to the
owners of the firm.  (The operation is a father-son business which hires
10-15 additional persons to operate and maintain the spray rigs.)  Although
the company is a pesticide dealer, they actually sell only a very small
quantity of pesticides to persons whose groves they do not treat.
Essentially they are dealers to improve their purchasing position, and to
permit them to sell directly to those customers who do not wish to purchase
the chemicals themselves.

     The  company  operates 12 ground spray  rigs.   Their  facilities  consist
 of an office building,  chemical warehouse,  repair  shop,  and  small storage
 shed.  Most  of the spray equipment is well-used, if not  old.   The  operation
 appears  quite typical  of most  medium-sized  farmer  and  commercial  applicator
 operations.

     The  company  does not handle large quantities of pesticide containers.
 In a year,  they  will use 250 to 300, 5-gallon containers and  20 to 30, 30-
 gallon drums.  In addition,  a  few 55-gallon drums are used  as  well as
 numerous one-gallon and  paper  containers.   Perhaps 40%  of  their pesticide
 volume is packaged in paper  containers.   The head of  the  company prefers
 to use powder materials  over liquids.   Apparently  when  the powder or
 dust spills,  either on the  individual,  ground,  or  equipment,  it  is more
 noticeable  than  the liquids since clothing,  equipment,  and ground may
 all be wet  from  the water being mixed.  Being more noticeable, personnel
 are generally more conscientious  in taking  precautions  to  avoid  or clean
 up the spilled material.
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    The maximum protective clothing or equipment worn by the spray rig
operators appears to be only gloves when handling certain chemicals.
Seldom if ever are respirators used, and it seems that no protection is
used when empty containers are handled for disposal.  Apparently, however,
the company has a good safety record in handling pesticides..  Infrequently,
someone will require hospital treatment for a day , but this generally
has resulted from spraying during unusual weather conditions rather than
from handling containers or unused or stored pesticides.  Although he
did not object to a closed system for handling pesticides, the head of
the firm did voice two concerns about such a system.  First, since rigs
vary so considerably in type and size, it will be difficult to devise
a closed system adaptable to all rigs.  Second, a closed system would
increase application costs; already customers are complaining about the
high cost of treatment.  Apparently he did not feel that the hazards to
employees really warranted a closed system.

    The company hauls chemicals to the field or spray site in a caged
truck and then returns the empty containers, bags, and partially used
containers in the same truck.  Mixing of chemicals occurs both at the
site of application and the base operation.  Probably 70% of their spray
jobs are inspected either at the mixing site or spray site (more often
the latter) by representatives of the County Commissioner's office.
The firm's spraying operations occur over a radius of approximately 100
miles outward from the home base.

    The company's facilities are enclosed by a fence.  However, this fence
also encloses an unrelated citrus packing house and a small lumber yard-
mill with no division between the three operations.  Although pesticides
are stored in a locked warehouse at night, during the day the warehouse
remains open.  There are no restrictions to prevent employees of the
other two operations from visiting the spray mixing and container
storage sites.

    Integrated Pesticide Firms

    The companies represented in this description act as pest control
advisors, distributors, dealers, applicators, and femulators.  Each of
these operations annually treat 300 to 750,000 acres.  Generally they own
their own ground spraying equipment and subcontract their aerial work
to various aerial applicators.  These firms operate out of as many as
ten locations throughout the state and cover several thousand square
miles of cropland.  One such operation has approximately 100 mobile spray
units, five  fixed-wing aircraft, and 10 warehouses with locations as
far south as Bakersfield and as far north as Atwater.  In  one year
one of these integrated pesticide operations may handle 5 to 10,000, 30-
to 55-gallon drums  (more than the statewide estimates given earlier),
10 to 20,000,  5-gallon containers,  and innumerable one-gallon and paper
containers.
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    Rather than operating their own application equipment and facilities,
many large farmers  (1 to 20,000 acres)  will contract with the integrated
firm to monitor and treat all pest buildups.  In other instances, the
farmer will do his own monitoring and then contract with the integrated
firm to treat the pest when a threshold level is felt to have been reach-
ed.  In this latter situation, the farmer will generally purchase his
chemicals from the integrated firm.

    Due to the size of their operations and the diversity of crops they
treat, these integrated firms have a relatively stable level of pesticide
sales and applications throughout the year.  Those crops most commonly
treated will be cotton, vegetables, and various field crops.

    These firms receive most of their technical grade materials for
formulation in 30- and 55-gallon drums.  When selling their in-house
formulated pesticides or those pesticides formulated elsewhere, they
generally do so in 1- and 5-gallon containers.  In addition, they sell
large quantities of pesticides in paper containers; however, these are
manufactured and packaged elsewhere.

    Generally when subcontracting spray work to an aerial applicator,
the integrated firm delivers the pesticide to the airstrip.  The applicator
will then bill the farmer directly for the application service, while
the integrated firm would charge the farmer only for the pesticides used
and for the pest consulting service employed.

    5.  Status of Regulations and State Policies

    Regulations promulgated by the State of California are very specific
concerning the disposal of unused pesticides and the transportation,
handling, storage, and ultimate disposal of pesticide containers.
The State has established and approved three classes of landfills for
solid waste including pesticide disposal.

    Class  I—provides complete  protection,  at all  times,  for  "the
    quality of  ground and  surface  waters  from all  wastes  deposited
    therein and against  hazard  to  public  health and  wildlife  resource."

    Limited Class  I—a special  case  of  Class  I site  "where  a  threat
    of  inundation  by  greater  than  a  100-year  flood exists."

    Class  II-l—may overlie or  be  adjacent  to usable groundwater;
    artificial  barriers  to both vertical  and horizontal  leaching are
    required; protection from a 100-year  frequency flood  must be
    provided.

    Class  II-2—may have vertical  and  lateral continuity  with ground
    water  but provides protection  to water  quality.

    Class  III—inadequate  protection to ground water.
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    Pesticides, unrinsed containers and bags can be deposited at Class
I sites only.  There are 17 Class I sites in the State, however only
12 of these sites  will accept pesticides and containers.  These are:
Big Blue Hills (Fresno), Calabassas (L.A.), Hollister (Hollister),
Hunter (Santa Barbara), J&J Disposal (Benicia), Omar Rendering Co.
(Chula Vista), Otay (San Diego), Palo Verdes (L.A.) Simi Valley (Ventura),
Stringfellow Quarry (Riverside), West Contra Coasta (Richmond) and West
Covina (Wilmington).

    Only rinsed pesticide containers and bags and cartons may be disposed
of in Class II-l dump sites.  There are about 20 Class II-l dump sites
in California.  The operators of the dumps can inspect material coming
in and are required to charge a fee (levied by the State) for the
disposal of hazardous wastes.

    Specific state regulations pertaining to pesticides and containers
are summarized below.

    •  Unused pesticides—any pesticide which cannot be used must be
       disposed of in a Class I dump.   With prior agreement, it may
       be returned to the registrant.

    •  Transportation—no pesticide or containers may be transported
       in the same compartment as food items.  All containers must be
       secured to the vehicle in order to prevent accidental spillage
       or loss of containers during transport.   Paper bags, cardboard
       containers and  the like must be covered to protect them from
       moisture.

    «  Handling—all  metal, plastic or glass containers, which contained
       less than 28 gallons of a liquid pesticide shall be triple rinsed
       according to the following guidelines.

       Size of containers        Amount of rinse water for each rinse

        1 gallon or less              1/4 of volume
        5 gallons                     1 gallon
        over 5 gallons                1/5 of volume

       Rinse water is to be drained into the mix tank.  Containers should
       be allowed to drain for 30 seconds after each rinse.  After rins-
       ing, metal containers should be punctured at the top rim to allow
       remaining liquid to drain out.   All containers should subsequently
       be punctured,  broken or mutilated so as to make it impossible
       to use the containers for any purpose.

    •  Storage—any empty containers as well as pesticides must be
       stored in a locked enclosure on the user's property.  The area
       must be posted with suitable warning signs in English and, if
       necessary, another language.  Containers may also be stored in
       designated holding sites prior to final disposal.
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    •  Disposal of pesticide containers—rinsed pesticide containers may
       be disposed of in approved Class II-l dumps, or be contributed to
       a recycle program approved by the Department of Food and Agriculture.
       Unrinsed containers, of 28 gallons or more, may be sold to a re-
       conditioner (approved by the Department) or taken to a Class I
       dump.  Paper bags and cartons may be burned in small quantities
       at the site of use.

    Drafts of procedures and practices for the reconditioning of used
pesticide containers have been prepared.  Several reconditioning process-
es are specified, one for any gauge metal container and another for 16
gauge or lighter.  Safety precautions are emphasized.  Reconditioned
containers may be reused for the same chemical class of pesticides
previously contained, but may not be used as food, feed, beverage, drug
or cosmetic containers.

    The State Water Resources Control Board and the Regional Water
Quality Control Board are responsible for approving and classifying the
various dump sites.

    The State has developed a system for enforcing these regulations.
All farmers and commercial applicators must obtain a permit to possess
and use restricted materials.  These permits are issued by the county
agricultural commissioners and must be presented when purchasing
pesticides.

   The day prior to applying pesticides, the applicator must file a
"Notice of Intent to Apply Injurious and Regulated Pesticides" with
the county agricultural commissioner's office.  These forms are checked
and a master list of all applications in the county is prepared from
this.


     Field  inspectors visit  the various  farms where  spraying is being
done.  An  inspector can appear at any  time  to view  the  operation.  He
checks for  adherence to all  regulations regarding pesticide storage,
handling, use, and disposal  (e.g.,  triple rinsing).   If regulations are
not  being  observed, the inspector issues a  "Notice  of Violation"  to the
offender.   A violation can be handled  in various ways,  depending  on the
circumstances.

     •  A first violation serves primarily as a warning to the  individual.

     •  If  a particular user  receives several violations, the  county
       agricultural commissioner usually "talks"  to the violator.

     •  If  a user,  primarily  a commercial applicator,  has received
       violation notices  in  different  counties, the State Department
       of Agriculture  will deal with the violator.
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    6.  Current Disposal Practices

    As indicated earlier, California has an established well-defined
procedure for the disposal of pesticide containers.  Basically, all
containers of 28 gallons or less must be triple-rinsed, punctured, broken
or otherwise rendered unusable, and transported to an approved landfill.
Paper bags may be burned in small quantities at the site of use.  Larger
containers, i.e., 30- and 55-gallon drums, may be sold to approved scrap
dealers or reconditioners.  In our field study in California, we contacted
people active in all phases of the use and disposal of pesticides to
ascertain how well the system functioned.  Rather than attempt to gener-
alize actual disposal practices, we present here a series of descriptions
and scenarios of representative actual disposal practices obtained from
these discussions.

    State and County Representatives

    State and county agricultural staff believe the approved disposal
system is working reasonably well and that good cooperation is generally
obtained from the applicators, dealers, distributors, etc.  They believe
that the triple-rinse program, which has also been advocated by the
Western Agricultural Chemical Association (WACA) has been accepted in
general.

    Formulators, Distributors, and Applicators

    While county and state officials believe the program is working quite
well, the practices we encountered in our field interviews show some
variety.  One formulator/distributor (who also operates a small applica-
tion service) reported the following disposal practices:

    »  1-, 5-, 15-gallon drums—triple rinse, crush and haul the cans
       to a Class II-l dump site.


     •   30- and  55-gallon drums—most of  the  55-gallon drums are picked
        up by  a  cooperage firm (however,  the  firm  is not  licensed  to
        accept pesticide containers and will  no  longer be able to
        recondition pesticide  containers  after January 1, 1^75).   Some
        drums  are used for storage at the formulating operation.   Thirty-
        gallon drums are steam cleaned and resprayed.  Drums containing
        "toxic"  materials are  sold to a salvage  firm. . This company also
        sells  spray oils in 30-gallon drums.  They charge an $8 deposit
        for the  drum which is  steam cleaned and  repainted for reuse upon
        return.  About 75% of  their customers return these drums.  The
        company  does not accept  empty containers sold by  others.

     Another formulator/distributor/commercial applicator triple rinses
the  1-  and 5-gallon containers.  The containers are returned to the
central location where they are stored (in a locked yard).  About once
every two weeks one of the company trucks takes them 40-45 miles  to a
Class I site.
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    This company uses the drums originally containing active ingredients
to store formulated products.  When these drums are no long usable they
are taken to a scrap dealer.   Any excess drums are sold to a cooperage
firm.   This formulator also receives materials in 55-gallon drums made
of high-density polyethylene.  There is a deposit on these drums.  The
formulator must pay the freight cost to get the drum back to the manu-
facturer for "reconditioning."

    A third formulator/applLc ator was somewhat different from the others
in their practices and operation.  They handle about 5000, 30- to 50-
gallon drums and about 8000,  5-gallon  cans.  All containers used in
their custom applicator service are returned to the facility where they
are washed with caustic soda, crushed, and stored for eventual disposal
at a Class II-l landfill.  Paper products are baled  and then taken to
a dump.  (The company contracts with a disposal service to haul the con-
tainers to the dump.)  The firm will accept empty, triple-rinsed containers
from their customers which they will crush and put in their storage for
hauling to a dump.  The 30- and 55-gallon drums sometimes are used for
storage of formulated materials.  At other times they are cleaned out and
sent to a scrap dealer.

    This company also formulates a pesticide which is packaged in a
1-gallon plastic container.  They would like to have the containers
returned, unwashed, so that the container can be reused.  They have
obtained the permission of the county agricultural commissioner to
dispense with the triple-rinse required by law.  Part of this stems from
a desire to preve.nt cross-contamination and the fact that the material
is anhydrous (hence, the desire to avoid water in packaging).  They re-
fill the container and, if necessary, relabel it; no rinsing or recondition-
ing is done.  The container lifetime is about 2 years.

    A firm which owns and manages  large citrus acreage as well as a
"licensed dealer" and applicator reports the following disposal practices.


    Glass  containers are usually rinsed  once, broken,  and put  in a
dumpster which  is periodically  hauled  to  the  local  landfill.   (The  land-
fill  is neither an  approved  Class  I  or  II  site.)  Five-gallon  metal
containers have holes  punched in them  after emptying  and  are then
allowed to drain  for several hours.  (The draining area is not  secured
except at  night.)   After  draining,  these  containers  may  or  may  not be
washed; if they are, only  one rinsing  occurs.  The  containers  are then
crushed by hand if  only  a  small quantity  is accumulated.  Otherwise,
a bulldozer is  used to crush them.   A  year's  supply of crushed containers
is collected before they are bought  to  a  Class II site 15-20 miles
away.   (The nearest Class  I  site is  30-35  miles  distant.)    Thirty-
gallon drums are  delivered back to the  formulator for reuse.   However,
the option exists  to sell  the drums  to  a  reconditioner for  approximately
$1.00.  The reconditioner  steam rinses  them and  uses  a cautic  rinse.
The reconditioned drums  are  then generally used  for petroleum  spray
containers.
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    Some paper sacks are burned, but most are put in the dumpster for
disposal at the local landfill.  The production manager stated that the
firm had authorization from the Agricultural Commissioner's office
to dispose of the bags in this manner.  Plastic containers are a
difficult disposal problem.  The 5-gallon plastic container' is especially
attractive for various personal uses by employees.  Consequently, these
containers have a habit of disappearing.  As a result, company instruc-
tions are that the containers are to be irreparably damaged after
emptying.  One-gallon plastic containers are easier to destroy than are
the 5-gallons.  After damaging and often without rinsing, all plastic
containers are hauled to the local landfill.  [The description of dis-
posal practices is for the firm's main spraying operation.  Their second
facility, approximately 75 miles away, apparently has greater difficulty
in disposing of its containers.]

    The county agricultural commissioner's staff does inspect the
corporation's pesticide application operations.  Apparently the most
common violations recorded by the inspectors are incorrect, damaged,
or missing labels.

    The company attempts to find users for unwanted pesticides and will
trade or sell them.  Several years ago, a local chemical firm volunteer-
ed to pick up unwanted pesticide and the company was able to dispose of
material that had accumulated over a long period of time.

    Another small pesticide owner/applicator who uses about 250, 5-gallon
cans and 20 to 30, 50-gallon drums per year, reported the following pro-
cedures.

    The triple rinse method for cleaning small pesticide containers is
used with the rinse water put back in the spray machine.  Containers
are rinsed with a hose rather than a jet rinse and they are often not
drained prior to rinsing.  They are punctured rather than crushed.
Plastic containers are handled the same as metal, but at this time
there are far more metal containers than plastic.

    A 1 to 1 1/2 ton truck which has four high wooden sides is kept on
the premises.  All empty, rinsed containers are thrown into the back
of this truck to await hauling.  Periodically they are disposed of at
a nearby Class II dump (3-4 miles away).  No estimate was made as
to the number of trips that are made to the dump in a year.

    Almost all the large drums are recycled in one form or another.  Some
go to barrel reconditioners.  However most go back to a local formulator
(15-20 miles away).  Whenever 3-4 empty drums are ready, the formulator
delivers the next order of chemicals and picks up the drums.  They are
apparently reused for the same chemical.  The owner/applicator felt
this was a good system as long as the formulator was not at too great
a distance.  Several large drums are used for trash barrels.  These
drums had held banned chemicals; and consequently, the formulator did
not want them back.
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    Empty bags are disposed of by two methods:  burning in the field
(only occasionally) and disposal with the other empty containers.  In
most cases empty bags are returned from the field in a truck and then
thrown into the refuse truck described above.  The bags are not cleaned
in any way and are disposed of at the Class II site along with the
rinsed containers.

    One aerial applicator we visited indicates that he impresses on his
employees the necessity of triple rinsing, but does not feel that it
is done most of the time because it is too time-consuming.  He handles
70,000 to 80,000 containers per year, of which about 50,000 are 5-gallon
and the rest mostly 1-gallon.  He contracts with a disposal service to
pick up the containers at his various locations.

    Farmers

    As mentioned earlier, most pesticides in California are applied by
commercial aerial or ground applicators.  Although we contacted only
a few farmers, we asked county officials and applicators for their views
of typical disposal practices of small farmers.  In general, most persons
feel that although the small farmer has relatively small quantities of
pesticides to store, his security arrangements are motivated less by
regulatory pressure than they are by the fear of theft and the result-
ing financial loss.  Pesticides are usually stored in a tool room or
general supply shed; only occasionally do special facilities exist for
pesticide storage.  When empty, containers are seldom triple rinsed and
containers may not be rinsed at all prior to disposal.

    The disposal of empty containers and unused pesticides by small
farmers may not conform to state regulations governing disposal.
Some containers will be washed by conventional means and then will be
used in some manner around the farm—trash bins, feed or water containers
for animals, feed scoops, water bottles, storage containers, etc.
Other containers and unused, unwanted pesticides are apt to be buried
on the farm.  Small farmers will often  take their empty containers to
unsupervised or lightly supervised dumps for disposal.  These are
generally not Class I or Class II sites, but local sites used for the
disposal of general trash and rubbish.  There are people with small trucks
who visit farms and either pay the farmer for them or are paid by the
farmer to haul the containers away.  Once the containers are obtained,
they may be placed in a pile, doused with fuel oil or kerosene, burned,
and then sold to junk dealers as scrap  metal.  There are, however, a
number of small farmers who do follow state regulations and thus dispose
of empty containers and unused pesticides in the prescribed manner.

    Disposal Site Operations

    We obtained information on one Class I site.  The facility has been
in operation since Fall 1973 and is  opened twice each year  for about
10 days each time  (in April and October).  In the past, it  has been used
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 for "emergency"  dumping requirements.   Notices  of opening are placed
 in various newspapers and  pest  control newsletters, direction signs
 placed,  and an access road opened.   A bulldozer  is rented, and an operator
 and foreman estimate load  size, levy charges,  and supervise the operation.
 The dump has processed between  4000 and 7000 cubic yards of- material
 during its openings.   Upon closing, all refuse is covered with a minimum
 of 1 foot of earth.   The fence  around the site is locked, the access
 road is  closed and all the direction signs are taken down.  All personnel
 wear protective  clothing and  the bulldozer is  decontaminated with
 bleach at the dump site.   The ratio of crushed to uncrushed pesticide
 containers received  at the site is  1 to 4.

     We also visited  a Class II-l landfill and  interviewed the operator.
 He was very leery .of accepting  pesticide containers because he had an
 accident with a  load and was  in the hospital for several weeks.  Now he
 carefully inspects all loads  and, if anything  is wrong,  he will not
 allow them to be dumped.

