Without Appendices
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United States Office of Pesticide Programs EPA 735-R-02-001
Environmental Protection Washington, DC 20460 May 2002
Agency
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About this Report
This version of the Clean Sweep Report
does not include the Appendices listed in
the Table of Contents.
Appendices are available on line at the
EPA Office of Pesticide Programs Web
site: www.epa.gov/pesticides
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Foreword
The states and some counties voluntarily provided information on their waste pesticide collection and
disposal programs, i.e., Clean Sweep programs, to the Office of Pesticide Programs in the U.S. Environmental
Protection Agency (EPA). This allowed EPA to compile a nationwide summary of Clean Sweep programs.
The Office of Pesticide Programs thanks the states and counties for providing this information and, more
importantly, for the hard work and accomplishments of their Clean Sweep programs. The point of this report
is really to acknowledge and publicize the great work they have done.
The report includes information that EPA received as of October 23,2001, and includes pesticide
collection totals through 2000. There is a clear need to update the information in this report periodically as
Clean Sweep programs continue to collect more pesticides and the programs evolve over time. To check for
updates, please go to http:www.epa.gov/pesticides or call 703-305-7102.
11
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Table of Contents
SECTION PAGE
FOREWORD h
TABLEOFCONTENTS iii
LIST OF FIGURES AND TABLES v
STATE INDEX vii
EXECUTIVE SUMMARY viii
SECTION 1 INTRODUCTION 1
1.1 What are the goals of this report? 1
1.2 How do Clean Sweep programs mesh with EPA's priorities and programs? 1
13 What laws and regulations apply to Clean Sweep programs? 5
1.4 Why do Clean Sweep programs exist? 6
1.5 What have Clean Sweep programs accomplished? 7
1.6 How has EPA categorized Clean Sweep programs? 7
1.7 What information is included in this report? 8
SECTION 2 CLEAN SWEEP PROGRAM OPERATIONS 9
2.1 Who organizes and oversees Clean Sweep programs? 9
2.2 What are the sources of Clean Sweep program funding? 10
2.3 To what extent has EPA provided funding to Clean Sweep programs? 15
2.4 Who may participate in Clean Sweep programs? 16
25 What materials are collected in Clean Sweep programs? 18
2.6 Are all pesticides accepted in Clean Sweep programs? 19
2.7 How is the material collected during Clean Sweep programs? 20
18 Do participants have to register before the material is collected? 23
2.9 How is the material disposed of? 24
2.10 Can usable pesticides be exchanged or donated to a party which needs 25
or can use them?
Ill What is involved with establishing a contract between the lead agency and a 26
hazardous waste management company?
112 Which hazardous waste management companies have been or are actively involved 28
with Clean Sweep programs?
113 How can states reduce disposal costs and improve program efficiency? 28
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The Clean Sweep Report
SECTION 3 CLEAN SWEEP PROGRAM RESULTS 31
3.1 How many and what type of Clean Sweep programs have been implemented? 31
32 How many pounds of pesticides have Clean Sweep programs collected? 33
3.3 How many pounds of pesticides are collected from each participant? 42
3.4 Which pesticides are collected at Clean Sweep programs? 43
3.5 What are the safety requirements and procedures of Clean Sweep programs? 45
SECTION 4 CHALLENGES AND OPPORTUNITIES 48
4.1 How do states design their Clean Sweep programs to comply with the 48
regulatory requirements?
4.2 What is the Universal Waste Rule? 49
4.3 How can states deal with liability issues prior to, during, and after collection? 50
4.4 How can states increase participation? 52
45 What are the disposal options for dioxin-containing wastes? 53
4.6 What are the benefits of tracking specific pesticides? 54
4.7 How do states track specific pesticides? 54
4.8 What are states doing to prevent future accumulation? 56
SECTIONS OBSERVATIONS 57
5.1 Permanent funding has many advantages. 57
52 The unit costs (on a per pound basis) of Clean Sweep programs have 58
decreased over the past decade.
