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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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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29
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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.
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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.
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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.
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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
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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.
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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.
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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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48
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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
-------
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.
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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.
71
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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.
72
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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.
73
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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.
74
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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.
75
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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.
76
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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.
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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.
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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.
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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.
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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.
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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.
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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.
94
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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:
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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
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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.
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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.
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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.
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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
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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
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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.
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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;
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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.
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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:
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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.
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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.
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Figure 5. Pesticide Distribution System in New York
PRODUCER
FORMULATOR
REGIONAL
COOPERATIVES
INDEPENDENT
DISTRIBUTORS
COMMERCIAL
APPLICATOR
INDEPENDENT
DEALER
FARMER
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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.
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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
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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.
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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.
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inal Disposal
\_J Intermediate Handling
Figure 6. General Three-Level Disposal System
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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
125
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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
-------
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.
127
-------
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
-------
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
-------
Crushed
Containers
Asphalt
Vessel
Steam
Burial
Figure 7. Encapsulation Process
130
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
San Francisco
N
t
50 100 Miles
50 by 50 Miles
Figure 16. Principal Agricultural Areas in California
149
-------
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
-------
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)
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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 (
-------
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.
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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.
159
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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;
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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
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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
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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
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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.
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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.
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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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