     Disposal Contracting Firms

     There are a  growing number  of organizations  in California which
 handle hazardous waste disposal.  For example, one firm we visited
 will pick up pesticide containers and bring them to a central location
 where they are washed with caustic  and crushed.   The containers are then
 taken to an approved landfill.   If  the containers have not been used
 for "hazardous"  materials  (e.g., carbamates, phosphates), they are
 rinsed and sold  for  scrap.  The firm is interested in handling disposal
 for county-wide  areas on a continuous, contract  basis.  They believe
 that holding sites should  be  established, probably at the dump, for the
 containers.  The sites would  have to be a locked enclosure, have drain-
 age protection and be posted.  (The state solid  waste staff has developed
 criteria for approving holding  sites.)  The company would then take two
 trucks to the site,  one for rinsing containers and one for crushing and
 transporting the containers to the dump.

     Another firm we visited is not currently involved with pesticides
 and pesticide container disposal but is interested in entering the field.
 They have conducted a survey of 400 local farmers and applicators.
 Ninety percent of the respondents favored the  holding site concept.
. They are investigating two possibilities:   (1) hauling to a Class I site
 or  (2) shredding and bailing metal containers  for sale as scrap.  They
 hope to start this program in the near future.

     Cooperage Firms and Drum Reconditioners

     Although several cooperage firms and reconditioners have been operat-
 ing in the State to recondition pesticide drums, only a few were
 approved by the State to handle pesticide drums  as of January 1, 1975
 when the regulations pertaining to reconditioners became effective.
 Typical procedures are described below.
                                 83

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     Drums are picked up at the user's location and must have the bungs
on tight.  Drums are processed on arrival because a storage facility
does not exist.  The actual reconditioning process involves the follow-
ing steps:

     1.  Rinse with hot caustic (from one to three times);
     2.  Cut tops of drums off and "curl" cut edge to make it safe;
     3.  Burn in an incinerator at 1700-1800°F;
     4.  Steel shot-blast;
     5.  Reform (to remove dents);
     6.  Test;
     7.  Lids are reformed;
     8.  Paint; and
     9.  Dry.

 After the initial washing, the materials handling is done by mechanical
 means.  The process requires 3-4 hours.   The drums then go to an industry
 which does not deal in food, feed, cosmetics or Pharmaceuticals (as
 specificed by state law).  One reconditioner has a contract with a
 formulator.  He sells most of his reconditioned drums to a paint dealer
 Drums that are not suitable for reconditioning are rinsed with caustic
 and sold to a scrap dealer.   The reconditioned drums can be used between
 8 and 13 times, depending upon the treatment by the user.

     Another cooperage firm/reconditioner provided the following descrip-
 tion of current practices.

     •  Drums are brought  to  the plant and stored in a special area if
        they cannot be processed immediately.   The storage area is
        designed with a special surface,  special collection systems to
        handle runoff and  a 12-foot high  fence topped with barbed wire
        to prevent unauthorized entrance.

     •  The drums are rinsed three times  with a solution of hot caustic
        soda and sodium gluconate.

     •  The tops of the drums are cut off. and the edges beaded in a
        unit that can handle 50 drums/hour.

     •  The drums are sent to a five-stage burner, diagrammed below.
   Ambient
600-800°F
                                            .After burner 1450-1800°F
1240-1500°F
600-800°F
Ambient
        The unit is 90-120 ft long and can process 400 drums per hour.
                                   84

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    •  The drum  and lid are steel shot blasted in a unit that can
       handle 400 drums/hour.

    •  The covers are reformed in a press that can handle 200 covers/
       hour.

    •  The drums are placed on an expander to "take out the dents."
       One of these units can process 200 drums/hr.

    «  Each drum is tested in a unit that processes 200 drums/hour.

    •  The drums and lids are painted, both inside and out.

    •  Finally, the drums go to a drying oven.

    Another drum reconditioner operated three plants in the San Francisco
area.  Two major processes are used.  "Tight head" reconditioning in-
volves washing with caustic and rinsing.  "Open top" reconditioning
involves rinsing, passage through an incinerator operated at 1200-1400°F
for 1 1/2 to 2 minutes, cooling, grit-blasting, and painting.  The
company accepts only pesticide drums which are "certified as decontaminated."
These may only be triple rinsed.  The company keeps track of the drums
it receives from major formulators or manufacturers and returns the re-
conditioned drums to the specific formulators or manufacturers.  Most
of the reconditioning is done with 55-gallon drums.  The company will
pick up drums if there are a sufficient number in any location, or
collects drums from scavengers.

    Holding Areas

    Several counties have established holding areas for the storage of
pesticide containers prior to disposal.  Some of the sites were
originally set up as part of a  "container collection compaign" initiated
jointly by the State and the Western Agricultural Chemical Association
to remove unwanted containers from the area.  Several thousand empty
containers are located at some  of these sites.  In some counties not
having Class I or Class II-l dumps, holding areas are periodically opened
so that farmers and applicators have a temporary disposal site.  Several
counties are now negotiating with disposal contractors to operate these
sites; others are attempting to have reconditioners or cooperage firms
purchase the stored containers.  Some of the major pest control operators
(commercial applicators) have applied for permission to operate holding
areas for containers to improve the logistics and economics of the
disposal operations.

    Disposal of Pesticides

    Unused pesticides appear to be of less consequence in California.
Several years ago the State ran a program to collect unused pesticides
and many users got rid of them  at that time.  County agricultural
commissions will often accept small quantities from individual users.
They store the pesticide and, when there is enough, transport  it to a
Class I dump.

                               85

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    Commercial applicators try to avoid situations which lead to large,
unusable quantities.  They usually apply the pesticide in the recommended
manner (if not illegal) or take it to a Class I dump as required by law.
Although most dealers reported little problems with pesticide disposal,
one dealer/applicator we visited indicated that he had at one time about
7 or 8 tons of unwanted pesticides.  Most of these contained arsenic,
lead, or mercury.  He also had surplus of other chemicals that no longer
had valid registrations.

    Other Views of Disposal Methods

    Aerojet Corp. and North American Rockwell have proposed incinerators
for the disposal of pesticides and/or containers.   Most persons in
California who had been informed about these systems believed that the
high cost of incineration would be unacceptable.  To our knowledge, these
proposals have not been accepted by any organization in their disposal
operations.

    Although the above discussion of our site visits generally suggests
that the state approved system for container disposal was being practiced,
we were left with some skepticism on the extent to which all containers
were disposed of within the system.  We were informed by several indus-
trial participants and applicators that "not all containers were disposed
of in the officially approved manner."  It was indicated that "all the
metal containers used could never be accounted for in Class I and Class II
dumps" and "many scrap dealers sell shredded or compacted scrap from
pesticide containers overseas."  This view is supported, in part,
from data obtained  from county agricultural commissioners and pesticide
dealers.  We checked the records in one county of the containers
disposed of in the  only Class II-l dump site in the county.   (Records
of the quantities of containers dumped are kept along with the fees
charged.)  The number of containers disposed of was far less than the
number sold by the  largest dealer  in the county. There were several
other major dealer/applicators in  the county.  Further, one dealer/
applicator indicated that he disposed of many containers in the local
Class II-l dump, and few records of his using the dump could be found.
This information suggests that pesticide containers do reach  "non-
approved" channels  for disposal.

    7.  Cost of Disposal

    Because the pesticide container disposal operations are relatively
highly developed in California, we were able to obtain cost information
from a number of applicators, disposal site operators, etc.   The  cost
of current disposal practices is summarized below in  four principal
categories:  crushing  and landfilling; reconditioning; disposal services;
and costs of deposit systems.
                                 86

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    Crush and Landfill

    Typical costs of crushers, provided by several persons are as follows:

         Type                      Cost               Remarks

    5-gallon cans                $ 1,100        More than 100 cans/day

    5-gallon cans                  1,162        1 can per minute

    5- and 30-gallon cans          1,500        11, 5-gallon cans/min.
                                   ("homemade")

    55-gallon cans                 7,988

    The cost of a typical compactor/bailing machine, to handle bags and
plastic bottles, is $15,000.  The cost of shredders to handle 180 cans
per hour is between $15,000 and $20,000.

    Cost data for landfills included actual fees charged at Class I and
II sites as well as estimates for the development of new sites.

    State fees for hazardous wastes are imposed at Class I dump sites.
For uncrushed containers, the fee is $.60/ton.  The minimum fee is $1.00.
On a volumetric  basis the charge is $1.00 for up to 20 cu yd and 50
for each additional cu yd.  There are about 12 cu yd/ton of uncrushed
containers.  Crushed containers, averaging 3 cu yd/ton, are assessed
at $0.60/ton.  For loads of 5 cu yd or less, a minimum fee of $1.00 is
charged; any additional volumes cost 20
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The minimum charge is $1.50 and a permit is required for loads in excess
of 2000 Ib.  A 10% surcharge is imposed on non-county residents.

    Reconditioning

    One drum reconditioner located in the Los Angeles area pays 50c
per drum for any drums picked up "below Fresno" and 25c/drum "above
Fresno."  They also charge freight costs.  Reconditioned, open-top,
black drums sell for $9.65 for a 55-gallon drum and $7.90 for a 30-
gallon drum.  Tops cost $1.00 and rings, $1.25.  Colored drums are more
expensive.  The costs of the reconditioning process were "confidential."

    Another cooperage firm  gave the following costs for various
components of his present reconditioning system.
    Item

    Drum Cutter & Edge Header

    Five-stage Burner/Incinerator
         Equipment

         Fuel
         Water

    Drum Body Shot Blaster

    Drum Expander

    Drum Tester
Drum
Capacity

 50/hr

400/hr
400/hr
200/hr
200/hr
    Painting Equipment

    Dryer
    Materials Handling Equipment

This facility can handle several thousand drums/day.
   Cost

$50,000


$400,000 (exiusive of
         installation)
$ 60,000/year
$  3,000/year

$ 75,000

$ 30,000

$ 25,000

$100,000

$ 60,000

$100,000
    This firm is designing a new plant to process 9000 drums/day.  The
capital investment is estimated to be $5 million, plus 23% contingency,
with an addtional $1.5 million for real estate.

    This cooperage firm buys drums for $.75-$1.00, depending on the
condition.  The cost of reconditioning a drum is $1.75-$3.25.  Pesticide
drums  cost more to recondition than ordinary drums due to the additional
treating involved.  The drums are sold for  $6.00-$6.50.  There is a
4-5% scrap loss and the average drum life is 9 reuses.
                                 88

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    Disposal Services

    Several disposal services handle pesticide containers on a one-time
basis.  Following are typical disposal prices:

    1.  Rinsed, 1- and 5-gallon cans                       25c/can
        Unrinsed, 1- and 5-gallon cans                     30
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The other general attitude, expressed by a few participants in our field
survey, was that pesticide and container disposal did not become a
"problem" until regulations were passed.  Prior to that time,  i^sticides
and containers were t. isposed of through "normal channels" with very
little environmental and health problems.

     Applicators and pest control operators, who are the largest user
group of pesticides in California, generally believe that the state
enforced disposal system was operating adequately.  They feel that
greater emphasis should be placed on reuse of larger containers,
primarily through returning them to formulators or through drum re-
conditioners.  They were not in favor of deposit systems since it added
considerable bookkeeping and costs to their activities.

     Pesticide dealers and distributors were generally opposed to any
system which would return containers through their inventory or
processing.  They believe that it is the primary responsibility of the
user to dispose of containers.  They prefer to see the user bring
pesticide containers to a disposal site or have disposal contractors
pick them up.  They were not in favor of the deposit system because of
the added bookkeeping and inventory problems.  Most were willing to
become "disposal centers" only if it were required by regulations.

     We expect that individual farmers would prefer to dispose of
containers on their own property rather than to bring them to disposal
areas.  However, our sample of farmers was insufficiently large to
determine this adequately.

     Several people discussed the opportunities for another class of
service business in the pesticide industry—the pesticide container
service that takes unrinsed pesticide containers, rinses them, disposes
of rinse water, and takes the containers for reuse or other reclamation.
Pesticide disposal contractors felt that it was the responsibility of
the manufacturer and distributor  to communicate the proper method of
disposal  to  the consumer.  They also believe that they will play a
more  important role in disposal in the  future.

     Another interesting  attitude of some  individuals was  that  the types
and sizes  of pesticide containers may ultimately be established by OSHA
regulations which  limit weight of containers for handling.  They ex-
pected  that  industry would move towards  15-gallon containers as the
largest size for easy handling.   They also indicated that most  industrial
people  are trying  to reduce the number  of  1-gallon and perhaps  2-gallon
containers and move towards a 5-  and 15-gallon container size.

      Several industrial people also believe  that bulk  shipments would
become more  important, particularly where  they can be combined with
closed  pesticide delivery systems.  This would help eliminate some con-
tainer disposal problems.
                                90

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     Several pesticide distributors felt that the continued increase in
the use of large returnable plastic containers would help solve some of
the disposal problems but could create others.  The problem of rinsing
and crushing steel containers and health problems related to scrap and
reuse would be partially solved.  However, problems of contamination
using plastic containers, and the ultimate disposal of plastic containers,
may be more serious than those with the steel containers.  In general,
drum reconditioners have mixed feelings toward the use of plastic
drums.  Although it will affect their steel drum reconditioning business,
many of them will move towards reconditioning plastic drums.

     Many applicators believed that "closed systems" will become a more
widespread practice.  In closed systems, containers have special open-
ings requiring appropriate tools for entry and mechanisms to prevent
unauthorized persons for putting substances back into the container
except the manufacturer.  Small containers are not used; contact with
pesticides and containers is minimized.  Closed system of containers
would be advantageous in large spray applications.  Several pesticide
applicators indicated they would be willing to pay up to several thousand
dollars to convert to closed systems.  They believe this would consider-
ably reduce the number of containers to be disposed of, eliminate to
a large extent the occupational hazards of applying pesticides, and
save labor.

     Some small operators had objections to closed systems, although they
concluded they would help solve the disposal problem. Some of the
objections are that spray rigs were often quite different from one
another, and, as a result, it may be very difficult to devise a closed
system adaptable to all or most rigs.  Second, the cost of converting
the spray rig to a closed system adds to the cost of application which
is undesirable in today's economy.  The same objection would be raised
by the small operators towards a deposit system.

      b.   Burning and  Incineration

      Most of  those  interviewed  believe  that burning  of  small amounts  of
paper pesticide containers was  appropriate and  safe.  There is some
discrepancy among the  local regulations on container burning.  For
example  in one county,  farmers  must  have  5 acres  of  land or more  in
order to burn containers.  The  general  feeling  is  that  paper bags
or cardboard  should burned provided  only  a few  are burned  at one  time
or burning is not done  in heavily  populated areas.

      Most people believe that incineration is a necessary  part of the
container recycle process, that it should be used  for disposal of excess
pesticides, but that  it  is an expensive process.

      c.   Triple Rinsing  of Containers

      Although there is  a general belief among the  State Department of
Agriculture staff that  the triple  rinsing process  has been accepted
reasonably well, enforcement has probably been  the principal reason for
its acceptance.

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     Nevertheless, several state people are skeptical of the acceptance
of the triple rinse method.   They claim, for example, there is no
effective way to tell whether a container has been rinsed once, twice,
or three times.  They feel that most people indicate they rinse the
container three times but really do not.  Discussions with applicators
and farmers indicate that containers are often rinsed only once and
that inspection of spraying operations is one of the principal reasons
rinsing is done at all.

     d.  Landfills

     Members of the several county agricultural commissions indicated
that landfills were the "best and cheapest way to take care of the
problem of pesticides and containers."  Most applicators and dealers
were not adverse to landfills, but believed recycle or reuse was better.

     Users of landfills were not entirely satisfied with their operation.
For example, several people felt that the greatest difficulty in the
current landfill disposal system in California was Class I sites.  Be-
cause of the remote and distant location of several Class I sites, and
the few periods in which they are open for acceptance of pesticides
and containers, pesticide users either have to travel long distances
or hire outside parties to move containers and materials.  It was felt
that pesticide users often handle and store pesticides and containers
in an acceptable manner, but the persons who carry or haul pesticides
to landfills have little knowledge of pesticides and do not take
appropriate precautionary measures.  Others felt that the distribution
of landfills was inadequate.  For example, in some counties there are
three Class II-l facilities and perhaps several Class I facilities.
In other counties there may be neither type of disposal facility.  Any
 system which is designed  to provide the pesticide user  with disposal
 sites must take into account the distribution  of containers and  users.
 The  general attitude is that most users will not travel very  far to
 reach a disposal  site,  even if  it is contrary  to regulation.

      Several pesticide  disposal site operators are  hesitant to accept
 loads of pesticide  containers because they do  not believe  they were
 rinsed.   The incidents  where health hazards have occurred, although few,
 have apparently made many disposal site operators leery of pesticide
 containers.

      e.   Holding  Areas

      Several members of state and county agricultural staff believe
 that holding areas  operated by  the counties  are not acceptable,
 They believe that if such holding areas were readily available,  they
 would be deluged  with persons attempting to leave pesticides  and contain-
 ers  there and that  these  could  have a serious  health and environmental
 impact.
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     On the other hand, several applicators and distributors felt that
holding areas operated by the county or private concerns would be helpful.
Holding areas would eliminate the problem of having the distributor
handle pesticide containers more than once and would not involve him in
the return.  If sufficient holding areas were located throughout the
state,  consumers would know that there is a nearby place where the
container could be deposited safely until the containers could be re-
cycled or reused.

     f.  Reuse and Recycle

     Because reuse and recycle is already prominent in California, it
was not surprising that these systems found considerable acceptance.

     Concerning reuse of containers, one of the major integrated pest
control companies we visited believes that the returnable container
system would best suit their needs.  Although they currently contract
for disposal in landfills, they believe that either a returnable system
or one in which pesticide containers are reconditioned or sold as scrap
is more useful.  They believe that the environmental and health hazards
involved in the recycling or reconditioning process could be minimized
and that resources could be conserved.  Several other distributors
are looking forward to the increased use of large plastic containers
which can be reused.

     On the other hand, state and county staff did not believe that
a system whereby the container is returned to the manufacturer or
distributor is workable except for returnable plastic containers.

     The general view of the cooperage firms and drum reconditioners
was that their business will probably become more profitable in the
future.  Some believe that whereas now they pay farmers and applicators
for empty pesticide containers, in the future farmers and applicators
may pay them for collection of the individual containers.  Cooperage
firms generally would not prefer the reusable container or the deposit
system since they now make considerable profit from their operations.
One drum reconditioner we contacted suggested six areas where attention
is needed in drum reconditioning; transportation, storage, mechanics
of reconditioning, employee exposure, residues, and ultimate reuse.
Although he did not give specific recommendations in each of these
problem areas, he believed that a coding system for containers by a
combination of painting and embossing of symbols should be accomplished.
The embossing could be done along with the DOT classifications.  He
felt that it should be against the law to remove the embossed designa-
tions.  This way both the reconditioner and the user can be certain that
a pesticide container does not enter beverage, feed, or other channels
where exposure could be a problem.  Such a system also could be used to
help assure that containers were used and reused for similar chemicals.
He also suggested that all containers, 30-gallon or larger, should be
reconditioned.
                               93

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     Cooperage firms and reconditioners did not believe that small
containers could be reused.  Instead, these companies and many dealers
and applicators felt that scrap metal companies will probably become
more important in the pesticide disposal process.  Rather than bury
small metal containers in a landfill, they feel the best solution would
be to have counties operate holding areas and have applicators and
farmers bring rinsed and/or crushed pesticide containers to  the holding
area.  A scrap dealer or other disposal contractor would then collect
and recycle the containers.  Most people believed this could be a
profitable operation for counties as well as for the scrap dealers
and could present a reasonable solution for the pesticide applicators
or farmers.  One of the problems is assuring rinsing of the containers,
but even if they are not rinsed, most people feel that the hazards
involved would be relatively small.  It was felt that if only scrap
dealers collected the pesticide containers, they would soon become
knowledgeable of the hazards involved and be able to rinse out containers
in their own facilities with minimum difficulty.  Only one reconditioner
we contacted felt that pesticide drums or containers should not be used
as scrap because of the hazards involved.

     g.  Deposit Systems

     Attitudes toward deposit systems were mixed.  Several state staff
members believe that a returnable deposit system would be very valuable.
They suggested that associating dollars with containers would make
containers a more valuable commodity and thus they would be handled in
a more reasonable fashion.