53 Reliable estimates of uncollected pesticides are elusive. 62
5.4 Only a fraction of the pesticides used in states is disposed in Clean Sweep programs. 63
55 Clean Sweep programs will continue to be needed for the foreseeable future. 63
APPENDICES
Appendix I - State Profiles
Appendix n - Pesticides that are RCRA-Listed Hazardous Wastes
Appendix HI - Sample Contract
Appendix IV - Contact Information for Some Hazardous Materials Contractors
Appendix V - Number of Participants and Average Quantity of Pesticides Collected per Participant (pounds)
Appendix VI - State Web Sites
Appendix VII - Sample Emergency Plan
Appendix VIE - Comparison of Pesticides Used per State versus Pesticides Collected at Clean Sweeps
iv
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List of Figures and Tables
Number Title Page
Table 1 Clean Sweep Lead Agency by Program Category 9
Figure 1 State Clean Sweep Lead Agencies 10
Table 2 Clean Sweep Funding Sources by State 12-13
Figure 2 Clean Sweep Funding Sources by Source 14
Figure 3 Ohio Funding Sources 15
Table 3 Clean Sweep Participants by Program Category 17
Figure 4 State Clean Sweep Participants 17
Figure 5 State Clean Sweep Materials Collected 18
Table 4 Clean Sweep Materials Collected by Program Category 19
Table 5 Clean Sweep Methods of Collection by Program Category 22
Figure 6 State Clean Sweep Methods of Collection 22
Table 6 Requirement for Clean Sweep Collection Pre-Registration by Program Category 23
Figure 7 State Requirements for Clean Sweep Pre-Registration 23
Table 7 Clean Sweep Methods of Disposal by Program Category 25
Figure 8 State Clean Sweep Methods of Disposal 26
Table 8 Typical Charges in Minnesota's 1999-2002 Contract 27
Table 9 Charges in North Dakota's 1997 Contract for a Combined 27
Household Hazardous Waste and Clean Sweep Program
Figure 9 State Clean Sweep Programs by Category 32
Figure 10 Number of States with Clean Sweep Programs per Year 33
Figure 11 States with Clean Sweep Collections for at Least Seven Years 34
Table 10 Status of State Clean Sweep Programs 35
Table 11 Total Amount of Pesticides Collected by Clean Sweep Programs Each Year 37-38
(in pounds)
Figure 12 Amount of Pesticides Collected per Year 39
Figure 13 Cumulative Amount of Pesticides Collected 39
figure 14 Cumulative Clean Sweep Collections by Program Category 39
Figure 15 Amount of Pesticides Collected by the States with More Than 40
One Million Pounds
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The Clean Sweep Report
Figure 16
Figure 17
Table 12
Figure 18
Table 13
Table 14
Table 15
Table 16
Figure 19
Table 17
Table 18
Amount of Pesticides Collected by Selected States through Year 2000
Quantity of Pesticides Collected by State
Average Quantity of Pesticides Collected Per Participant
Clean Sweep Quantity (pounds) per Participant for Selected States
Specific Pesticides Tracked in Minnesota's Clean Sweep
Programs 1988-1998
Quantity of the Most Common Pesticides Registered in Virginia's
Clean Sweep Program from 1992 through 2000
Status of Adoption and Authorization of the Universal Waste
Rule re Pesticides
40
41
42
42
44
46
51
Outreach Methods Responsible for Participants' Knowledge of Collection Event 52
Cost (per pound) of Clean Sweep Collections for Selected States 59
Total Program Cost per Year for Selected States (in dollars) 69
Average Cost per Pound for Selected States (dollars per pound) 61
VI
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State Index
Alabama 13,15,60,61
Alaska 31,50
Arizona 31
Arkansas 10,13
California 11,12,34,39,40,63
Colorado 11,13,15,16,18,20,21,24
Connecticut 11,13
Delaware 11,13,20
Florida 11,12,16,17,21,24,52,56,58,59,60,61,62
Georgia 12,15,58,59,60,61,62,63
Hawaii 13,60,61
Idaho 12,18,34,45,50,63
Illinois 12,17,24,26,34,45
Indiana 13,34,64
Iowa ix, 11,12,24,33,34,38,40,50
Kansas 12,16,26,54
Kentucky 12,16,20,21,26,34,55,56
Louisiana 13,14,24
Maine ix, 13,16,33,34,38,49.60,61
Maryland 13,15,20,21,58,59,60,61
Massachusetts 11,13,45,49,50,53,55
Michigan 11,12,15,18,20,21,27,28,30,34,53.54,55
Minnesota 3,12,15,21,22,24,27,28,34,40,43,44,45,47,50,52,55,58.63
Mississippi 10,13,15,18,34,45,58,59,60,61
Missouri 13,50
Montana 11,12,18,45
Nebraska 13,39,40,58,60,61,63
Nevada 12,26
New Hampshire 13,60,61
New Jersey 9,11,-13,31,34
New Mexico 31
New York 9,11,13,31,45,55,60,61
NorthCarolina ix,7,9,10,11,12,18,21,33,34,38,40,45,49,55,58,63
North Dakota ix, 12,24,27,33,34,38,40,45,52,56
Ohio 12,15,26,34,40,45,53,58,63
Oklahoma 31
Oregon 11.13,16,18,24,34,45
Pennsylvania 12,26,34,40,49,63
Rhode Island 13,20,21
South Carolina 13,14,20,24,50
South Dakota 12,34,45,50,56,60,61,63
Tennessee 11,12,24,45
Texas 11,12,14,15,18,20,26,34,40,42,45,50,58,63
Utah 12,26,34,45,58,59,60,61
Vermont 12,20,21,26,54,60,61
Virginia 12,20,21,34,42,43,45,46,55,58,59,60,61,64
Washington 11,12,21,24,34,40,42,45,48,50,56,58
West Virginia 13,24,60,61
Wisconsin 9,12,15,17,18,21,24,26,28,29,34,40,42,45,53,58
Wyoming 13
NB: The above includes mention of the state in figures, tables, and table footnotes. In addition, every state is included in the
tables or boxes on pages ix, 7,31,35,37,38,51.
vii
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Executive Summary
Over the past 20 years, states have been
actively promoting environmental protection and
pollution prevention by conducting collections of
waste chemicals, including agricultural pesticides and
household hazardous waste. Since many household
hazardous waste programs prohibit farmers from
participating, most states have developed programs
specifically for farmers. This report is an effort to
compile state data into a single document, focusing
on collections of unwanted agricultural pesticides,
which many states refer to as "Clean Sweep"
programs. The report is based on information in
existing documents and data voluntarily submitted by
state and local governments. The main goals of the
report are to:
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Executive Summary
Participants. Although Clean Sweep
programs are sometimes, at least initially, limited to
farmers and ranchers, states are increasingly opening
programs to include other participants, such as pest
control businesses, pesticide dealers, golf courses,
government agencies (county, state, and federal),
greenhouse and nursery operators, schools, parks,
and homeowners.
Materials collected. Most Clean Sweep
programs only collect pesticides. However, some
states also collect household hazardous waste and
several programs collect other materials, such as
empty pesticide containers, batteries, and wastes
from small businesses. These states have found that
collecting several waste streams as part of their
Clean Sweep programs is more cost effective, since
mobilization fees and staff time are reduced by the
combination.
Clean Sweep programs have few limits on
the pesticides they accept, although most programs
will not accept pesticide-contaminated material such
as rinsate, soil, and debris and many place limits on
pesticides that potentially contain dioxin. Many
programs will not accept compressed gas cylinders,
explosive or radioactive material, or large quantities
of unknown material.
Method of collection. There are three
prJnedpalmethods of collection: single day events,
permanent sites, and on-sitepickup. Single day
events are the most common method and have been
used by nearly all of the states. About one-third of
the states use more than one collection method, and
the methods chosen by a state can change over time,
particularly as collection volume increases. Many
encourage people residing far from the permanent
site to participate.