     Several applicators believed that a deposit system should be
developed.  It was mentioned that deposit systems are now used on pallets
and oil drums and work well.  One applicator favored a uniform, reusable
deposit system which he described as similar to that currently in use
with "beer kegs."  He indicated that such a deposit system could use
a color coding or other markings in a more direct and straightforward
manner than the current markings and labelings and suggested that a
uniform standard of codings and markings be adopted among pesticide
producing and marketing companies.

     Another formulator, distributor and custom applicator we contacted is
already involved in a returnable deposit system for large plastic drums.
Although they pay a $15 deposit on these drums and freight costs for
returning them, they adhere to this process because it  is most economical
for  them at the present.

     Another major dealer  believed that large containers, 30-gallons
and  over, should be reconditioned and reused and suggested that a deposit
of $9-10 might be appropriate, in view of  the cost of new drums of
$10-15.  He was not sure of the feasibility of the deposit and/or re-
cycle  system in view of the high cost of transportation and  the possible
large  distances between users and reconditioners.
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     A reason  given by several dealers who would not like a deposit
system is that they have relatively small storage facilities for con-
tainers they would have to handle in a deposit system.   They suggested
a recycling system where farmers bring containers to an appropriate
collection point and receive a deposit payment.   The general consensus
of dealers was that the recycling with a deposit system should be done
through drum reconditioners or through scrap dealers rather than through
pesticide distribution systems.

     9.  Environmental Effects

     The State of California has been compiling data on the fish and
wildlife losses caused by pesticides for over ten years.  Examples of
the reported accidents caused by disposal of pesticide containers
include:

     •  On September 7, 1971 a five-gallon can of "Hydrothol 191" was
        found dripping into a drain near Richvale, California.  Over
        1000 fish were killed (mostly carp).

     •  In a stream near Mather Air Force Base an extensive fishkill
        was noted in 1964.  Nearby, it was found that pesticide
        containers were being emptied of leftover material by military
        personnel at the Air Force Base.  Enough toxic material entered
        the stream to kill fish for several miles.

     Overall, state personnel feel that the number of accidents caused
by pesticide containers is minor compared to other causes of pesticide-
related accidents.  Furthermore, with the implementation of the state
disposal regulations, it appears that the number of accidents from
container or pesticide disposal is decreasing.
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D.   MISSISSIPPI - FIELD STUDY

     1.  Overview of Agriculture in Mississippi

     The importance of agriculture to Mississippi's economic structure
has been decreasing for the last 25 years.  Although agriculture's contri-
bution to total industrial based earnings in the State has remained about
the same dollar value since 1950 ($500 to $600 million), the percentage
contribution has declined from about 30% in 1950 to a projected 10% in
1980.

     Agricultural employment accounts for about 113,000 persons (15%) of
the labor force employed in major agricultural sectors in Mississippi.
Approximately 85,000 of the farm workers are classified family labor
while the remaining 28,000 are hired labor.

     The number of farms in Mississippi decreased nearly 50% during the
period 1959-1969, from 138,000 to 73,000.  During this same period,
average farm size increased from 135 acres to 221 acres (64%).  In general,
this shift can be interpreted as a movement to more highly capitalized,
mechanically efficient farms with a heavy reliance on purchased inputs
including pesticides.

     Only 27,100 farms (37%) in Mississippi are classified as commercial
farms, i.e., with annual sales over $2,500.  About one-third of these
specialize in cotton or cash grain, the majority of the remainder emphasize
livestock and mixed family operations.  The relative importance of the
agricultural production sectors in Mississippi has been quite constant
in recent years with crop production and livestock production contributing
about equal proportion to the state's total agricultural income.

     Crop production in Mississippi is dominated by cotton and soybeans.
During the period 1971-73, these two crops accounted for approximately
80% of the harvested cropland acreage in the State.  Cotton production
in Mississippi averaged nearly 14% of total U. S. cotton production in
the years 1971-1973.  Cotton production requires about 30% of Mississippi's
harvested cropland acreage.  Mississippi is said to possess an economic
advantage in cotton production (compared to Texas and California) with
average yields considerably above the national average due to favorable
soil and climatic conditions.

     Since 1950, soybean acreage in Mississippi has steadily increased
until  it is now  the major crop in the State in terms of cropland utilized.
Soybean acreage  occupied nearly 50% of harvested cropland in the period
1971-1973.  Soybean yields in Mississippi are reported to be nearly 25%
less than U.S. average yields.  However, the restrictions on cotton
acreage by government controls in the past and by the restrictions of  the
present market necessitate an alternate crop to cotton, especially on  the
land least suited for cotton production.  Soybeans have proved to be
more profitable, even at relatively low yields, than any other major crop
available to Mississippi farmers.  Total soybean production averages about
                                   96

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4% of total U. S. production.

     A summary of Mississippi crop acreages, yields and crop production
is presented in Table 32, along with comparisons to total U. S. production.

     The dominant livestock activity in Mississippi (about two-thirds
of total livestock income) is beef cattle production.   Sales of hogs,
dairy and poultry comprise the bulk of the remainder of livestock income.
Beef cattle operations in Mississippi are primarily cow/calf and back
grounding operations.  No large-scale feedlot fattening operations are
reported for the State.  The beef cattle raised in Mississippi are fed
primarily on native and cultivated pastures supplemented with locally
grown and imported grain and hay.

     2.  Pesticide Use in Mississippi

     An estimated 30 million pounds of insecticide active ingredients
were applied in Mississippi in 1974, a 30% increase from 1973.*  Approxi-
mately 90% of this total was purchased in liquid form while the remainder
was in granular, wettable powder or dust formulations.  Two insecticides
comprise about 85% of the market; Methyl Parathion and Toxaphene with
38% (11.5 million Ibs A.I.) and 47% (14 million Ibs A.I.), respectively.
These two major insecticides are commonly formulated both alone and in
combinations, such as:

          6# Toxaphene + 3# Methyl Parathion
          6# Toxaphene + 1.5# Methyl Parathion

     No insecticides other than Toxaphene or Methyl Parathion are believed
to possess greater than a 3% market share.  The most widely used other
insecticides are:

          Insecticide                       Formulation

          Azodrin                           Liquid
          Guthion                           Liquid
          Chlordane                         Liquid
          Endrin                            Liquid
          Strobane                          Liquid
          Di-Syston                         Granular
          Temik                             Granular
          Thimet                            Granular
          Sevin                             Wettable Powder and Dust
*
 The source for much of the data in this section was the Mississippi
 State Extension Service.
                                   97

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     Table 32.    Mississippi and U. S. Crop Production, Selected
                            Grogs, 1973
Crop

Mississippi

Cotton Lint
Corn for Grain
Soybeans for Beans
Oats
Wheat, All
Rice2
Sorghum for Grain
Irish Potatoes
  late spring
Sweet potatoes
Peanuts3
Hay, All
Peaches^
Pecans, All

United States

Cotton Lint
Corn for Grain
Soybeans for Beans
Oats
Wheat, All
Rice2
Sorghum for Grain
Irish Potatoes,All
Sweetpotatoes
Peanuts-^
Hay, All
Peaches
Pecans, All
Unit
Harvested
Acreage
 Yield
 Per Acre
        (thousand)   (unit)
Ibs
Bu
Bu
Bu
Bu
Ibs
bu

cwt
cwt
Ibs
tons
mil Ibs
Ibs
  1,340
    148
  2,750
     20
    100
     62
     30

      2
      9.5
      9.5
    650
  645
   39
   22
   40
   27
4,306
   35

   85
  110
1,750
    1.86
Production
(thousand)

   1,800
   5,772
  60,500
     800
   2,700
   2,670
   1,050

     170
   1,045
  16,625
   1,208
      10
  22,000
Ibs
bu
bu
Bu
Bu
Ibs
Bu
cwt
cwt
Ibs
tons
mil Ibs
Ibs
11,995
61,760
56,416
14,110
53,875
2,170.2
15,940
1,303-1
113.2
1,495.7
62,190
	
	
519
91.4
27.8
47.0
31.8
4,277
58.8
228
111
2,323
2.16
	
	
12,958
5,643,256
1,564,518
666,867
1,705,167
92,765
936,587
299,410
12,534
3,473,837
134,608
2,604.9
275,700
 Yield in pounds, production 480-pound net weight bales.
2
 Yield in pounds, production in 100-pound bags.
3
 Harvested for nuts.
4
 Production in million pounds  (Miss. Prod, in 48-pound equivalents,
 1973 (208,000); U.S. Prod, in 48-pound equivalents, 1973
 (54,269,000).

Source:  Mississippi Crop and Livestock Reporting Service,
         December 1, 1974.
                                  98

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     The majority of insecticide application in Mississippi is on cotton.
Typically, cotton acreage will receive eight or more insecticide applica-
tions at rates ranging from 0.75 Ib/acre A.I.  (Methyl Parathion) to 2.0
Ibs/acre A.I. (Toxaphene).  It is estimated that 80-85% of all insecticide
applications in the State is for cotton with 10% applied to soybeans and
the remaining 5-10% devoted to minor agricultural and non-agricultural
uses.

     An estimated 10-15 million Ibs of herbicide active ingredients were
applied to cotton and soybeans in Mississippi in 1974.  Cotton received
an estimated 65-75% of herbicide application.   Estimates of 1972 percentage
of acreage treated by herbicide and by stage of crop growth are presented
in Table 33 and Table 34, for cotton and soybeans, respectively.  These
estimates are based on a survey conducted by the Mississippi State Extension
Service for the 80 counties comprising nearly 100% of acreage of these
crops.

     Precise estimates are not available for fungicide usage in Mississippi.
However, based upon fungicide usage rates for cotton and soybeans through-
out the U.S., we estimate that the total annual application for this
class of pesticide is substantially less than 1 million pounds.

     Pesticide usage by the livestock is insignificant.  The USDA
"Pesticide Review" for 1972 reported only 1% of the value of Mississippi
pesticide sales was for livestock usage.

      3.   Pesticide Distribution System

      The  pesticide distribution system within Mississippi is relatively
simple.   A small number of firms supply the pesticide needs of  farmers.
A flow diagram of pesticide distribution is presented in Figure  4.

      This system is typical for distribution of insecticides.   Little
formulation of herbicides takes place in Mississippi.  However,  the
organizations which act as insecticide formulators also act as  the major
distributors of herbicides within the state.

     Seven organizations perform the majority of insecticide distribu-
tion and a large percentage of herbicide distribution:
                                    99

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            Table 33.   Estimated  Percentages  of Cotton Acreage Treated
         With Herbicides by Herbicide and  Stage of Growth in Mississippi. 1972

                               Preemergence  Stage
Herbicide
Treflan
Planavin
Cotoran
Karmex
Telvar
Herban
Caparol
Percentage of
Acreage  Treated

       12.0%
       4.0%
       11.0%
       6.0%
       1.0*
         .3%
         .1%
          Herbicide  Combination
           over  Treflan
           over  Treflan
           over  Treflan
           over  Treflan
           over  Treflan
or Planavin
or Planavin
or Planavin
or Planavin
or Planavin
                  Percentage of
                  Acreage Treated
45.0%
14.0%
 5.0%
 1.0%
  .5%
Total Acres Treated
   Preemergence  542,826
                         Total  Acres  Double  Treated
                             Preemergence  1,057,392
Herbicide
Percentage of
Acreage Treated
Herbicidal Oil
Mobilnix
MSMA or DSMA
(alone)
MSMA or DSMA
+ Herban
MSMA or DSMA
+ Cotoran
MSMS or DSMA
+ Karmex
MSMA or DSMA
+ Caparol
MSMA or DSMA
+ Lorox
Dinitro (alone)
MSMA or DSMA
+ Dinitro
Dinitro + others
4.0%
2.0%

40.0%

6.0%

69.0%

52.0%

10.0%

10.0%
3.0%

30.0%
5.0%
Postemergencq Stage


          Herbicide


          Karmex
          Lorox

          Cotoran

          Other
Total Acres Treated
   Postemergence  3,804,543
                                                            Layby
                 Percentag
                 Acreage  Treated

                        23.0%
                        11.0%

                         3.0%
                          Total Acres
                             Treated Layby 595,691
Notes:  Cotton was cultivated an average of 3.6 times.
        Total acres planted—1,603,563 (80 counties)

Source:  Mississippi Extension Service
                                          100

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             Table 34.   Estimated  Percentage  of  Soybean Acreage Treated
with Herbicides by Herbicide and Stage of Growth in Mississippi

Preemergence
Herbicide Percentage of
Acreage
Treflan 31.
Planavin 12.
Amiben 3 .
Dyanap 9 .
Lasso 3.
Lorox 3.
Vernam
Solo
Maloran
Total Acres Treated
Preemergence 1,283,408

Herbicide

Dinitro at "cracking"
Tenoran directed
2, 4-DB directed
Lorox
Wax bar
Other
Treated
0%
0%
0%
0%
0%
0%
3%
3%
1%


Postemergenca








.Stage
Herbicide Combination



plus Treflan or Planavin
plus Treflan or Planavin
plus Treflan or Planavin
plus Treflan or Planavin
plus Treflan or Planavin
plus Treflan or Planavin
plus Treflan or Planavin
Total Acres Double Treated
Preemergence 321,606
^Stage
Percentage of
Acreage Treated
24%
4%
9%
7%
2%
5%
, 1972

Percentage of
Acreage Treated


3.0%
8.0%
1.0%
3.0%
<.!%
<.!%
<.!%











Total Acres Treated
   Postemergence 1,052,492


Notes:   34% of treated soybeans had only one postemergence spray

         14.4% of treated soybeans had two or more postemergence sprays

         Soybeans were cultivated an average of 2.8 times

         Total Acres Planted — 2,103,625 (80 Counties)


Source:   Mississippi State Extension Servicp
                                      101

-------
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                                                                 102

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Organization             Location

Staple Cotton Growers    Greenwood
Assoc.

Valley Chemical          Greenville

Helena Chemical          Belzonia

Riverside Chemical       Marks

Cleveland Chemical       Cleveland

Thompson-Haywood         Greenville

Miss. Fed. Cooperative   Jackson
                     Function
                co-op form. & distrib.
                form. & distr.
                     No. of
                     Formulating
                     Plants
                         1
                         3
                         4
                       unknown

                         1
                distributor
Several of these firms also provide entomological consulting services to
farmers.

     Based upon discussions with representatives of these organizations,
we believe that most sales of pesticides are made direct to the large
farmer or applicator by the formulator/distributor.   Retail outlets
serve mainly small farmers and "pick-up" business.   The cooperatives
and cooperative retail stores often perform only a facilitating function,
taking orders, buying in bulk and arranging delivery while never
actually having physical possession of the product.

     4.  Magnitude of the Pesticide and Container Disposal Problem

     a.  Number and Types of Containers

     Estimates of the number of pesticide containers by type in Mississippi
are presented in Table 35.
            Table 35.
Estimated Number of Insecticide
Containers used in Mississippi
     Container Type

     55-gal drum (metal)
     30-gal drum (metal)
     5-gal (metal)
     1-gal (glass & plastic
     Other
                           TOTAL
               1968
(thousands)

 1969    1973
1974
46.5
13.5
185.0
351.0
100.0
65.8
16.0
240.0
400.0
115.0
49.1
17.0
228.0
775.9
102.1
90.9
24.0
334.0
620.0
180.7
               696.0   836.8  1172.1  1249.6
     Source:   1974 data—ADL estimates based on Bureau of Environmental
              Health Data.   1973 data—Mississippi State Extension Service.
              1968 & 1969 data—Stojanovic,  B.U.,  F.L.  Shuman and M.J.
              Kennedy (1969),  Basic Research on Equipment and Methods for
              Decontamination and Disposal of Pesticide Containers,
              Mississippi Ag.  Exp.  Stat.
                                 103

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     Detailed information on the number and type of herbicide containers
was not available.

     A significant development in pesticide handling in Mississippi is
the use of bulk pesticide tanks.  These tanks, ranging in size from 500-
5000 gals, are placed by the chemical company on a large farm, PCO airstrip
or central distribution point.  Product is metered from the tanks with
the chemical company refilling when necessary.  The tank may be owned
by the pesticide distributor or the farmer.  Several companies now have
25-30 bulk tanks throughout the state.

     The advantages of using bulk tanks are said to be:  elimination of
container disposal problems, storage convenience, handling convenience
and cost savings.  However, bulk tanks are regarded as an
experiment.  Negative factors cited for bulk tank usage were:  high
capital cost (tanks and trucks), company liability (for  vandalism or
contamination), and farmer prejudice.

     b.  Quantities of Pesticides Requiring Disposal

     There has been no comprehensive study of the quantity of unused or
unwanted pesticides requiring disposal in Mississippi.  Most sources we
contacted indicated that they believed the quantities for disposal were
small.

     c.  Pesticide Distribution Practices and Container Disposal
         Problems—Case Examples

     Several examples of the distribution practices of formulators and
distributors are discussed below because they significantly impact
current and future container disposal practices.

     Company A
     Company A is a cooperative which serves about 950 large cotton
farmers in the Mississippi Delta.  Their distribution area is concentrated
in the area near their formulation plant.  The plant produced 1.75
million gallons of pesticides in 1974.  1.25 million gallons of these
pesticides were distributed directly to farmers in bulk tanks located on
52 different airstrips.  The size of tanks at these airstrips varies
according to the demand, ranging from 1400 to 5000 gallons.  Bulk tanks
were introduced by Company A in 1970.  The bulk tank capacity has doubled
every year since.

     In 1974 two products were delivered in bulk tanks:  a mixture of
six pounds of Toxaphene and three pounds Methyl Parathion per gallon, and
a three pound per gallon formulation of sodium chlorate.  Additional
pesticide used on the farm are added directly from small containers to
the aircraft spray tanks.  Cleaning equipment is available to prevent
cross contamination.
                                  104

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     The remaining 500,000 gallons of chemical not distributed in bulk
tanks are distributed in 55-gallon drums and 5-gallon metal cans, primarily
in the 55-gallon drums.  Pesticides are distributed from the formulation
plant to one of the 17 warehouses used by Company A.  Three of these
outlets are fully owned and operated; the remaining 14 are operated by
selected farm supply businesses.  These outlets serve as a pickup
point for co-op members.  The outlet owners are paid a fee for warehousing,
handling and filling orders.  The shift to bulk tanks by Company A was
motivated by the desire to provide a lower cost to farmers.  Since Company
A is a co-op and gives patronage refunds to farmers, they feel that they
can give higher refunds through the lower cost achieved by using bulk
tanks.  Company A also has seven entomologists  on their staff who pro-
vide consulting services to the farmers at no cost.  These entomologists
also assist the aerial applicators in achieving the correct pesticide mix.

     Company B

     Company B formulates five principal compounds:

     e  A four pound per gallon formulation of Methyl Parathion;
     •  A six pound per gallon formulation of Toxaphene;
     •  A formulation of six pounds per gallon Toxaphene with 1 1/2
        pounds per gallon of Methyl Parathion;
     •  A formulation of 1.6 pounds per gallon Methyl Parathion
        with 1.6 pounds per gallon Endrin; and
     •  A formulation called Defend 267.

     Direct sales of these formulations are in:

     •  bulk tanks (four);
     •  55-gallon drums (majority of product);
     •  30-gallon drums (small volume); and
     e  5-gallon cans.

     Company B also sells pesticide through four authorized agents who
operate farm supply stores.

     Company C

     Company C is a privately owned chemical company which operates
three formulating plants in Mississippi.  Company C distributes pesticide
in three ways:

     •  direct to farmers from the formulating plants;
     •  direct to farmers from company-owned chemical outlets
        in several locations; and
     •  to a variety of farm supply stores and small co-ops.

A large amount of pesticides are delivered directly to the farmers at
airstrips.   Company C presently serves more than 40 airstrips.  Most
product is delivered in 55-gallon drums.
                                  105

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     Company D

     Company D is a large supply co-op.   This firm does not own a
formulating plant but purchases pesticides from other formulators in
Mississippi.  Company D sells directly to farmers in 55-gallon drums
which account for 75% of their total volume, 5-gallon drums which are
about 1/8 of their total volume, and 1-gallon cans which are the remain-
ing eighth of their total volume.  Company D is discontinuing the use
of 30-gallon cans.  Bulk tanks are not used for pesticide distribution.
The reasons cited are the possible legal liabilities, the need for
pesticide mixtures, a lack of interest by area applicators and the
possible fear of being cheated when material is taken from the tanks.

     The majority of the Company D's business is what might be called
pass-through business which operates in the following fashion.  One of
the farm supply stores takes orders from a number of farmers and
consolidates these orders.  These orders are consolidated at a district
or a regional office of the co-op which then places an order with a
formulator.  The pesticides are delivered direct to the farmer by the
formulator if it is a large order or by the co-op if it is a small order.
In the majority of instances the product is never stored in the Company
D warehouse.  Aerial applicators do not buy any pesticides from Company
D; the pesticides are purchased by the farmers and then used by the
aerial applicators.

     Company E
     Company E is a co-op which owns a formulation plant and has 15 farm
supply outlets (warehouses) from which they take and fill orders for
co-op members on a fee basis.  Major products sold by Company E are a
formulation of four pounds Methyl Parathion per gallon and a formulation
of six pounds of Toxaphene and three pounds of Methyl Parathion per
gallon.  This co-op formulated 600,000 gallons in 1974.  Fifteen percent
of this chemical was distributed through bulk tanks; approximately 8%
in 5-gallon cans; and the remainder in 55-gallon drums.  This firm does
not use 30-gallon drums.  Representatives of this co-op stated that
the trend is toward greater use of bulk tank for pesticide distribution.
Their experience has been that the airstrip operators and aerial applicators
"love" the bulk tanks.

     Company F

     Company F formulates six major pesticides and mixtures in plants
in two cities in Mississippi.  Farm distribution is carried out in three
ways:

     •  direct to farmers from the plant;
     •  through 11 farm supply outlets owned by company; and
     e  to retail dealers such as Independent Farm Supply Bureau
        and small co-ops.
                                  106

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     This firm's goal is to have a retail outlet in every agricultural
trade area in Mississippi.  Company F is presently increasing its use
of bulk tanks and states that they much prefer this method of sale.
The company has from 20-30 bulk tanks located throughout Mississippi.
The remainder of the pesticide sold by this firm is in 55-gallon drums
(70%), 30-gallon drums (2% or 3%) and 5-gallon cans (10%); thus 17-18%
of the total is distributed through bulk tanks.

     From these examples, it is apparent that bulk tank usage is increasing
and that the majority of pesticides are sold in larger containers.
Collection and disposal of containers may be easier in Mississippi than
in several other states because of the extensive use of aerial applica-
tion and the direct delivery of pesticides to airstrips.

     5.  Status of Regulations and State Policies

     The disposal of unused pesticide containers in Mississippi is
covered under the "Solid Wastes Disposal Act of 1974."  Unused pesticides
and containers are classified as hazardous wastes and are to be disposed
of by means determined by the State Department of Health, the Bureau of
Environmental Health.

     Containers should be triple rinsed, crushed and buried in an approved
sanitary landfill.  Larger containers, such as 30- and 55-gallon drums,
may be sold  to reconditloners.  While it is legal to bury containers or
paper bags on private property, this practice  is not encouraged.

      Disposal  of  unused  pesticides must  be  referred  to the  Bureau  of
Environmental  Health which  is  responsible for  the ultimate  disposition
of  the material whether  it  be  incineration,  soil  injection,  sanitary
landfill,  shipment  overseas,  storage,  etc.

      6.  Current  Disposal Practices

      a.  Disposal of Small  Containers

      The State  of Mississippi's  pesticide container  disposal program
for 1-, 5- and  15-gallon containers  and  all combustible  containers is
integrated with the overall  solid  waste  disposal program administered
by  the Bureau  of  Environmental Health, a department  of the  Mississippi
State  Board  of Health.   The  program  operates  in the  following manner.

      •  In areas/counties where  garbage  collection  is  unavailable,
        the  state places containers  for  disposal of  waste (including
        pesticide containers), 4  to  6  cubic yards  in volume,  at
        locations convenient  for  any disposer,  such  as major cross
        roads, near housing  projects,  etc.   Usually  those who need  to
        dispose of  solid waste are no more  than 2 miles  from a  disposal
        container.   On  the  average,  there is  one container  for  every
        150  people.
                                107

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     •  The disposal containers are emptied twice a week.  Containers
        which, by experience, tend to fill up quickly are emptied more
        often.  A diesel engine truck, with a volume of 30-35 cubic yards
        and a compaction ratio of 4 to 1, is used to empty the container.
        The schedule in most counties calls for collection of waste in
        one-half of the county on Monday and Thursday and the other
        portion on Tuesday and Friday; Wednesday is for maintenance and
        collection at those sites which require more than two pickups
        per week.

     •  All solid waste which is collected is taken to the sanitary landfill
        in the county.  When all sanitary landfills are in operation,
        no disposal container will be more than 20 miles from the sanitary
        landfill site.  At the sanitary landfill, the solid waste material
        is spread, packed and covered each day.  The sites are also open
        to the public for disposal of items which are too large to be
        deposited in the collection containers.

     The Bureau of Environmental Health conducts several projects to
inform the public about the program.  Printed circulars are distributed
in all the counties.  These outline the various parts of the program
and contain,.a county road map with all container sites located on it.
People from the Bureau will speak and present a slide presentation to
civic organizations.  A program in conjunction with the Cooperative
Extension Service has been planned.   The program will consist of meetings
with farmers in the various counties to inform them about the safe disposal
of pesticide containers.  The program is only several years old, but the
state people feel that it is very successful.

     There are several recommended methods for disposal of pesticide
containers which come from the Bureau of Environmental Health and from
the Cooperative Extension Service.  The Bureau of Environmental Health
recommends the following procedures for containers up to 15 gallons:

     triple rinse all containers  (except paper bags);

     puncture all cans; break glass containers and remove caps from
     and slash, cut, or mutilate plastic bottles, and

     deposit in solid waste containers along with tne household
     refuse.

     Most of the persons we contacted indicated that most users only do
"one quick rinse."  This is done primarily to get as much out of the
container as possible because of the high cost of the pesticide, rather
than as a safe practice.  Based on observations of the Bureau of
Environmental Health staff, most of the cans which are deposited in the
solid waste containers have been crushed.  Plastic bottles usually have
only had the caps removed and are not slashed, as recommended.

     Combustible material can also be disposed of in the solid waste
containers.  However, most users burn these materials at the site of
                                    108

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use.  This is a violation of state law but very few individuals are
ever "caught" and prosecuted or fined for this violation.

     The program appears to be effective for container disposal.  The
farmer can dispose of his empty containers with his other solid waste
as opposed to two separate disposal streams.  This also eliminates the
time-consuming process of digging a pit for burial.  State inspectors
have noticed a "substantial decrease" in the number of pesticide
containers left by the side of the road, on the banks of streams, floating
down the river or in other places where they could cause health and
safety as well as aesthetic problems.  The overall safety of the approach
has not been validated.

     Another disposal  option is presented by the Cooperative Extension
Service which distributes a number of publications on the recommended
methods for disposing  of pesticide containers.  This agency recommends
the following procedures:

     •  For combustible containers,  including paper bags, fiber drums,
        burlap bags, cloth bags, cardboard boxes, fiber boxes and wooden
        boxes, the disposal methods, in order of preference, are:
        burning in a commercial incinerator; burning in a supervised
        public or private dump; open burning at the site of use if
        permitted by local authorities, or crushing and burial under
        at least 18 inches of soil, away from water, livestock, etc.

     •  For small, non-combustible containers (glass, plastic, or metal
        containers up  to and including 5-gallon size), "it is strongly
        recommended that this type of empty container not be reused
        for any purpose."  An exception may be a 5-gallon metal container
        if "it is deemed of sufficient economic value."  The disposal
        steps are:

        -  Wash outside of container with water; rinse inside of
           container with water containing detergent and caustic
           soda (sodium hydroxide);

           Discard rinse solution by burying at least 18 inches deep
           in an isolated area, away from water supplies;

           Break glass containers; puncture and mutilate plastic
           containers; puncture and crush metal containers;

        -  Discard in  a designated landfill or bury on farm property
           following recommendations for construction of disposal pit.

     These guidelines  are in general agreement with those of the Bureau
of Environmental Health (i.e., burial in a landfill) with the exception
of the desired "treatment" prior to actual disposal and the fact that
the Bureau does not mention burial on private property.  The Bureau of
Environmental Health hopes that their program with the Cooperative
Extension Service will bring the two agencies into agreement on the
                                109

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recommendations.

     The disposal system described is used primarily by the small farmer.
Users of large amounts of pesticides—such as owners of large acreage
or commercial applicators—employ different methods of handling
container disposal.  When they have accumulated a large number of the
smaller containers, they use their own truck to transport the containers
directly to the sanitary landfill nearest their operation.  There is
also a disposal service in the northern part of the State which will
handle pesticide container disposal for a fee.  The service simply picks
up the containers at the customer's operation and transports the
containers to the state-operated sanitary landfill.

     Because this program is relatively new, it is difficult to
ascertain how well the program is working and how many farmers and
applicators follow the  state recommended approach.  Most of our
contacts indicated that the program was making progress and was "not
unreasonable."

     The Department of Biological and Agricultural Engineering at
Mississippi State University conducted a study in 1970 to ascertain what
users did with their empty containers.  A summary of their findings is
given in Table 36.   Those containers which were kept or sold to the
public (usually 30- and 55-gallon drums) frequently ended up in such
uses as barbecue pits, whisky stills, water troughs, animal feed
troughs, etc.

          Table 36.  Methods of Disposal of Pesticide Containers,
                                 1970
       Method                                         Percent

       Buried                                           18.4
       City dump                                        16.6
       Burned
          metal                                          5.8
          plastic or paper                               4.2
       Kept                                             15.3
       Sold to:
          reconditioner                                  6.6
          public                                         6.8
       Thrown  in gully or on farm trash pile             8.9
       Crushed                                          9.5
       Returned to dealer                                7.4

       Source:  Mississippi State University, Dept. of Biological
                and Agricultural Engineering, 1.970.
                                  110

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     b.  Large Container Disposal

     The disposal of 30- and 55-gallon drums is  just  beginning to
be handled by the State.  In two of the delta counties, the State has
established a holding site at the sanitary landfill.   Users can leave
their empty containers there anytime the dump is open.  When a sufficient
number of the drums have accumulated, the State calls a cooperage firm
in Louisiana.  The firm picks up the drums and reconditions them.   The
money received from the sale of the drums is given to the Boy Scouts.
The program has only been in effect since spring of 1974, but, in the
two counties over 700 drums have been collected.  Plans have been made
for similar holding sites in all delta counties by spring, 1975.  The
program may later be expanded to include all counties, even though there
may not be many drums to collect.

     The Cooperative Extension Service recommends that 30- and 55-gallon
drums be sold to a reconditioner.  If this is not possible, they suggest
disposal by one of the methods suggested for smaller containers.

     Our discussions with pesticide formulators and applicators on
disposal methods indicated that drum reconditioners in Mississippi,
Louisiana, and Tennessee pick up most 30- and 55-gallon drums at air-
strips.  Farmers are given cash for the drums, or they may be given a
credit by the cooperative or distributor who is paid by the drum re-
conditioner.  The cooperatives usually operate the pickup service at
no profit.  However, other cooperatives do not participate in the drum
return; it is handled directly by the farmer or applicator.  Some
cooperatives will remove 5-gallon cans from airstrips and bring them to
sanitary landfills as a service to the farmer/applicator.  The general
belief is that most of the larger containers—30- and 55-gallon—
are sold to reconditioners;  smaller metal containers are sent to landfills.

     One drum reconditioner we contacted reconditions the drums via a
series of washings with different solutions.  The insides are washed
eight times and the exterior are washed six.  The process is completely
automated from unloading of drums through to storing of completely
reconditioned drums.  Sludge from the washing solutions is burned in an
incinerator.  The reconditioned drums are not sold for use in the food,
feed or cosmetic industry.

     c.  Disposal of Pesticides

     The disposal of unused pesticides is supposed to be referred to
the Bureau of Environmental Health.  Table 37 summarizes the findings
of a study of disposal practices in 1970 (Mississippi State University,
1970).  The Cooperative Extension Service recommends the following
methods, in order of priority:

     •  Incineration, if acceptable facilities are available;
                                 111

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     •  Use for purpose originally intended, if it is not illegal;

     •  Return to manufacturer or distributor for potential re-
        labeling, recovery or reprocessing;

     •  Burial in a specially designed landfill; and

     e  Temporary storage if none of the above are possible.


        Table 37.  Methods of Disposal of Unused Pesticides, 1970

     Method                                             Percent

     Return to dealer (usually unopened containers)       7.0
     Dumped in city sewer system                          1.6
     Applied to soil surface                             15.6
     City dump                                           11.0
     Sanitary landfill                                    6.3
     Buried                                              24.2
     Burned                                               7.0
     Stored for possible future use                      27.3
     The State Environmental Agency will accept these methods if the
user has only a small quantity.    Large quantities have been handled
in several ways:

     •  Materials should be encapsulated in large concrete "containers"
        and buried in a sanitary landfill which is equipped with special
        wells for monitoring for any leakage or leaching of the
        materials;

     •  Large quantities of DDT should be sold to foreign countries
        or to organizations which distribute them for use in under-
        developed nations; and

     •  Temporary storage pending a final acceptance disposal
        alternative  (or use if the ban on the material is removed).

     Mississippi State University has investigated disposal methods
primarily for pesticides but also some for containers.  Their research
has encompassed three basic areas:

     •  Microbiological degradation—This process involves the
        degradation  of pesticides (and residual material in containers)
        by soil micro-organisms.  Degradation ranged from almost none
        to a high of 36%.  However, the pesticides were found to cause
        slight  to severe  (99%) reductions in the microbial population
        in the  soil.  This disposal route is satisfactory for very
        small amounts or a few cans, but cannot handle large volumes.
                                  112

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     •  Chemical degradation—The only substances found suitable
        for detoxifying all major types of pesticides were liquid
        ammonia and metallic sodium.  Both these agents requite extreme
        caution when used and are likely to cause more accidents and
        environmental damage than the pesticides themselves.

     •  Thermal degradation—A pilot plant incinerator was built to
        handle 12 gallons/hour of pesticides.  All pesticides were
        degraded at a temperature above 900°C (1652°F).  Containers
        must be shredded prior to introduction into the incinerator.

     Staff of the state university believe that thermal degradation appears
to offer the best means of disposal at the present time.  Operated in the
proper manner with the necessary pollution control equipment, incineration
is even more desirable, from environmental and safety standpoints, than
landfilling.

     One other route of disposal which has been suggested but not
evaluated is a combination of microbiological and thermal degradation.
In this process, the pesticide (or container) would be partially de-
composed by burning at a lower temperature (say 250°C) and then subjected
to soil micro-organisms for final decomposing.  This would appear better
from an energy standpoint than total thermal degradation.

     7.  Cost of Disposal

     Limited cost information was obtained in Mississippi.  Staff of
the Bureau of Environmental Health provided some cost estimates for
the disposal system which they operate in Mississippi.  On the basis of
one ton  of waste disposed, the waste collection containers, storage
and pickup costs $6/ton and the disposal in the sanitary landfill costs
$2.25/ton.  Costs of some of the components of the system are:

        Waste collection container (4 cu yd)           $290-295
        Truck (32 cu yd)                              $34,000-35,000
        Tractor (for landfill)                        $46,000-48,000

These costs are for the total solid waste disposal system not just for
pesticide container disposal- The capital investment for a county of
4000 population is about $88,000.

     In the recycle program, which the state operates for 30- and 55-
gallon drums, state people quoted the following average prices- paid by
the drum reconditioner in 1974:

        30-gallon                                     $1.25
        55-gallon                                     $2.25

A cooperage firm, however, supplied the following quotes from their
current (1975) price list:
                                  113

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        Picked up
        Delivered
        to Facility
30-gallon                 $1.00

55-gallon                 $1.50


30-gallon drum            $1.50

55-gallon drum            $2.00
The amount given for a mono-stressed, 55-gallon drum is 50
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E.   NEW YORK—FIELD STUDY

     1.  Overview of Agriculture in New York

     Although agriculture is important in the economy of New York, it is
one of the less important industries of the state.  About 95,000 persons,
or less than 2% of the State's labor force is employed on farms, compared
to a national average of 5.7% farm labor.  An additional 10% of the work
force in New York is employed in enterprises directly related to agriculture,
Farm income in New York accounted for 0.3% of total personal income in
New York in 1972, compared to 2.5% for the U.S. in 1972.  Cash receipts
from farming in New York from 1971 to 1973, including both crops and live-
stock averaged $1,200,000,000 per year or about 1.8% of the total U.S.
receipts; government payments were about $17,000,000.

     Approximately 34% (10.9 million acres) of New York's total land
area was devoted to farmland in 1969 as compared to 47% of total U.S.
land devoted to farmland.  The number of farms in New York is currently
estimated at 56,000 with an average size of 195 acres per farm compared
to a U.S. average farm size of 385 acres.

     The most significant aspects of New York's agriculture is the diary
industry.  During 1971-1973, New York produced 10.2 billion pounds of
milk annually, 8.6% of the total U.S. milk production.  In 1973 milk
production accounted for 53.3% of New York's gross agriculture income.
New York ranks number 2 nationally in the production of milk.

     A significant portion of field crop production (hay, corn, oats) is
fed to the dairy cows and other animals on New York farms.   Fruits and
vegetables also account for a significant share of New York's agricultural
income.  New York ranks number 1 nationally in the production of maple
syrup; number 2 in the production of apples, grapes,  tart cherries, and
snap beans; number 4 in the production of onions and  horticultural items.

     Milk, beef and veal, and eggs are the significant aspects of live-
stock production in New York.  Milk production in the state roughly equals
consumption.   However, the state's demand for meat and eggs far exceeds
the state's production.

      2.   Pesticide Use in New York
     The  state of New York requires that pesticide dealers report  their
 annual  sales of restricted chemicals.  However,  the  state has not  pro-
 vided the funds to have  the raw data  tabulated and published.  Knowledge-
 able people in the pesticide industry and the state  government have  said
 that no survey of pesticide usage  in  New York has been conducted since
 1952.   Hence, there appears to be  no  good source of  data on  the quantities
 of pesticides used in New York.
                                  115

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     Discussions with the Farm Chemicals Division of Agway- the largest
farm supply cooperative in the state, has however provided some useful
information.  Personnel at Agway estimated that they distribute approximately
1/3 of all pesticides marketed in New York.  Since Agway serves all types
of farmers in the Northeast, their list of top sellers is probably fairly
indicative of commonly used pesticides for the state.  Table 38 lists
Agway's top selling pesticides by type.  It should be noted that since
New York produces many different types of fruits and vegetables, many
chemicals are used in addition to those listed.

     Since good data do not exist, it was not possible to determine the
relative volumes of insecticide, herbicide, and fungicide usage.  However,
Agway personnel indicated that in fiscal year 1974, herbicides accounted
for about 52% of their total pesticide sales.


        Table  38.  Pesticides Commonly Used  in New York

      Herbicides           Insecticides          Fungicides

      Aatrex              Guthion              Maneb
      Lasso                Sevin                 Captan
      Princep              Monitor              Benlate
      Eptam
      Paraquat
      Premerge
      Lorox
      2,4-D

      Source:   Agway,  Inc.


      3.  Pesticide Distribution System

      The pesticide distribution system in New York is shown in Figure 5.
 The arrows indicate the  typical flow of chemicals.  There are several ex-
 ceptions to the flow indicated in the figure.  Local co-ops will, on
 occasion, purchase from  an independent distributor; likewise, an independ-
 ent dealer may purchase  from a regional co-op.  Also, chemicals will some-
 times be transported from a producer directly to a local co-op with the
 regional co-op serving as an ordering house and transportation.

      Some firms perform more than one function in the system, for example,
 some local co-ops in the state also serve as commercial applicators for their
 farmers.  Likewise, some independent dealers are also commercial applicators.
 Some farmers serve as commercial applicators for their farmer neighbors.
 Some private firms wholesale and retail pesticides.
                                  116

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 Figure 5.   Pesticide Distribution System in New York
                       PRODUCER
                      FORMULATOR
REGIONAL
COOPERATIVES
INDEPENDENT
DISTRIBUTORS
                      COMMERCIAL
                      APPLICATOR
INDEPENDENT
 DEALER
                    FARMER
                             117

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     Conflicting estimates were obtained from industry personnel con-
cerning the number of producers, formulators, distributors, and dealers
in the state.  It is generally believed that New York has numerous smaller
dealers, distributors and formulators due to the large number of small
volume crops produced.  Small firms are able to compete by serving a
specialty market.  Thus, it is not possible to estimate the number of
firms in each link in the distribution system.