Ifegistratien. Waving participants register
programs using on-site pick up and very useful for
other collection methods. Most programs require
preregistration, although a few states encourage but
do not require it. Preregistration allows the
contractor to know in advance how many stops
must be made and the volume of pesticides that will
be collected at each site, in order to determine the
number of trucks and personnel needed. However,
registration does deter people who prefer anonymity
from participating in Clean Sweep programs.
Disposal method. Most collected material
is disposed in high temperature hazardous waste
incinerators, although materials which cannot be
incinerated are sent to permitted hazardous waste
landfills. For unopened, legally-usable products, a
few states have tried various alternatives to disposal
such as product exchanges, redistribution tables, and
recycling centers.
Contractors. State or local governments
hire a hazardous waste contractor to transport the
material for disposal. In nearly all programs, the
contractor provides all materials and services for
collection, including manifesting, packaging,
transport, and disposal, and in many cases,
collection at end-user locations if containers are
deteriorated enough to make transport dangerous.
The contractor assumes all responsibility as the
generator of the waste. Some states depend on
county grantees to initiate and manage the contracts,
while others contract directly with the waste
management company and use its services as
needed. State program managers have provided
contact information for many of the contractors who
are currently or recently active in Clean Sweep
programs.
Decreasing costs and increasing effi-
ciency. States have found many innovative ways to
reduce disposal costs and improve program
efficiency, comprising both chemical handling
strategies and administrative strategies. The
rx
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chemical handling strategies include different
methods of packing the collected pesticides for
transportation and disposal, which may decrease the
cost of disposal. The administrative strategies
include specialized programs, regulatory options,
and contract management tips that may be available
to Clean Sweep program managers.
CLEAN SWEEP PROGRAM RESULTS
Number of states. Forty-six states have
conducted at least one Clean Sweep program.
North Carolina initiated the first program in 1980;
and until 1987, the only other states that started
programs were Iowa, Maine and North Dakota.
These states recognized early on that farmers were
accumulating unwanted pesticides and that, without
an affordable method of proper disposal, they risked
contaminating their land and water when the stored
product containers began to deteriorate.
Program categories. Even though some
programs are conducted by individual counties, this
report classifies the information by state. EPA is
unaware of any Clean Sweep programs imple-
mented by tribes or territories. The report divides
programs into five funding categories, which reflect
the frequency or permanency of the program:
permanently funded, continuous, intermittent, one-
time, and never.
Total amount collected. Based on data
provided by the states, EPA estimates that Clean
Sweep programs have collected over 24 million
pounds of unwanted pesticides from 1980 through
2000. A number of factors make it difficult to
record the exact amount of pesticides collected,
such as variation on how states characterize partially
full containers, differences in how solids and liquids
are recorded, and the lack of precise data from
early collections. In spite of these caveats, EPA
believes that the overall estimate of about 24 million
pounds and the totals for individual states are a good
indication of the minimum amounts collected, and
are probably underestimates. While 24 million
pounds is a substantial amount, it is significantly
smaller than the amount of pesticides sold and used
in the United States.
Amount per participant. Thirty-one states
reported the number of participants in at least some
of their collection events. The average amount
collected per participant in nearly three-quarters of
these states was between 101 pounds and 400
State Clean Sweep Programs by Category
Permanently funded programs: Georgia, Idaho, Iowa, Kansas, Kentucky, Michigan, Minnesota, Montana,
Nevada, North Carolina, North Dakota, Ohio, Pennsylvania, South Dakota, Tennessee, Texas, Utah,
Vermont, Virginia, Washington, Wisconsin
Continuous programs: California, Florida, Illinois, Indiana, Maine, Maryland, Massachusetts, Mississippi,
Nebraska, New Jersey, Oregon, West Virginia
Intermittent programs: Alabama, Arkansas, Colorado, Connecticut, Hawaii, Louisiana, Missouri, New
York, South Carolina
One-time programs: Delaware, New Hampshire, Rhode Island, Wyoming
Never held a program: Alaska, Arizona, New Mexico, Oklahoma
x
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Executive Summary
?he Clear OY;^:
pounds. States want to know what quantities are
typical in order to estimate the people and resources
they and the contractor must mobilize for the
collection. The information may also help estimate
how much unwanted pesticide remains to be
collected.