     Personnel in the New York Bureau of Pesticide Regulation indicated
that a total of 5,000 firms are registered to handle pesticides in New
York.  This list includes producers, formulators, distributors, dealers,
and commercial applicators.  A breakdown of these firms by type was not
available.


     4.  Magnitude of the Pesticide and Container Disposal Problem

     No data exist on the number and type of pesticide containers dis-
posed in the state of New York.  Table 39 shows the typical types
of containers for the more common pesticides referred to earlier.
Discussions with industry personnel indicate that roughly 60-65% of all
pesticides sold in New York are believed to be marketed in paper bags
or cartons. The remainder are sold in 1 gallon or 5 gallon metal cans,
30 gallon or 55 gallon metal drums, 1 gallon or 5 gallon plastic con-
tainers, and a few glass bottles.

     Since no published data exists on the quantity of pesticides used
or the number of pesticide containers requiring disposal each year in
New York, it is impossible to estimate the magnitude of the disposal
problem.  The situation is compounded further by the fact that New York
agriculture is quite variegated.  Dairying predominates, but many dairy
farmers raise a number of different field crops such as alfalfa, corn,
oats, winter wheat, and soybeans as well as having considerable pasture-
land and sometimes wooded land.  The pesticide usage pattern of each of
these crops is quite different.

     On the other hand, a significant number of farmers in New York are
engaged in fruit and vegetable production.  These farms vary greatly in
size and number of fruit or vegetable crops produced.  Each of  these
crops have specialized pest management problems, and varying requirements
for pesticides.


     5.  Status of Regulations and State Policies

     Parts 325.5 and 325.6 of the New York State Environmental Conserva-
tion Law relate to the disposal of unused pesticides and pesticide con-
tainers.  Used containers may only be disposed of in approved sanitary
landfills, incinerators, or refuse disposal sites.
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Table 39.  Typical Containers for Pesticides
           Commonly Used in New York
 Pesticide

 AAtrex

 Lasso

 Guthion

 Paraquat

 Maneb

 Captan

 Sevin

 Princep

 Benlate

 Eptam

 Premerge

 Monitor

 Lorox

 2,4-D
Container(s)

paper bags

metal cans

metal cans

metal cans

paper bags

paper bags

paper bags

paper bags

paper bags

paper bags and metal cans

metal cans

metal cans

paper bags

metal cans
 Source:  Agway, Inc.
                      119

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     Disposal for combustible and non-combustible containers is
as follows:

     •  Combustible containers- burial or incineration at an approved
site or burning, in small quantities, at place of use with permission
of the local public health officials.

     •  Non-combustible containers- rinse at least twice, returning
rinse water to mix tank and dispose of at an approved site as listed
above.  The law does permit the reuse of certain pesticide containers
provided they are not for storage of water, human or animal food, cooking
utensils, dishes, clothing, and the like.  Containers destined for reuse
must be rinsed at least twice, tightly sealed and the exterior cleaned.
The reconditioning procedure and intended reuse must be approved by the
Department of Environmental Quality.

     The regulations specify that unused pesticides must be disposed of
by burying under at least 18 inches of compacted soil at a location where
ground or surface water cannot be contaminated.

     There were no approved public landfills which could accept unused
pesticides or containers at the time of our survey.   The Department of
Environmental Quality recommends burial on the farmer's property at a
site that is approved by the agency.  Unused pesticides may be incinerated
by an authorized disposal firm.  These guidelines are only temporary until
such time as approved landfills are available.


     6.  Current Disposal Practices

     The disposal of pesticide containers in New York State is handled
almost totally by burial.  The state law requires rinsing, at least
twice, and disposal at an approved site or burning, in small quantitites.
However, since there were no approved sites in the State during our survey, the
Department of Environmental Conservation (DEC) allows burial on the farm
at an approved site.

     The farmer may either apply pesticides himself or contract with a commer-
cial applicator to apply them.  The empty containers, which the farmer
has usually rinsed once, are usually buried somewhere on the farm, thrown
on a farm trash pile to "degrade" or taken with the household garbage to
a local landfill.  Even though the on-farm burial sites are supposed to
be inspected, no farms have ever been inspected due to a lack of manpower
in the DEC.  Almost all combustible containers are burned at the site of
use.  No information was found as to whether farmers contact their local
health authorities for permission to burn these materials as is required.

     Farmers who contract with a commercial applicator usually are "left"
with the containers for disposal.  In some cases, however, the commercial
applicator may take the containers and dispose of them with his other
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used containers.  When the farmer has supplied the commercial applicator
with the chemicals, the farmer will dispose of the empty containers in
the same way in which he would if he applied the chemicals himself.

     The commercial applicator in New York generally operates on a rather
small scale.  For example the average aerial operation consists of 1 or 2
aircraft and about 3 employees.

     Commercial applicators almost always use combustible containers, dispos-
ing of  them in small quantities   at his  place of  business or at the location
where the pesticide is applied.  Containers of the 1 and 5 gallon size
are either crushed or bioken and taken to a landfill.  The applicator
usually does not have the time or space to bury them on his property.
The 30-and 55-gallon drums generally go to reconditioners.  Only few
applicators have bulk storage tanks, which reduce the container disposal
problem.

     There are two drum reconditioners in the state which will accept
pesticide drums.  They require the user to rinse out the drums and
replace the bungs.  In the reconditioning operation, the tops of the drums
are removed and then the drums are burned at 1500°F, shot blasted (with
steel shot), dedented and painted.  The drums are then sold to non-food
connected industries as prescribed by law.

     The New York State College of Agriculture at Cornell University
conducts mini-courses for farmers and applicators on the use of pesticides
and disposal of containers.  Their recommendations are the same as the
DEC; in fact, the people at the university work closely with DEC in
establishing the guidelines.

     There is only one firm approved by the state to handle pesticide
disposal.  The firm employs incineration as the disposal method.  Because
there were no approved landfills in the State, DEC did allow other methods
of disposal for small quantities.  These include use (if not illegal) at
the recommended application rate, burial on the farm or storage until a
suitable disposal method can be found.  In 1975,  the State planned to
pick up and dispose of all unused pesticides from the farmer and commercial
applicators.  How this system will be financed and operated is not known.
They will probably "package" them and send to the approved incinerator.
Cornell handles many inquiries from farmers in regards to small amounts
of unused pesticides.  The quantities are usually less than 1-gallon, i.e.,
a partially used container.

     Farmers who have unused pesticides will store the pesticides, usually
in a locked enclosure, and use it next year in the recommended manner.
The New York State College of Agriculture and the pesticide department of
DEC regularly receive many calls regarding disposal of unused pesticides.
If the quantities are small, they recommend application at the specified
                                 121

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rite.  For larger quantities, usually in the possession of commercial
applicators or large farmers (of which thtte are relatively few),
they did recommend stoi ige but will offer to pick it up.   Several
years ago, the State College of Agriculture collected a large quantity
of unused, banned pesticides (e.g. DDT) and took it to Dow for
incineration.  They do not plan to do this again because the DEC will
soon handle disposal.

     7.  Cost of Disposal

     Information on disposal costs in New York was limited to recondi-
tioning of drums and disposing of unused pesticides.  The state will
transport, store and dispose of unused pesticides for $1.00/lb.  A
pollution service, the only one licensed by the state to dispose of
pesticides, charges 20£/lb for bulk material or $80/drum for separately
packaged units.  This disposal firm handles large quantities and would not
take small lots from individual users.

     One reconditioner in the state will pay $.75-$1.25 for a 30 gallon
drum and $1.00-$1.50 for a 55 gallon drum.  The other reconditioner does
it as a service, i.e., does not pay for the drums.   Both firms sell the
reconditioned drums for $7.00.

     8.  Environmental Effects

     We were unable to obtain any documentation of incidents caused by
disposal of pesticides or containers in the State of New York.
State personnel contacted knew of no record keeping or systematic
documentation of any  incidents on a statewide basis.
                                  122

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                         V.  ECONOMIC ANALYSIS
A.   FRAMEWORK OF ANALYSIS

     In order to provide a convenient framework for the economic analysis
of alternative disposal systems, a general three-level system, shown in
Figure 6, can be defined.

     The first or source level includes those places, persons and activities
which provide or generate used pesticide containers (or excess unused
pesticides).   Farmers and commercial applicators are part of the source
level.

     The second level includes the places, persons and activities associ-
ated with intermediate handling or storage of the used containers after
they leave the source and before they reach the ultimate disposal site.
Holding areas and distributors who take back containers from their
customers are part of this level.

     The third level encompasses the final disposal of the used container
or unused pesticide, whether by landfill, incineration or recycle.
Containers are transported between these levels, and the possible modes
of transport must be defined and analyzed.

     Several variations of this general system need to be considered.
Most important is the case of on-site disposal, where containers or
unused pesticides are disposed of at the source, e.g., at the farm.
This system is widely practiced currently, and forms the "base case"
against which other alternative systems can be compared.

     The second principal variation covers cases where the containers
or unused pesticides move directly from the source (farm) to the final
disposal site, without passing through an intermediate handling stage.
As will be shown, this kind of system is economically attractive only if
the final disposal site can be located quite close to the sources.

     In the following sections, the economics of alternative actions at
each of the three levels are analyzed.  Finally, the economics of these
parts are assembled into complete systems, and the economic characteristics
of each are shown.

     The economic characteristics of a complete disposal system depend
on the balance between:

     •    The cost of the disposal or handling operation, and how that
          cost changes with scale of operation;

     •    The cost of transporting the containers from one level to
          another within the system.
                                  123

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                                     inal Disposal





                                \_J Intermediate Handling
Figure 6.  General Three-Level Disposal System





                      124

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     The balance between these costs varies for different systems.  The
most economical configuration for a system varies significantly between
systems.  One system may be most economical if disposal takes place at
each source site, with no transportation involved.  Another system may
be most economical if all containers from a multi-state region are
transported to one final disposal site.  In our analysis, we attempted to
identify the most economical configuration of each system considered,
so that alternative systems can be compared on the basis of the best
that each has to offer.

     The economic analysis which follows is based on weight of material
handled, and costs are expressed on a unit basis for ease of comparison.
To convert numbers of containers to weight, the values shown in Table 40.
were used.

                      Table 40.   Container Weights
                  Size                       Weight (Ib)

               55 gallon                        60
               30 gallon                        46
                5 gallon                         5
                1 gallon                         2.4
              1/2 gallon                         1.8
                1 quart                          1.3


     In computing weights, no distinction is made between metal^ glass or
plastic containers in the smaller sizes.  Material
considered in describing disposal technology.

     The estimated costs given in the following sections include costs of
equipment, labor, raw materials and utilities where appropriate, and in
some cases land.  While these costs differ from place to place and from
time to time, the general nature of the analysis precludes taking these
detailed differences into account.  We judge that our disposal cost estimates
are generally accurate to within +40 percent and -20 percent (i.e., the
actual cost is not likely to be more than 40 percent greater than our
estimate nor less than 20 percent lower).  In most cases we nave shown
the specific cost estimates for a disposal process in sufficient detail
to allow direct determination of the effect of changing one or more item
costs on the total cost.  The most uncertain elements of the cost factors
are indicated, and ranges of disposal costs are provided in several
examples.  In some examples, the sensitivity of the results to variation
in cost factors is also described.  Average or "best value" costs are
then used in a "systems" analysis which integrates collection and trans-
portation costs with disposal costs for various scales of operation.

B.   ON-SITE DISPOSAL

     1.  Open Dumping

     In open dumping, pesticide containers or unused pesticides are
combined with other types of solid refuse, generated at the source, in

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an open area on the user's site.  Since the area will exist whether or
not pesticide materials are dumped there, the cost of disposing of
pesticide materials in an open on-site dump is nil.

     2.  Controlled Burial

     Controlled burial is characterized by burial of the pesticide under
two feet of earth in a fenced-in area.  The principal costs are associated
with digging the hole and subsequent backfilling.  The area need not be
large and the cost of the fence, amortized over the useful life of the
area is negligible.

     To bury 10 five-gallon containers in a hole three-feet deep would
require excavation of about one cubic yard of material.  The cost of this
excavation is estimated to be $4.50, assuming 1.5 man hours at $3/hr.
Backfilling would add another $1 to the cost.  This work could be done
much more quickly by machine, but the costs would not likely be lower when
the setup time of the machine is considered.

     Based on these estimates, the cost of controlled burial would be

                550
                50
                        llC/lb or 55
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     The size of the holding area actually built will depend, of course,
on the size of the area that it serves, how often it is open and how
frequently the stored containers are removed to the disposal site.  Minimum
capacity is one large truckload (60 cubic yards, which could handle 2000
five-gallon containers which weigh 10,000 Ibs) . Unit costs are essentially
independent of size.  The cost of operating such an area is essentially
equal to the amortized capital cost of the facility.  No  utilities are
required, and the only labor needed is to open and close the facility at
the appropriate times.

     The capital cost of a 300 sq yd area is estimated to be $32,000,
based on concrete at $2/sq ft and roofing at $10/sq ft including labor.
If the capital is amortized over ten years, and the turnover time in the
area is three months, the unit cost of operating the holding area is:

             -  3,200,000
             '  (100,000) (4) (10)
     This cost will be relatively insensitive to the size of the holding
area since the capital costs are essentially proportional to size.  More
rapid turnover would allow more containers to be handled in a given
facility, so that cleaning out the area more than four times per year
would reduce the unit cost proportionately below 0.8c/lb.  An anticipated
range would be from about 0.7c/lb to 1.2c/lb depending upon construction
costs and turnover rates.

 D.   FINAL DISPOSAL

     In  estimating the  costs  of  the  alternative methods  of  disposal  of
 pesticide containers  and unused  pesticides,  an important question is,
 "at  what scale  of operation should the  costs be estimated?" Unit
 operating costs generally  decrease as the  amount of material handled
 increases, so that the  choice of scale  affects the estimated cost.

     For each process considered, we have  selected a  scale  of  operation
 which  is on  the low side of the  scale appropriate for the particular
 process.  Alternative processes  can  only be  compared  at  comparable scales
 of operation.   Later, each process will be scaled according to general
 engineering  rules, so that a  direct  comparison of systems costs can  be
 made.

     1.   Landfill

     Burial  of  pesticide containers  in  specially designated landfills
 is practiced in California, and  some cost  data are available.   As
 indicated in Section  IV-C,  a typical class  I landfill is open for two
 10-day periods  each year.   During these periods, it is manned  by three
 men  equipped with special  protective gear.   A bulldozer  is  used to crush
 and  cover the containers.
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     We will assume that containers brought to the landfill have been
properly rinsed by the user.  If the landfill is properly sited and
engineered to contain hazardous materials , unrinsed containers could be
landfilled directly with no danger.  On-site rinsing at the landfill
poses the problem of rinse-water disposal and could be expensive.
Rinsing might be accomplished in as little as one minute per can using a
specially designed rinsing sprayer, but this operation could add 10<: per
container (or 2£ per pound for a five-gallon container) to the costs
estimated below.  In addition, rinsing would complicate the intake
procedure.

     The estimated daily operating cost (of the California landfill) ,
assuming a labor rate with overhead of $6/hr and a bulldozer rental cost
of  $10/hr, is $224/operating day.  Depreciation of the capital cost of
the landfill amounts to $300/yr or $15/operating day.  The yearly intake
of  containers was estimated to be 15,000  cubic yards at a density of
167 Ib/cubic yard, or 1250 tons/year.  The unit cost is therefore

               ( 239") (201
         C  =    1250     =  $3-83/ton or 0.19c/lb or 0.95c/5-gallon container

     This cost is low relative to what might be encountered in other areas.
The low depreciation cost is due to inexpensive land ($100/acre)  and the
need for only minor site preparation.   In other locations,  higher costs
for these factors could increase the amortization cost by a factor of ten
to  $3000 /yr or $150/operating day.

     In addition, adequate cover material was available at  the California
site.   As much as 200 cubic yards of cover material could be required
per day, depending on the topography of the landfill, to cover the 750
cubic yard daily intake of containers to a depth of two feet.   Acquisition
of  this fill from another site could add another $200-$300 to the daily
cost.   Under these circumstances, the unit landfill cost ranges from
                         =  $9-20/ton or 0.46c/lb or 2.3c/5-gallon container

to

                         =  $10.78/ton or 0.54
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     2.   Encapsulation and Burial

     Pesticide containers and some pesticides can be rendered less
susceptible to leaching in a landfill by encapsulation of the materials
in asphalt or concrete prior to burial.  The encapsulation process is
shown in Figure 7.   Containers are first crushed and then mixed with
asphalt in a steam-heated vessel.  The mixture is put in 55-gallon drums
which are covered and buried.

     For a process disposing of 2000 Ib of material per day in a mixture
containing four volumes of asphalt to one volume of material, the costs
are estimated as follows.

     Installed capital cost  $32,000

     Operating Cost                                         $/day

          Raw materials—asphalt 1000 Ib @ lc/lb             10
                       —drums 2 @ $5                        10
          Steam 10,000 Ib @ $2/1000 Ib                       20
          Labor - 8 man-hr @ $6/hr                           48
          Overhead                     ^                     24
          Depreciation, Maint. and Ins.                      36
                                                           $148

          Burial:

               Excavation 2 CY @ $5/CY                       10
               Backfill and Cover                            __5
                                                             15

                                               TOTAL COST  $163/day

*
     Depreciation, maintenance and insurance are taken to be 20%, 5%
     and 2%, respectively of the installed capital cost.

     Unit cost C = 25'o'b  = 8.2c/lb (or 41<:/5-gallon container) at a
capacity of 480,000 Ib/yr.

     Concrete could be used as the encapsulating material with no
appreciable change in cost.

     The greatest uncertainty is in the labor effort and rate and the
capital costs of the operation.  As indicated earlier, we believe our
estimates to be accurate to within -20% to +40%.  Thus the unit cost of
encapsulation and burial of the 5-gallon container should be in the
range of 33
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               Crushed
Containers
Asphalt
                                 Vessel
                                                        Steam
                                                                Burial
                  Figure 7.   Encapsulation Process
                                   130

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     3.   Incineratioii

     Metal containers can be decontaminated by exposing the shredded
containers to high temperatures (around 2000°F) in an incinerator.  The
stack gases must be scrubbed to remove potential pollutants arising from
the combustion of the residual pesticide.  Figure 8 shows a diagram
of the system.  The estimated costs for a system designed to process
700 five-gallon containers per hour, or 28,000 Ib of containers/day are,
as follows.

     Capital Cost  $300,000

     Operating Cost

          Fuel—35 MM Btu/day at $1.50/MM Btu
          Labor - 16 man-hrs @ $6/hr
          Overhead
          Depreciation, Maintenance and Insurance         	
                                                          ~$534/day

     Unit cost = oQ"*V.r>r> = 1.9
-------
Shredder


	
r
Fuel
Oil
»
Furnace



LAir
                                              Water
                                                4-
                                          Scrubber
                                                      Gases vented
                                                    •>   to the
                                                       Atmosphere
                                Metal to
                            Scrap or Landfill
                                               \o waste
                                                treatment
        Figure 8.  Incinerator for Pesticide Containers
                                           Lime Water
                                    Water
Pesticide
Air
            Kiln
 Spray
Chamber
Scrubber

>,
•
                                                               1
                                                              Stack
                            to treatment
                            facility
                   ^
              to filter
              and sewer
X
    Figure 9.  Incinerator for Unused Pesticides
                                 132

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     Unit costs of incinerating pesticides are much higher than those
for pesticide containers since there is more combustible matter per pound
fed.  Hence a larger furnace and scrubber are required.  If an "empty"
5-gallon container weighing 5 Ib contains 4 oz of residual pesticide,
only one- twentieth of the weight fed must be burned in container
incineration, as opposed to total combustion when pesticides are
incinerated.

     4.   Reuse/Recycle

     a.   Reclamation of Large Containers for Reuse

     Economic data on reclamation of 55- and 30-gallon containers for
general reuse was given in Section IV-C.

     b.   Recycle of Small Containers

     Small metal containers can be recycled as scrap.  Figure 10 shows
a process in which the containers are shredded to expose maximum surface
area, and washed in a detergent or mild caustic solution.  The entire
system, shredder, storage hopper and washer are maintained under a slight
negative pressure to prevent leakage of fumes into the operating area.
The in-leakage of air is collected and scrubbed with a mild caustic
solution to remove traces of pesticide vapor before the air is exhausted
to the atmosphere.  The cost "of a system to process 4000 Ibs of containers
per day is estimated as follows.

     Capital Cost  $30,000

     Operating Cost

          Hot water 5000 gal @ 50
-------
                       4-
                                                      Exhaust


Shredder

>
— ^ 1
Hop

«, J
per J

'
>
Wa
^
^
Scrubber
1
er to Sewer or
Treatment
r
Uaah^r- , , w Srrap to Sal e


                   to Sewer or
                   Treatment
Figure 10.  Scrapping of Small Metal Containers
                      134

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     The cost of delivery by the individual user depends on how far he
must take them (M miles), how much he takes at a time (N Ibs of containers
or pesticides) and how much his time is worth (L $/hr).  Assuming that the
out-of-pocket cost of vehicle operation is IOC/mile and that an average
speed of 30 miles per hour can be maintained, the cost per pound delivered
is:

               c = to.10 + 35-] f1 ($/ib)

If

               L = $2/hr
               M = 10 miles
               W = 50 Ib (10 five-gallon containers)
               C = 6.70/lb or 33.5<:/5-gallon container.

     The cost is high and perhaps unrealistic.  Lower labor costs,
shorter distances and larger loads reduce the cost.  Also, for example,
if the holding area is on the way to a location that the user normally
visits, the cost of the trip attributable to delivery of the containers
may be nothing.  In summary, then, the cost of user delivery can range
from nothing to around 7£/lb, (for a ten-mile trip)  depending on the
circumstances.   This  uncertainty will be important in assessing the overall
costs of disposal systems,  since the costs of operation per pound at other
system levels can be  considerably less than 7C/lb.

    An alternative to individual user delivery is organized periodic
collection of containers from a number of sources.  This collection service
could be contracted to a local trucker as required.  The time required
per pound of material collected depends on the distance between stops
(M miles), the weight of material collected at each stop (W Ib/stop) and
the time spent in talking to the user, locating the material and loading
it onto the truck (t hours/stop).  Assuming an average over-the-road
speed of 30 mph, the time per pound is:


               (3o + y I (hrs/lb>

The cost of truck and driver is estimated as follows:

     Capital cost of truck $15,000
     Depreciation period 5 years
          at 1872 hrs/yr
     Operating and Maintenance Cost $1.50/hr
     Drivers wages                  $6.00/hr

Therefore, the hourly cost is:

     Depreciation                $1.60
     Operation and Maintenance    1.50
     Labor                        6.00
                                 $9.10/hr

                                  135

-------
and the unit cost of collection is:
                           M    t-
               c = (<

if

               M = 1 mile
               t = 10 minutes
               W = 50 Ib (10 five-gallon cans)
               C = 3.6<:/lb or 18<:,/5-gallon can.

This collection cost is significantly lower than the "upper limit" for
user delivery of 7£/lb computed earlier, and about equal to the user
delivery cost if the user's time is free.

     In addition, the collected load of 2000 Ib must be delivered to a
holding area or final disposal site.  If the site is M miles from where
the collection day ends, the transport cost is


               c = (910) (f > <25oo>
                 = 0.03M

If the holding area is 20 miles away, the transport cost of 0.6<:/lb must
be added to the collection cost of 3.6<:/lb.

     2.   Intermediate Level to Final Disposal

     When containers are collected at a holding area or distributor,
they can be transported to the final disposal site in large quantity in
a tractor-trailer rig with considerable saving in unit cost.  This cost
can be estimated using the equations developed for collection costs given
above.  For this application, the loading time will probably be insignificant
relative to the on-the-road time.  Taking the capital cost of the tractor-
trailer to be $40,000, the hourly depreciation cost based on 5-years
operation is $4.30/hour, and the total cost is:

     Depreciation                 $ 4.30
     Operation and Maintenance      2.40
     Labor                          6.00
                                  $12.70

     Using a density of uncrushed containers of 167 Ib/cubic yard, a
60-cubic yard trailer will carry 5 tons, or 10,000 Ib.  Therefore, the
unit cost of transport is

               C = (1280) (f£) (rfTTSG) (0/lb)
where M is the distance to the disposal site, and it is assumed that  the
cost of the return trip must be charged against container transport.
                                   136

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     If the distance from holding area to final disposal site is 100 miles,
the unit transport cost is about 0.9c/lb.

     The unit cost per unit distance (C/M), which will be useful in the
system analysis is 0.009<:/lb-mile.  Actual unit transport costs are
obtained by multiplying this value by the one-way distance to the
disposal site.

F.   SUMMARY OF SYSTEM COSTS

     1.   Economic Justification of Holding Areas

    In transporting the containers or pesticides to the ultimate disposal
site, the user (or collector) may take them directly to the final site
or he may take them to a holding area where they are stored and later
trans-shipped to the final disposal site  (see Figure 6).

     To compare these alternatives, we will assume that the final disposal
site is D miles away from the sources, on the average, and that a holding
area is H miles from the sources.  If the sources are uniformly distributed
around the holding area, the distance from holding area to disposal site
is also D miles.

     As shown earlier, the cost of direct transport to the disposal site
by the user ranges from nil to 0.67<:/lb-mile.  Taking the higher figure,
the per pound cost is

               (^ = 0.67 D (c/lb)

     The cost of using the holding area has several components; the
cost of user delivery to the holding area (0.67 H 
-------
     A similar analysis can be made in which user delivery is replaced by
 collection truck delivery.  Since the cost of delivery by collection
 truck is 0.03c/lb-mile, direct delivery to the disposal site is preferable
 if:

               D is less than 1.5 H + 40 miles.

 Because of the lower per mile cost of truck delivery, direct transport
 is more often attractive.  The table below shows the values derived from
 the basic inequality.

                 If H                Go direct to disposal
               Will Be      then       if D is  less than

                5 miles                     47.5 miles
               10                           55
               20                           70
               30                           85

For example,  holding areas  built  so  that  the  average user  was  20 miles
away (H = 20  miles)  would be economical  if the  disposal  site was more  than
70 miles  away (D = 70  miles)  from the average user.

     This analysis is based on the assumptions of uniform rates of generation
 of pesticide containers and no restriction on the location of the holding
 area.  In practice, areas would be sited  to reflect local container use
 patterns at available and convenient locations.

     In summary, conveniently located holding areas are economically
 justified in nearly all cases where the user delivers the pesticide
 containers or unused pesticide.  If source-to-source collection is
 provided as part of the disposal system,  there is less economic incentive
 for closely spaced holding areas.

     In the analysis of disposal alternatives that  follows, we will
 assume that holding areas are included as part of the disposal  system.
 Transport of containers and unused pesticides to the final disposal site
 will be by large truck.

     2.   Final Disposal Alternatives

     The economics of final disposal and  the economics of  transportation
 presented earlier can be combined to show the best  scale of operation
 for  each of the disposal alternatives.   The most economical system for
 each alternative can  then be compared.
                                  138

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    The unit cost of transporting material to a central site and processing
it there can be expressed as:


               C = CTD + Co (I-> n
                              o
                   Trans-  Processing
                   portation  Cost
                   Cost

where

     CT is the transport cost per pound-mile

     D is the one-way transport distance from holding area to disposal site

     C  is the unit processing cost (<:/lb) at the base capacity of L  (Ib/day)

     L is the actual capacity of the facility (Ib/day)

     n is an empirical exponent used to scale cost estimates from one
       capacity to another.

     While processing costs associated with different processes will
scale somewhat differently (i.e., have different values of the empirical
exponent n), the value of n for most processes lies in the range of
0.4 to 0.6.  We have chosen the value of 0.6 for this analysis, since
the processes we are dealing with tend to be labor intensive and there-
fore more strongly variable with capacity.  Recognizing the uncertainties
inherent in our knowledge of how many pesticide containers may be
generated in a specific area, more precise analysis is not warranted at
this time.  The value of n chosen, within the limits stated, will not
have an important effect on the nature of the results obtained.

     The basic  solution  considered  is  shown in Figure 11.  Pesticide
 containers  are assumed  uniformly distributed over  the  area.   These
 containers  are brought  to  the  final disposal site  in  large  trucks.   The
 capacity  of the  disposal  facility  (L)  is  related to the size  of  the
 area served by

               L  =  irR2p

 where

               p  is the  density of  container generation (Ib/sq mi-day)
                                 139

-------
                                            Area Served by Disposal
                                            Facility (Radius R)
Holding Areas
  Figure 11.   General Disposal System
               140

-------
     The average transport distance to the disposal site is (2/3) R.
The unit cost can then be expressed in terms of R, the radius of the
area served by the disposal facility, and p, the density of container
generation.
The other factors, C , C  and L  are parameters known from the cost
estimates made in preceding sections.

     For each disposal alternative considered, the cost (C) can be
calculated and arrayed as a function of R and p.  Figure 12 shows the
relationship for disposal by encapsulation and burial.  The unit cost
increases with decreasing density, since a larger area must be served to
accumulate a given amount of material.  For any given density, there is a
minimum unit cost at the radius at which the increase in transport cost
with increasing distance just balances the reduction in processing cost
with increasing capacity.

     For encapsulation and burial, costs range from as high as 25c/lb,
for small plants serving areas with low container density, to as low as
about 2
-------
                                                                         /-x
                                                                          co
                                                                          0)
                                                                         1
                                                                         T3
                                                                         
-------
    28
    26




    24




    22
-   20
a
    18
    16
a   14
c
ro
•8   12
    10
          60
         100
         200
Generation Density

10 Ib/sq—mile-year
                   100
                                    I
                             I
            200            300


           Radius of Area Served (Miles)
400
500
                     Figure  13.  Costs of  Container Incineration
                                         143

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   14
   12
   10
a
•a
ra   6

           20
           200
                   Generation Density
                   10 Ib/sq—mile—year
                                    I
                  I
                    100
 200            300
Radius of Area Served (Miles)
400
500
                      Figure 14.   Costs of Recycle  by Scrapping
                                            144

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     For both container incineration and recycle by scrapping, processing
costs can be at least partially offset by revenues from the sale of scrap.
A scrap price of $20 per ton (lc/lb) would reduce the net cost of the
optimally sized recycling process to about l
-------
                    Generation Density

                    10 Ib/sq—mile-year
R
C
re
I
V)

to
 -
O

tt

(3
                                         I
                     I
                      100
 200               300

Radius of Area Served (Miles)
400
                                                                                             500
                            Figure  15.   Costs  of Sanitary Landfill
                                                146

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and the revenue from sale of the drum is v.  Equating the cost and the
revenue and solving  forM yields

               M  = (v - P - r)
                o      0.004
If the transport distance from holding area to reconditioning facility is
less than M ,  the reconditioning is profitable.

     Taking the most conservative values for costs and revenue from the
data obtained in California yields

               M  . 6.00 -1.00 - 3.25 _ 44Q ^
                o         0.004
     Taking the most liberal cost and revenue values yields

               M  = (9.00 - 0.50 - 3.25)7(0.004) = 1310 miles

     It is likely that nearly every agricultural area is within 450 miles
of a private drum reconditioner, so that reconditioning appears to be a
generally valid and economical method for handling large used pesticide
containers.

     Drum reconditioners interviewed were generally skeptical of the
validity of reconditioning and reusing smaller pesticide containers
(5-gallon and smaller), except as they can be directly reused by the
pesticide formulator.  They believe that these containers are too fragile
for effective reconditioning and that the reconditioning cost would exceed
the value of new containers.  The price of new 5-gallon containers is
currently quoted at about $1400 per thousand ($1.40 each) FOB the factory.

     Those containers which are damaged in use and cannot be reconditioned
can be disposed of with the smaller containers.  Only a small fraction of
the large containers should fall into this category.

     3.   Some Specific Examples

     The general analysis described in the preceding section was based
on a uniform container generation density with each disposal facility
serving a circular area around it.  The equations on which the analysis
is based can also be used to estimate the costs of alternative systems
under more realistic conditions.

     These estimates are intended only to provide guidance as the range
of costs to be expected and the relative effects on those costs of disposal
technology and container generation density.  More detailed engineering
designs, taking into account the specific characteristics of the local
areas served,  would be required for more detailed cost estimates.
                                  147

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     Table 41 shows the number and estimated weight of containers
generated in the state of California in 1969 (Rogers and Cornelius,
1970).

                                Table 41

            Annual Container Generation in California (1969)

                                     Estimated Wt
                       No.        Per Container (Ib)     Total Wt  (Ib)
55- gallon
30- gallon
small metal
small glass and
plastic
Subtotal
Paper sacks
Other paper
8,000
98,000
346,000
172,000

624,000
3,239,000
8,000
60
46
5
1.8


0.5

480,000
4,508,000
1,730,000
310,000

7,028,000
1,620,000
	
     Total          3,871,000                              8,648,000

     The use of pesticides is concentrated in three principal areas in
California (see Figure 16) ;

     •    An area in Central California encompassing the San Joaquin Valley
          and about 430 miles by 100 miles in dimension (43,000 sq miles)

     •    An area southwest of Los Angeles measuring about 50 by 50 miles
          (2500 sq miles)

     •    The Imperial Valley in southern California, measuring about
          50 by 50 miles  (2500 sq miles)

     Taking first the incineration systems for containers and assuming
that only metal containers are processed, Table 41 shows an annual
generation rate of 6,718,000 Ibs per year.  If only the small metal
containers (5-gallon) are processed, the comparable figure is 1,730,000  Ib/year.

     Assuming a uniform generation rate in each of the three agricultural
areas, the generation density ranges from 36 to 140 Ib/sq mile-year.

     For each of these generation densities, the  system costs for incineration
were estimated for the following service areas:

     A - One incinerator  serving the San Joaquin  Valley
     B - Two incinerators serving the  San Joaquin Valley
                                    148

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San Francisco
                                                             N
                                                             t
                                                            50      100 Miles
                                 50 by 50 Miles
        Figure 16.  Principal Agricultural Areas  in California
                                         149

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     C - One incinerator each in the Los Angeles area and in the
         Imperial Valley
     D - One incinerator located in the Imperial Valley serving both the
         Imperial Valley and the Los Angeles area
     E - One incinerator in the San Joaquin Valley serving all three
         areas.

     Table 42 shows  the results.   At each density,  Alternative A is
preferable to B for the San Joaquin Valley and D is preferable to C for
the Los Angeles-Imperial Valley areas.  The cost for a state-wide system
combining Alternatives A and D is computed from the costs of each alternative
weighed by the number of containers generated in each area.  Alternative E
is less expensive than the combination of A and D.  Therefore, the best
incineration system for California is one incinerator in the San Joaquin
Valley serving all three agricultural areas.

     Similar systems of landfills were also considered.  Table  43  shows
the results.  Two landfills, each serving half of the San Joaquin Valley,
are less expensive than one landfill serving the whole area.  A combined
landfill for the Los Angeles area and Imperial Valley is less expensive
(or the same cost at the high density) than separate landfills for each.
On a state-wide basis, the best landfill  system combines Alternatives
B and D with two sites in the San Joaquin Valley and one serving both the
Los Angeles area and the Imperial Valley.

     For the Alternative landfill systems, the costs do not vary as much
from case to case as with the alternative incineration systems.

     In Mississippi, the annual generation of containers is somewhat
higher than in California, as shown in Table  44.

     The area of Mississippi is 47,358 sq miles and agriculture seems
to be spread  fairly uniformly across the state.  The total generation
rate is about 9,700,000 Ibs/year of all containers (1-gallon and larger
are considered);this translates into a density of 204 Ib/sq mile-year.
If the larger containers (55- and 30-gallon) are reconditioned for reuse,
only about 3,100,000 Ibs remain for disposal, and the generation density
is 65 Ib/sq-mile-year.

     Assuming a uniform generation density across the state, the only
question is how many processing facilities should be located in the state.
Using the equations described earlier, the costs of incineration and
sanitary landfill were calculated and are shown in Table  45.   One
incinerator is less expensive than two.  For landfills, the best number
is around three or four depending on generation density.
                                  150

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          Table 42.  Cost of Alternative Incinerator
                     Systems in California
a)  Density = 36 Ib/sq-mile-year
    Alternative

    A (one incinerator in
      San Joaquin Valley)

    B (two incinerators in San
      Joaquin Valley)

    C (one incinerator each in
      Imperial Valley and Los Angeles)

    D (one incinerator in
      Imperial Valley)

    E (one incinerator in San
      Joaquin Valley serving all areas)
Unit Cost
(0/lb)

  5.87
  7.69


 25.27


 17.72
Statewide System
Ave. Unit Cost
   (C/lb)
     7.12 (A and D combined)
                  5.75    (E only)
b)  Density - 140 Ib/sq-mile-year

    A (one incinerator in San
      Joaquin Valley)

    B (two incinerators in San
      Joaquin Valley)

    C (one incinerator each in
      Imperial Valley and Los Angeles)

    D (one incinerator in
      Imperial Valley)

    E (one incinerator in San
      Joaquin Valley serving all areas)
  3.25
  3.74
 11.57
  8.19
                  3.76  (A and D combined)
                  3.30 (E only)
                                    151

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      Table 43.  Costs of Alternative Landfill Systems in California
a)  Density  =  36 Ib/sq-mile-year
    Alternative

    A - one landfill in San Joaquin
        Valley

    B - two landfills in San Joaquin
        Valley

    C - one landfill in each of Los
        Angeles and Imperial Valley

    D - one combined landfill for
        Los Angeles and Imperial
        Valley

    E - one landfill in San Joaquin
        Valley serving all areas
Unit Cost
(C/lb)

  1.70
  1.40
  3.02
  2.56
Statewide System
Ave. Unit Cost
     (C/lb)
              1.52   (combination of
                    B and D)
               1.85  (E only)
b)  Density = 140 Ib/sq-mile-year

    A - one landfill in San Joaquin
        Valley

    B - two landfills in San Joaquin
        Valley

    C - one landfill in each of Los
        Angeles and Imperial Valley

    D - one combined landfill for Los
        Angeles and Imperial Valley

    E - one landfill in San Joaquin
        Valley serving all areas
  1.41
   .95
  1.48
  1.48
1.01 (combination of
     B and C or B and D)
               1.57   (E only)
                                  152

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            Table 44.   Annual Container Generation in
                       Mississippi (1974)

                                Estimated         Total
      Size        Number       Weight  (Ib)     Weight  (Ib)

     55-gal        90,875          60           5,452,500
     30-gal        24,050          46           1,106,300
      5-gal       334,125           5           1,670,625
      1-gal       620,250           2.4         1,488,600
    1/2-gal        56,200           1.8           101,160
    1/4-gal       124,500           1.3           161.850
                 1,250,000                       9,981,035
                Table 45.  Disposal Costs  in Mississippi
     A)   Incineration

          Generation            Unit Cost of Transport & Disposal ($/lb)
           Density
          (Ib/sq mi-yr)             One Incinerator   Two Incinerators

               65                       A.14              5.20
              204                       2.64              2.89

     B)   Landfill              Unit Cost of Transport & Disposal (
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     Two basic deposit systems are considered.   In the first, containers
go from distributor/dealer to user to a disposal facility.  In the second,
containers are followed from the formulator to the distributor/dealer to
the user and then back through the same chain with the formulator reus-
ing the container.

     1.  The Distributor/Dealer-User-Disposal System

     Figure 17 shows the flow of containers and money in the distributor/
dealer-user-disposal system.

     The user purchases pesticide from the distributor/dealer and pays
a deposit (D).  Used containers, less some that are lost, are taken to
the disposal facility and the user receives a refund (D) for each container.
Deposit revenues collected by the distributor are turned over to the
agency which operates the disposal facility, which in turn reimburses the
disposal facility.  The operating agency must be part of this circuit
in order to coordinate the receipt of funds from several distributors/
dealers and the possible disbursement of funds to several disposal
facilities.

     The basis for the economic analysis is taken to be one container
going from distributor/dealer to user.  If the fraction of the used containers
lost by the user  is a, the number of  containers he delivers  to the disposal
facility is  (1 -  a).

     The net  cost to  each participant of handling the containers  under  the
deposit system can be  added  up.  The net cost  to the distributor/dealer  is:
      Income:
      Outgo:


      Net  Cost:

 For the user:

      Income:

      Outgo:
    D  Deposit received from user
    D  Deposit passed on to operating agency
  + A, Administrative cost
  (l-a)D   Deposit refund from disposal facility
       D   Deposit paid to distributor/dealer
+ (l-a)C   Cost of transporting containers to the disposal

+ (l-a)F
                          facility
                          Disposal fee paid  to  the  disposal  facility.
      Net Loss:   aD + (l-ct)Ct + (l-a)F.
                                   154

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 Operating
  Agency
Distributor/
  Dealer
                                                         Flow of
                                                        'Containers
Flow of
 Money
                                                  ..ost
                                                   Containers
  Figure 17.  The Distributor-User-Disposal  System
                         155

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     The foregoing costs include a disposal fee charged to the user to
cover the cost of disposal.   Alternatively, that cost would be borne by
the operating agency.  The user has an economic incentive to deliver the
container to the disposal facility if the deposit is greater than the cost
to him of the delivery, i.e., if D is greater than C  + F,.
For the operating agency:
     Income:

     Outgo:
                       D

                  (l-a)D


                     +A
Deposit passed on from the distributor/dealer

Deposit revenue paid to the disposal facility
to cover their reimbursement of the user.

Administrative cost at agency and disposal
facility under its control
                A  - otD.
                 a
     Net Cost:

For the disposal facility;

     Income:
     Outgo:
     Net Cost:
   (l-o)D
1- (l-a)Fd

  d-a)Fd

 + (l-a)D

 nil
Deposit revenue from operating agency
Disposal fee from the user.

Cost of operating the facility.

Deposit paid to the user
     The total cost of the system is the sum of the net costs to each of
the participants;

            A,   Distributor/dealer administrative cost
             d

          + A    Operating agencies' administrative cost
             Si

     + (l-a)C    User's delivery cost

     + (l-a)F,   Disposal fee paid by users.

     The amount of the deposit does not influence the net cost of the
total system.  It does, however, affect the transfer of money among the
participants, as is shown by the net costs to each.  Under the system
described, the operating agency gains from a higher deposit and the user
loses.  The only economic constraint on the amount of the deposit is that
it must be larger than the combined cost to the user of delivering the
container to the disposal facility and paying the disposal fee.
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     This system requires recordkeeping by the distributor/dealer, in order that
his deposit payments to the operating agency fairly reflect his income
from users, and by the disposal facility, in order that it be properly
reimbursed from the operating agency for payments made to users.  Records
must be kept at both levels since payments are made solely on the basis of
records rather than on direct delivery of the material as occurs in  the
user-distributor/dealer and user-disposal facility interactions.

     In order to illustrate the transfer of money occasioned by the  deposit
system, the following values for costs and f rational container losses are
assumed:

      a =0.10  xhe user loses 10 percent of the containers he purchases
     A  = 1C
      a

     C  = 15c  This cost is quite variable, as was discussed earlier.
               This value is representative for 5-gallon containers.

     F, = 15c  Again, this value is variable, depending on the mode of
               disposal used.

      D = 40c  Chosen to be greater than C  and F,.

Based on these values, the costs to each of the participants are:

Pis tribute ^Dealer  -  lc

User

      (0.1)  (40)  lost containers
     +(0.90) (15)  transport to facility
     +(0.90) (15)  disposal charge
           31C

Operating Agency

               l£  administrative cost
     -(0.10) (40)  gain on deposit transfer
           -3C     the agency makes 3
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     In this system the deposit must be greater than 30c (the sum  of the
transport and disposal cost) to provide the desired economic incentive to
the user.

     The required level of the deposit is changed if the cost of disposal
is funded by the operating  agency rather than charged directly to the
user.  Under this condition, the net cost to each participant is:

                             General        With Assumed Values

     Distributor/Dealer    A,                      l.OC
     	     (j

     User                  aD4-(l-a)Ct             17.5
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     2.   The Formulator-Distributor/Dealer-User System

     A deposit system in which used containers are passed back to the
formulator for reuse is shown in Figure 18.  While this system involves
carrying the deposit back through the formulator level, the bookkeeping
might be simpler than in the system described in the previous section.
Here the money flow is always parallel to the flow of containers so that
immediate payment can be made on delivery.  Detailed records would not
be required.

     An economic analysis of this system yields essentially the same
substantive results as that of the previous system.  They are:

     •    The amount of the deposit does not influence the cost of the
          system, except as it encourages extraneous containers to enter
          the system at the user level.

     •    The amount of the deposit does influence the transfer of payments
          among the participants.  The user loses an amount equal to the
          deposit for each container that he does not return, and the
          formulator gains that amount.

     •    In order to provide an economic incentive to the user, the
          deposit must exceed the net cost of returning the container to
          the holding area.  This net cost is the sum of the transport
          cost and the handling fee, if any; or the difference between
          the transport cost and the price of the user is paid for the
          container, if any.
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                                                 Flow of Containers

                                                 Flow of Money
                       Holding
                        Area
                     Distributor/
                       Dealer
Losses
Figure 18.  The Formulator-Distributor-User  System
                        160

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    VI.  ENVIRONMENTAL EFFECTS OF THE DISPOSAL OF PESTICIDE CONTAINERS
                         AND UNUSED PESTICIDES
     The discussion of environmental effects is divided into two parts:
first, a discussion of the status of the problem as seen from a number of
viewpoints including examples of actual environmental effects of the
disposal of containers and unused pesticides in various states; second,
a discussion of the potential effects of the principal disposal methods,
both existing and proposed.


A.   INCIDENCE OF ENVIRONMENTAL DAMAGE

     The actual amount of damage caused by disposal of containers and
unused pesticides is a matter of wide disagreement.  One of the reasons
for this disagreement is the lack of recordkeeping on the part of states.
Although most states keep track of accidents, fishkills and other environ-
mental effects of pesticides in general, often this information is not
broken down as to whether the accident was caused by use of the pesticide
or by the disposal of the pesticide.

     We surveyed briefly the environmental (or agricultural) agencies
in 6 states other than those used in field studies for environmental
or human accidents related to container and pesticide  disposal.  Our
search yielded reports of very few accidents, posisbly due to the lack of such
incidents or the lack of recordkeeping in many states.  The results of
our survey combined with review of the literature for similar incidents
are given below.*

     In Maine, reported problems related to disposal of containers have been
limited to fishkills, averaging about 2 or 3 per year. The incidence of fishkills
is sporatic; in 1974, there were none, and in 1973, there were about
5.  Wardens of the Fish and Game Department  (authorized to act as enforcers
of the regulations) issued 20 to 30 warnings for infractions in 1974.

     In Virginia, a container was disposed of near a building with an
air vent.  The container had only been partially cleaned, and  the pesticide
material volatilized and was sucked into the vent, poisoning some farm
animals inside the buiULng.

     In Florida, a citrus  grower disposed of bags in a nearby  lake,
contaminating the water, and causing the death of several aquatic organisms
 (species or types not immediately available).

  Since many of these incidents were related  from memory by state agency
  personnel, very few details are available.  Documentation for these
  incidents, although existing,  was not immediately available.
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     In Tennessee, a chemical company buried one hundred 55-gallon drums
of chlorinated hydrocarbons in shallow, unlined trenches.  The pesticides
escaped from the containers to contaminate the local ground water supply
and a nearby creek (Buder,  1970).

     In Minnesota, lead arsenite was found to have contaminated a well,
causing a farmer to be taken to the hospital with arsenic poisoning.
The lead arsenite had been buried 1000 yards from the well 30 years
ago (Trask, 1973).

     In Maine, a barn burned down and a pesticide container, with sodium
arsenite left in it, was left unsecured.  It eventually tipped over and
the contents flowed into a low area and mixed with water which cows later
drank.  Two or three of the cows died.

B.   POTENTIAL ENVIRONMENTAL EFFECTS OF DISPOSAL SYSTEMS

     The environmental effects of disposing of pesticides and containers
depends on the particular hazards of the chemicals involved (toxicity,
persistence, solubility, volatility of both the active ingredient and
formulation) and the particular susceptibility of the areas in which they
are disposed (proximity to surface and ground water systems, human
and wildlife accessibility).  The wide range of potential severity of
environmental effects should be kept in mind when considering the various
impacts which could occur.

     1.  On-Site Disposal

     a.  Open Dumping of Containers

     Open dumping is the most hazardous of all pesticide container
disposal methods, and is probably the one that is most commonly used throughout
the United States.  Open dumping involves discarding containers either
in a centralized location on the farm  or wherever they happen to be
used.  Potential environmental hazards of this method of disposal  range
from sublethal effects to humans to secondary food chain effects.
Briefly, the potential environmental hazards include the following:

      (1)   Humans—The potentially most hazardous aspect of open
     dumping is the exposure of humans, especially children, to
     pesticide residues in the container.  Since it is likely that
     persons disposing in this way may also fail to triple rinse  the
     containers, pesticides are normally left in the container. Pesticides
     could come in contact with umans  in the following ways:

     •  Children  could be exposed while playing near discarded
        pesticide containers,

     •  Containers could be retrieved  from the discarded area and
        put  to use by  the farmer's  family or other workers.
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•  Disposing of other pesticide containers, farmers could come in
   contact with spilled material from previously discarded
   containers.

Even if such exposure does not result in acute effects such as
sickness  or death, less noticeable chronic effects may occur
especially when the container has been retrieved from an open
dump area and put to use on the farm in some way.  It is interesting
to note that one survey on disposal methods (discussed in Section
III) indicates that 10-20% of the containers are "washed and reused."

(2)  Farm animals—Farm animals are also susceptible to poisoning
from containers which have been discarded around the farm.  Rain
water may collect around the discarded pesticide containers, and
be contaminated by the pesticide residues.  Also, water may collect
in or on some of the leftover containers themselves.  Horses,
cows, and other farm animals may drink this water and receive a
relatively concentrated dose of the pesticide.

(3)  Surface Ground Water Systems—Surface waters may be contaminated
when containers are disposed of in surface waters, or near stream
banks or other areas which drain into surface waters.  Fishkills
caused by this contamination are usually very localized and easily
traced to the containers nearby.  Downward movement, as well as
lateral movement, may also be a problem.  Percolation of rain
water through the soil may lead to leaching of pesticide material
into ground water systems.  Although not causing the dramatic
effects seen with lateral movement into surface water systems, the
cumulative contamination of ground water from pesticide containers
as well as other pesticide sources may be the more serious of the
effects.

(4)  Soil—The seepage of pesticide into the soil may also cause
a localized effect on the soil ecosystem.  Microbial populations
are the most dramatically effected of the soil organisms.  Pesticides
vary widely in their toxicity to various soil microorganisms.
Particular chemical structures may be harmful to fungi, while others
are only harmful to bacteria and/or actinomycetes.  By disposing of
several different pesticides in one area, a microorganism which is
potentially able to degrade one pesticide might be eliminated by
the presence of another pesticide.  Also, decreasing the number of
species of microorganisms decreases the competition among the
numerous types, leading to instability in the soil ecosystem, and
possibly leading to the predominance of a relatively few species.
Although this in itself is not harmful, the species which become
predominant may be harmful to other soil organisms or nearby plants.
Plant pathogens may be able to survive applications of pesticides
and increase rapidly due to the elimination of competitive species
(Edwards, 1973).
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     A more widespread effect or: the soil ecosystem may be caused by
     the elimination of some ;  .nefical soil invertebrates (e.g.,
     earthworms, enchytraeiJ worms, and some Acarina) which have been
     shown to be susceptible to pesticides, especially chlorinated hydro-
     carbons.  These organisms are necessary to the soil ecosystem since
     they contribute to soil fertility by ingesting and breaking down
     the organic detritus contained in the soil and distributing the
     nutrients throughout a large area (Edwards,  1973).

     (5)  Food Chain—The open dumping of pesticide containers can also
     cause food chain effects.  Earthworms and soil mollusks have been
     shown to accumulate pesticides and may be a hazard to predaceous
     birds and mammals.  Birds and mammals, especially rodents, also
     directly incorporate the pesticide residues from contact with the
     disposal area itself or from contaminated water bodies, and pass
     these residues on to higher trophic levels.

     b.  "Controlled" On-The-Farm Burial of Pesticide Containers

     "Controlled" burial is burial by the farmer in a specified area of
the farm by approval or permit of some state or county official.   Environ-
mental effects of such a system would depend greatly on the requirements
for approval:

     •  It is likely that surface water contamination would be
        decreased by this method since inspectors could check for
        proximity to streams and other water bodies and the
        possibility of direct lateral movement of leachate to
        surface waters.

     •  The amount of ground water contamination which could be
        controlled by this method would depend on specific site
        characteristics and the requirements of inspectors.  Where
        the water table is high, controlled burial probably cannot
        eliminate contamination of ground water by downward movement
        of the pesticide.  If some kind of liner is required, e.g.,
        polyethylene sheeting, this could be controlled to some degree.

     The potential for human contact and contact with farm animals would
be reduced by this method as compared to open dumping, since at a minimum,
the containers would be required to be covered and fenced in.  Soil
effects would be decreased by  use of a liner.

     c.  Open Burning of Bags

     Because of low temperatures (compared to incineration), and variable
oxygen supplies,  it is likely that the pesticide residues in the bags
in an open field will not be completely burned.  As such, there will be
uncombusted and intermediate compounds given off as vapors.  Some of
these compounds might include long chain hydrocarbons, phosgenes, -and
other chlorine compounds, nitrogenous compounds, and others.  The
                                   164

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particular mixture and quantity of compounds given off is extremely
variable because oxygen supply and temperature are not constant through-
out the uncontrolled open field burn.  For example, on the outside of
a container in which bags are burned, there may be sufficient oxygen but
the air currents may cool the fire.  On the inside, temperature may be
high but oxygen may not be sufficient.  The end result would be a mixture
of vapors representing the various stages of thermal degradation of the
pesticide involved.  Additionally, vapors of the undecomposed pesticide
itself would likely be given off, as well as fumes of. hydrochloric acid,
sulfuric acid, and other compounds representing a more complete combustion
of the pesticide.

     The release of these vapors is a potential hazard to people and
wildlife downwind of the open field burn.  It is likely, however, that
the vapors would disperse rapidly enough as to eliminate a hazard to
potentially unsuspecting persons or wildlife outside of the immediate
area.  As a general rule of thumb, it can be estimated that there is a
20-fold dilution in vapors for every 10 'source diameters' away from the
burn.  This assumes that there is relatively little wind; additional
wind velocities would increase dispersion rates.  Since some of the vapors
mentioned above are toxic at the low ppm range, it is important that the
location where bags are burned is chosen so that there will be no known
exposure to persons or wildlife for several hundred feet downwind.

     Bags containing weed killers, such as 2,4-D, may be burned in the field
However, any remaining chemicals volatilize easily and may cause harm to
nearby crops, shrubbery, or other plants, it is important to choose the
location carefully to minimize adverse effects.  Also, those pesticides
containing chlorates may be explosive.

     Another environmental hazard from burning of bags in the field may
result from the unburned pesticide and residues of intermediate compounds
being concentrated in the soil directly underneath.  The particular
mixture and quantity of compounds in the residue would again depend on the
completeness of combustion.  Care should be taken to burn bags and containers
in areas which are not frequented by farm animals, children or wildlife.
Any ashes and residues, furthermore, should be spread out or covered with
clean soil.  It is also advisable to avoid low areas where water might
accumulate and result in high concentrations of soluble toxic materials.

     The environmental hazard of both vapors in the air and residues
in the soil would be decreased if the combustion were more complete,
A 'crib* could be constructed of inexpensive material such as available
rocks or planks of wood, which would enclose the burn on three sides,
allowing an updraft of air and maintaining higher temperatures.  Many
farmers burn bags in open wire "incinerators."

     The above discussion deals primarily with small numbers of bags burned
by individual farmers.  Burning of large numbers in the field, such as
might be done by commercial applicators, should be conducted only in
the presence of, or after the approval of, public health officials.
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     d.  Rinsing

     Although not a method of disposal, rinsing of pesticide containers
deserves attention because of the environmental effects of the disposal
of pesticides in the contaminated rinse water.   Depending on the quantity
of rinse water used, the concentration of pesticides in the rinse water
may not be significantly greater than the normal concentrations for
application.  Small quantities of this rinse water disposed in agricultural
fields therefore may not be significantly more harmful than pesticide
application.

     Commercial applicators, however, may release large amounts of con-
taminated rinse water into which drains eventually connect to secondary
treatment systems.  The bacteria in these systems may be exposed to a
wide variety of pesticides.

     The most likely reaction of most of these bacteria would be to be-
come sluggish and temporarily unable to digest as much organic matter as
normal.  The cause for this sluggishness may be a decrease in the variety
or numbers of the bacteria, or a temporary toxic effect of the pesticide
on the individual bacteria themselves.  The addition of the relatively
small amount of diluted rinse water containing pesticides, however, would
not significantly change the overall effectiveness of the treatment
facility.

     The bacteria, however, probably would not be able to decompose a
significant portion of the pesticide unless there were particular strains
of bacteria that preferred pesticides  as an energy or nutrient source.
In general, bacteria would probably prefer nutrients from other wastes
which  are more easily degraded.  It is possible that a strain of bacteria
could  be added to the secondary  treatment system which was known to easily
degrade a number of pesticide chemicals.

      In areas  of  heavy pesticide use,  it may be necessary  to  pass  the
effluent  through  a  carbon  filter to  avoid contamination  of  the  receiving
waters by significant amounts of pesticide  compounds.  The  effect  on
receiving water bodies will vary considerably  with  the compounds involved.
Chlorinated hydrocarbon  insecticides may cause significant  harm to popula-
tions  of  lower aquatic organisms whose LCsf. is often  less  than  .01 ppm.
Effluent  containing chlorinated  hydrocarbon insecticides may  also be
potentially damaging to  fish populations.

      2.   Intermediate Disposal

      The  effects  of holding areas will probably be minimal  if the  follow-
ing  three conditions are met:

      »  The containers are  closed and  stacked  properly so  that no
         pesticides  can drain;

      •  Bags are  placed  in drums or  other closed  containers with
         lids;


                                   166

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     •  The holding area is enclosed and locked so that children and
        wildlife cannot reach the containers.

     Preferably, the holding area would be on a paved surface to eliminate
the possibility of rodents burrowing into the area.  The normal precautions
should be taken by persons transporting the containers into and out of
the holding areas and persons handling the containers within the holding
areas to prevent exposure to pesticide residues on the outside of the
containers, etc.

     3.  Final Disposal

     a.  Effective Sanitary Landfill

     The environmental advantage of using a landfill is the fact that the
containers are placed away from contact with wildlife or humans.  The
potential environmental problems include the potential for ground water
pollution, surface water pollution, and possible occupational hazards
resulting from onsight handling.

     The ground and surface water problems can be significantly reduced
if thorough investigations of the geology and ground water hydrology of
the site are made before the site is designated for disposal of containers
(or pesticides).  Some of the factors which should be considered are:
1) the hydraulic gradient and the distance between the waste site and
any nearby aquifers, 2) the location of the water table, and 3) the
sorption characteristics and permeability of the soils beneath the
sanitary landfill.  Attention should also be given to the amount of
rainwater which is allowed to percolate to the sanitary landfill, since
a pesticide-contaminated leachate can be produced if percolating water
is present in sufficient amount.  This leachate could transport the pesticide
material downward until it reaches an impervious layer or a zone of
saturation, then moving laterally in the general direction of ground
water movement.  This downward and lateral movement could be significantly
lessened if the sites chosen were checked for favorable hydro-
geologic conditions prior to the disposal of the pesticide containers
(Miller, 1972).

     b.  Encapsulation of Pesticide Containers

     Bags, small metal containers, and other small containers could be
placed in 50-gallon drums and buried.  The effect is to delay the
entrance of the pesticide material in the containers into the soil system
until the drums have rusted.  This may allow for some chemical decomposi-
tion of the pesticides in the containers during this time, but other
than that the effects will be the same as simple burial of the containers.
More sophisticated encapsulation would involve placing the containers
in sealed material such as asphalt.   This has been suggested for the
disposal of surplus pesticides.  Although this would prevent the small
amounts of pesticide material in the containers from being released to
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the soil, the costs may be prohibitive.

     c.  Incineration of Pesticide Containers

     Incineration at temperatures near 1000°C can result in complete
incineration of a wide variety of chlorinated hydrocarbons, organophosphates,
carbonates, and phenoxy acid herbicides.  Because of the reliability and
completeness of this degradation, incineration may be the safest method
for the disposal of residues in pesticide containers.  At high enough
temperatures, and with adequate oxygen, most pesticides break down to
form SO-, P2°s' HC^ ' N<"X" anc* ot^er 8ases which must be eliminated by
scrubbing.  The only 'secondary' problem involved is assuring the safe
disposal of the waste from the gas scrubbing system, and the relatively
inert tars and other residues.

     d.  Reuse/Recycling

     Reuse and recycling of pesticide containers involves the collection,
cleaning, and use of pesticide containers for other purposes.  Hot
caustic soda is usually used to clean the containers for their reuse.
Although it has been shown that this washing effectively removes the
pesticide material from the container, it leaves a toxic effluent which
is placed in holding tanks until evaporation has left a dry residue
containing a variety of toxic materials.  This residue should be disposed
in a landfill approved for toxic materials or in incerators.  Although some
of the pesticide material may have been detoxified in this process, the
disposal of this residue may present some of the same environmental hazards
as disposal of the pesticide itself.

      Reconditioning via an incineration process is more acceptable
than washing with caustic soda.   As mentioned previously,  incineration
destroys almost all organic pesticides.  This leaves a cleaner, safer container
than washing.   The environmental effects again arise from disposal of
materials which are scrubbed from incinerator stack gases.
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C.   PESTICIDE DISPOSAL

     1.   On-Site

     a.   Open Dumping of Unused Pesticides

     Open dumping of unused pesticides involves discarding the surplus
pesticide on the farm or in local dumps.  (The practice of spreading
surplus pesticides over crops according to label directions is also con-
sidered a form of open dumping.)

     The environmental effects of open dumping of unused pesticides are
generally the same as those discussed above under open dumping of pesticide
containers, although the hazard to humans is appreciably greater.  An
added hazard to humans is that small amounts of the surplus pesticides
are sometimes removed from the containers for home use.  The effects on
soil ecosystems, surface and groundwater contamination, and possible food
chain hazards are similar to those discussed in regard to containers, but
greater in the potential magnitude of impact.

     b.   Burial of Unused Pesticides on the Farm

     This practice is somewhat less dangerous than the open dumping of
these pesticides.  The hazards to humans are less although groundwater
contamination and/or well contamination may result.  Soil ecosystem
effects will be serious, at least in the localized area of disposal.
While wildlife and farm animal exposure may be lessened, food chain effects
which originate in the soil ecosystem may be greater.

     2.   Final Disposition

     a.   Incineration

     The incineration of unused pesticides, if conducted at high enough
temperatures, is probably the most environmentally safe method of
disposing of unused pesticides.  The process and degradation products
are virtually the same as those discussed for the incineration of
containers.  Again, the only 'secondary' disposal problem involved is
assuring the safe disposal of the waste from the gas scrubbing system,
and the relatively inert tars and other residues.

     b.  Soil Injection

     Soil insection involves placing limited quantities of unused pesticide
in the soiL allowing it to be degraded by natural biological and chemical
processes.  Ideally, a soil injection system includes the following
components:  a high clay content to provide the greatest amount of surface
area for adsorption, a continuous supply of organic material with
the necessary carbon for bacterial growth and reproduction, a variety of
substrates for bacteria and fungi including roots, leaf litter and other
                                   169

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organic materials, vents for the release of gases, and possibly some
inoculation of bacteria specifically chosen for their ability to degrade
pesticides.

     One of the drawbacks with this disposal method is its unreliability.
It has not been possible to predict the amounts of pesticide which can be
degraded by this method.  Also, such essential details as how a pesticide
effects soil micro-organisms and its amount of mobility in the soil is often
not known for individual pesticides.

     It may be possible to assure degradation if:

     1)   Only known non-persistent pesticides are disposed of in this
          manner,
     2)   amounts are less than 10 times the normal application rates
          (or other order of magnitude as determined for different types
          of pesticide),
     3)   long durations of time as allowed before additional pesticide is
          disposed of in the same area, and
     4)   pesticide movement in the soil is monitored.  (Stojanovic, et al,  1972)

     Potential impacts of the soil injection methods if environmental
safeguards are not met would be the same as those resulting from simple
burial of pesticides in soil.

     c.   Biodegradation

     Biodegradation, as a method to degrade unused pesticides, usually
refers to microbial degradation.  Microbial degradation in the soil has
been discussed previously under soil injection.  However, microbial
degradation can also occur in a liquid medium specifically designed for
that purpose.  Such a liquid medium would involve a nutrient broth,
inoculated with bacteria suited for a wide range of decomposition
abilities, and maintained at optimum temperature, aerobic or anaerobic
conditions, and pH.  Unused pesticides would be added to this medium in
quantities which the bacterial culture could decompose without effecting
the bacteria themselves.  The end products of this system would likely
include gases such as methane or other lower hydrocarbons, and sludges
of dead bacteria and other waste products.

     The techniques in this system would approximate those used in
fermentation processes.  Lately, the fermentation process has been
considered for use in the production of methane from a variety of
solid waste materials. The greatest problem which has evolved in attempting
to use fermentation for this process has been the unreliability of the
bacterial cultures in degrading material.  The population dynamics of the
bacteria within the broth fluctuate greatly and are sensitive to
particular materials added for decomposition.  It would seem that this
problem would be intensified with the introduction of unused pesticides
because of the toxic nature of these compounds.  It is possible, however,
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that bacterial populations could be chosen which used a variety of compounds
as energy nutrient sources, and which were not susceptible to the compounds
as toxins.  More study is needed to determine the potential for this
method as a reliable means of disposal of unused pesticides.

     The sludge material resulting from this fermentation process would
probably be deposited in a sanitary landfill where soil microbes would
continue the degradation process.  The toxicity of this sludge material to
soil microbes (and other organisms which might be exposed to it) would
vary considerably because the sludge material itself would be a mixture
of undegraded pesticides, partial degradation products and bacteria.

     Degradation by contact with isolated microbial enzymes is also
a form of biodegradation.  Development of this disposal method is still in
the experimental stage.  However, these experiments (Miller,  1972)
demonstrate that particular pesticide-degrading enzymes can be extracted
from bacteria and that these enzymes can at least partially degrade some
pesticide compounds.  Table 46   shows the bacteria which had been used
in these enzymes' studies and the corresponding pesticide compounds which
they have been shown to degrade.  Since this method is still under
investigation in the laboratory, very little is known about its possible
environmental effects.  One potential problem may be the disposal of
partially degraded pesticides, since most of the isolated enzymes have
not been shown to completely degrade the toxic compounds.

     d.   Encapsulation

     Encapsulation is a method of disposing unused pesticide which involves
enclosing the pesticide material within a non-biodegradable substance,
such as concrete, and then burying this encapsulated material.  Since,
in most cases, the concrete enclosure outlines the toxicity of the enclosed
pesticide material, the environmental effects of the disposal method
would be negligible.  Theoretically, 55-gallon drums could also be used
for encapsulation of unused pesticides.  Since rusting of the containers
would release the material in a relatively short time, the environmental
effects would be similar to those caused by burial of the material.

     e.   Chemical Degradation of Unused Pesticides

     Chemical degradation is the detoxification of pesticide by reactions
with chemical reagents.  This method of disposal is in the experimental
stage and therefore its environmental effects are difficult to determine.
It is likely however that disposal of the waste material may be hazardous,
due to the compounds resulting from the chemical reactions, and the presence
of partially decomposed pesticides.
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                  VII.  CONCLUSIONS AND RECOMMENDATIONS
A.   CONCLUSIONS

     Based upon the literature survey, the results of field studies,
and economic and environmental analysis, we have drawn the following
conclusions on the disposal of pesticides and pesticide containers.

     Magnitude of the Container and Disposal Problem

     The number of pesticide containers and quantities of pesticides
which require disposal vary considerably among states or regions
depending upon the type and level of agriculture, the pesticide distri-
bution and application systems, availability of disposal facilities,
and the degree of attention focused on pesticide disposal.  Although
the use of larger reusable containers, bulk shipments of pesticides,
and closed systems for transfer of pesticides to spray equipment is
increasing, the majority of pesticides are sold in 5- to 50-pound bags
and cartons and 1- to 5-gallon containers resulting in a large number
of containers requiring disposal.  The quantity of pesticides requiring
disposal is a result of a backlog of outdated, banned or no longer
registered, or less effective compounds.  This quantity may change
depending upon future regulatory actions, pesticide shortages and in-
creasing pesticide costs.

     Actual Disposal Practices

     The disposal practices used vary considerably in different states
and regions and are determined primarily by convenience and economy
to the user/disposer and secondarily by existing disposal facilities
and regulations.  In general, the more visible the problem, the greater
the conformance with existing rules or regulations.

     Despite the efforts of trade associations, agricultural extension
services and state regulatory personnel, triple rinsing of pesticide
containers has not been accepted as widely as expected or desired.
Regulations promote triple rinsing, but only when they are adequately
enforced.  Farmers and applicators frequently do not rinse containers
or rinse them only once because of lack of time or facilities.

     Most paper and cardboard containers of pesticides are burned in
the field after they are used.  Most small metal, glass and plastic
containers are disposed of by on-site open dumping.   Burial either
on-site or in county dumps or landfills is the second most common
practice for small containers.  Reuse or recycling of these small
metal, glass or plastic containers is almost non-existent.   Methods
of disposal such as biodegradation, encapsulation, soil degradation,
etc., are not widespread.  Incineration is used as part of the pesticide
container reconditioning process, but is not generally used for container
                                  173

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disposal.

     There is an increased interest in recycling of small pesticide
containers by conversion to scrap and subsequent reuse.  There is a
trend towards reconditioning and reuse of 30- and 55-gallon containers.
Use of plastic containers is increasing; these may be easier to reuse
but more difficult to dispose.

     Low cost methods for disposal of unwanted, outdated or surplus
pesticides are not readily available.  The most common practice is to
use them as originally intended.  When they are disposed, incineration,
encapsulation, and burial are the most common practices.

     Costs of Disposal

     If environmental and social costs are not included, on-site disposal
by burial, open dumping and burning are the least costly to the pesticide
user.  A principal cost of most other systems is the cost of transport-
ing containers to disposal sites.  The costs of alternative disposal
methods such as landfill, incineration, encapsulation, etc., are
strongly dependent upon the scale of operation.  The variation of disposal
costs with scale of operation, and the variation of transport costs with
distance from disposal sites result in an economically optimum system
for each disposal method.  This optimum depends upon the rate of genera-
tion and distribution of containers.

     The cost of transport of containers from the user to a central
holding area  (or disposal site) is high and variable—between 0 and 10c
per pound.  Typical costs for disposal by landfill, encapsulation, incinera-
tion, and recycle are between 2-4
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however, that the pesticide user plays the key role in any disposal
process and most likely will ultimately pay indirectly for disposal.

     Most farmers, applicators, dealers, etc., are concerned about
the economics and practicality of disposal systems and only secondarily
concerned about health and environmental impacts.  Most pesticide
users believe that disposal of herbicides and herbicide containers
are less hazardous than disposal of insecticides and insecticide
containers.  Dealers and distributors generally believe that disposal
is a problem of the pesticide user.  They are opposed to any methods
which require their storage or handling of used pesticide containers.
Farmers and applicators accept the responsibility for disposal but
believe that dealers, distributors, and manufacturers should be involved.

     Most farmers and applicators prefer on-site disposal methods.
All participants in the disposal process believe that open burning
of pesticide bags and cardboard containers is acceptable, provided not
too many are burned at one time and that practical precautions are
undertaken.  There is varied opinion on the acceptance of landfill as
a disposal method because of the concern over possible concentration
of pesticides.  Pesticide users and others will cooperate with a recycl-
ing and reconditioning system if it is economical and will not increase
the costs of pesticides to the user.  There is general concurrence that
incineration is an acceptable method of pesticide disposal but that
its use is costly.

     Environmental Effects of Pesticide and Container Disposal


     Only recently have most states begun to record incidents of adverse
environmental and health effects of improper disposal of pesticides and
pesticide containers.  Reports to date consist primarily of sporadic
and sometimes serious incidents of poisoning of humans and animals,
fishkills, and accidents in handling and disposal of containers and
pesticides.  Chronic problems associated with pesticides and container
disposal have not been fully identified.

     Open dumping of containers and pesticides is potentially the most
hazardous disposal method.   Human and animal health hazards are most
significant but other possible effects include surface and ground water
contamination, wildlife exposure, and soil ecosystem disruption.
Incineration is safest from an environmental viewpoint provided suffi-
ciently high temperatures are maintained and scrubbing systems are
used.   The environmental effects of other disposal methods require
additional investigation.   Potential problems include unreliability,
failure to degrade pesticides completely, and disposal of wastes from
these processes.
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B.   RECOMMENDATIONS

     Based upon the results of this investigation,  we make the following
recommendations:

     1.  The Environmental Protection Agency should provide to appropriate
         state agencies basic technical, economic,  and environmental
         data and information on pesticide and pesticide container
         disposal methods and their effects.  Using this information,
         states should develop enforceable programs and procedures for
         pesticide and pesticide container disposal which meet guide-
         lines and minimal standards set by the Environmental Protection
         Agency.   The methods and procedures developed by each state
         must take into account the level and distribution of agriculture
         and pesticides, available disposal facilities, and user attitudes
         within the state.  Wherever possible pesticide and container
         disposal should be integrated with regulations and disposal
         practices for other hazardous wastes generated in the state or
         region.

     2.  In setting guidelines and minimum standards for disposal
         practices, EPA should give careful consideration to all
         participants in the disposal process, including farmer/user,
         manufacturer, and the general public.  Economics of disposal
         practices, types of pesticides and containers being disposed,
         and potential cooperation between pesticide users, persons in
         the distribution chain, and state agencies should be considered
         as well as potential environmental and health effects.  Special
         consideration should be given to the small pesticide user,
         i.e., the individual farmer, since in most states this user
         is the key element in any disposal process.

     3.  Pesticide distribution systems which provide economic and en-
         vironmental advantages by reducing the number of containers
         for disposal, e.g., bulk tanks, closed systems, large container
         recycle or reuse, should be encouraged.  However, the impacts
         of these systems on small farmers, applicators and distributors
         or dealers should be considered prior to their recommendation.

     4.  In cooperation with state agencies, universities, extension
         services, and commercial organizations, the Environmental
         Protection Agency should sponsor a series of pilot research
         and implementation programs including:

         (a)  Development, operation and analysis of several disposal
              systems, including ones operated by a state or county,
              and/or holding areas as an intermediary between pesticide
              user and the final disposal site;

         (b)  Implementation of a program to evaluate the costs and
              impacts of a returnable container deposit system on a
                                   176

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     state or regional basis;

(c)   Development of a program of  incentives  for  commercial
     pesticide disposal contractors,  drum reconditioners,
     recycle specialists,  etc., which would  promote  a  new
     service sector in the agricultural industry;

(d)   Additional programs in states  or regions  to collect data
     on the quantity of pesticides  and containers for  disposal;

(e)   Systems analysis of approaches to optimize  the  location,
     size, and type of pesticide  disposal facilities for
     specific states or regions;  and

(f)   Research on the environmental  and health  hazards  and
     costs of specific pesticide  disposal methods—landfills,
     encapsulation, controlled burial, soil  injection,
     biological and chemical degradation,  etc.
                        177

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                           VIII.  REFERENCES
Agway, Inc. 1974.  Personal Communications.

Buder, N. , 1974.  "Of Poison, Man and Indifference to Life,"
     Sierra Club Bull., December, p. 14.

California Dept. of Food and Agriculture, 1974.  California Agriculture:
     California's Principal Crop and Livestock Commodities, 1973.
     Sacramento, CA.

California Dept. of Food and Agriculture, 1974.  Pesticide Use Report, 1973.

Edwards, C.A., 1973.  "Pesticide Residues in Soil and Water," in
     C. A. Edwards (ed.) Environmental Pollution by Pesticides,
     Plenum Pub. Co., New York, pp 409-458.

Federal Register. 1973.   Vol. 38, No. 103, May 23, 1973.

Federal Register, 1974.   Vol. 39, No. 85, May 1, 1974.

Fox, A.S. and A.W. Delvo, 1972.  "Pesticide Containers Associated with
     Crop Production," Proceeding of the National Conference on
     Pesticide Containers, New Orleans, Nov. 28, 1972, published
     by the Federal Working Group on Pest Management, Washington, D.C.

Iowa Community Pesticide Survey, 1972.  "The Handling of Pesticides
     in Iowa," Iowa City, Iowa, Jan. 1972.

Jansen, L.L., 1970.  "Estimates of Container Numbers by Size, Type and
     Formulations Involved," Proceedings of the National Conference
     of the Working Group on Pesticide Disposal, June 30, 1970,
     Beltsville, MD.

Leach, E., 1974.  Land O'Lakes, Inc., Fort Dodge, Iowa, personal
     communication.

Miller, T.A., 1972.  "Problem Definition Study, Evaluation of Health
     and Hygiene Effects of the Disposal of Pesticides and Pesticide
     Containers,"  U.S.  Army Medical Environmental Engineering
     Research Unit, Report No. 73-01, p 5-12.

Mississippi Crop and Livestock Reporting Service, December 1, 1974,
     personal communication.

Mississippi State Cooperative Extension Service, personal communication.
                                   179

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Mississippi State University, 1970.   Department of Biological and
     Agricultural Engineering.   Report on the pesticide containers
     in Mississippi.

Pennsylvania Dept. of Health 1971.   "Pesticide Usage Profile Study,"
     Harrisburg, PA.

Rogers, P.A. and J. Cornelius,  1970.  "Tentative Guidelines for the
     Safe Handling and Disposal of  Used Pesticide Containers in
     California," California State  Dept. of Public Health.

Ryan, S.0., 1974.  A Study of Pesticide Use, Storage and Disposal in
     Iowa, Ph.D. Dissertation,  Iowa State University, Ames, Iowa

Shumacker, J.,  1975.  California State Dept. of Food and Agriculture,
     Agricultural Chemicals and Feed Branch, personal communication.

Stojanovic, B.U., F. L. Shuman and  M. J. Kennedy, 1969.  Basic
     Research on Equipment and Methods for Decontamination and Disposal
     of Pesticides and Pesticide Containers, Miss. Ag. Exp. Station.

Stojanovic, B.U., M.J. Kennedy, and F.L. Shuman, 1972.  "Edaphic Aspects
     of the Disposal of Unused Pesticides, Pesticide Wastes and Pesticide
     Containers," J. of Environmental Quality, ^, No. 1, p 54.

Tennessee Dept. of Agriculture, 1970.  A Summary of Pesticide Use and
     Container Disposition in Tennessee Agriculture, Nashville, TN.

Trask, H.W., 1973.  "Disposal Facilities," Proceedings of the Region
     VIII Pesticide Disposal Conference, U.S.E.P.A., Denver, Colorado,
     pp 93-94.

U.S. Dept. of Agriculture, 1970.  Census of Agriculture, 1969.

U.S. Dept. of Agriculture, 1973.  Agricultural Statistics.

U.S. Dept. of Agriculture, 1973.  The Pesticide Review, 1972, Agricultural
     Stabilization and Conservation Service, Washington, D.C.

U.S. Dept. of Agriculture, 1974.  "Farmers Use of Pesticides in 1971,"
     Economic Research Service, Agricultural Economic Rept. No. 252,
     Washington, D.C.

U.S. Dept. of Agriculture, 1974.  Farm Income Situation, July, 1974,
     Economic Research Service.

U.S. Dept. of Commerce, 1971.  Survey of Current Business, 54, 4, p 41.

U.S. Dept. of Commerce, 1974.  Statistical Abstract of the U.S.. 1973.

U.S. Environmental Protection Agency, 1973.  Final report of the Task
     Force on Excess Chemicals, 105p.


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U.S. Tariff Commission, 1973.  U.S. Production and  Sales  of  Pesticides
     and Related Products, Washington, D.C.

University of Florida, 1974.  unpublished report, "Non-Industrial
     Pesticide Wastes," Chem. Eng. Dept., Gainesville, Fla.,  Res.
     Grant R800189, prepared for U.S. Environmental Protection Agency.

VonRumker, R., 1972.  Pesticide Use on Non-Irrigated Croplands of the
     Midwest, EPA Office of Water Programs, Technical Study  Report
     TS-00-72-02, Washington, D.C.

VonRumker, R., E.W. Lawless, and A.F. Meiners, 1974.   Production,
     Distribution, Use and Environmental Impact Potential of  Selected
     Pesticides, Report prepared for Office of Pesticide  Programs,
     EPA 540/1-74-001, Washington, D.C.

Wallace's Farmer;  Agricultural Chemical and Fertilizer Survey, 1972.
 i-US GOVERNMENTPRINTINGOFFICE  1977-241-03753
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