Kinds of pesticides. Most pesticides sold
in the United States have shown up at Clean Sweep
programs. Both canceled pesticides, some of which
have not been sold in the United States for decades,
and currently registered products are collected.
Safety record. Information provided to
EPA by the states indicates that few, if any, incidents
of exposure are associated with Clean Sweep
collections, due to the diligence and competence of
state employees and contractors. This is particularly
impressive considering the large quantity of
pesticides transported and collected and the fact that
many products are in old or damaged containers.
Many states provide guidance or training on specific
precautions for Clean Sweep program participants.
CHALLENGES AND OPPORTUNITIES
The challenges faced by Clean Sweep
program managers include obtaining funding,
complying with the hazardous waste regulations,
addressing liability issues, getting information to
potential participants, overcoming distrust of
government programs, and managing problematic
waste streams. As states are trying to increase
participation in their programs, they are also working
to prevent the buildup of unwanted pesticide stocks
in me future.
Funding. Lack of funding is the principal
reason noted by states for not operating a continu-
ous Clean Sweep program. Without a permanent
funding mechanism, the annual scramble for funds
prograrniniplementation.
Regulations. Regulatory compliance is an
important challenge. The Universal Waste Rule, an
amendment to the RCRA regulations, is intended to
ease the regulatory burden on states and businesses
and reduce the hazardous waste content of
municipal landfills. Most states have adopted this
rule.
Liability. Liability prior to and during a
collection event is of concern to program managers,
who employ a variety of methods to prevent
accidents. Clean Sweeps are often set up so that
the pesticide agency becomes the official generator
of the waste for the purposes of compliance with
hazardous waste regulations. At the collection
event, trained contractor and government staff
unload and process the pesticides. After the
collection, the hazardous waste contractor is
responsible for stabilizing and securing the site and
transporting the waste for disposal. At permanent
sites, trained government staff manage the security of
stored products.
Public outreach. One of the biggest
challenges faced by Clean Sweep program
managers is maximizing participation. Collection
programs have tried a variety of advertising methods
and found that effectiveness varies. Therefore, most
programs use multiple methods, such as newspaper
ads, posters at pesticide dealerships, letters,
announcements on radio and television, efforts by
extension agents, and word of mouth. States have
relied on public outreach and good relationships
between extension agents and growers to gradually
diminish the perception by farmers that they could
be fined or otherwise punished if it came to the
attention of a government agency that they were
storing canceled pesticides on their property.
Dioxin-containing 'wastes. The report
discusses the problem of disposal for pesticides that
contain dioxin. Most states (and hazardous waste
contractors) accept dioxin-containing material only if
XI
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The Clean Sweep Report
apermitted dioxin disposal facility is available, which
is not always the case. However, rejecting such
pesticides on collection days creates ill will and the
potential that such products will be indiscriminately
dumped by the participants.
Tracking specific pesticides. Some states
track and report the individual pesticides collected.
Although tracking costs more staff time and effort,
some states want to know exactly what wastes they
are collecting in order to assess trends and plan
future collection strategies. Data on the specific
quantities of canceled and unregistered pesticides
also helps document the magnitude of the problem
so that funds might be budgeted for Clean Sweep
programs. In addition, EPA uses information on the
amount of specific pesticides to gauge the impact of
certain regulations and to demonstrate the country's
commitment to certain international treaties.
Preventing future accumulation. States
are actively trying to prevent the future accumulation
of unwanted pesticides by providing training and
outreach in good management practices and
promoting integrated pest management
OBSERVATIONS
Compiling the information on the structure,
funding, and accomplishments of the Clean Sweep
programs in all of the states provides an opportunity
to make observations about these programs
nationwide.
Permanent funding has many advan-
tages. The 21 states with permanent funding have
can think long-term, can plan for phased state-wide
collections, and can establish long-term, rather than
short-term contracts with waste haulers.
The unit costs of Clean Sweep programs
have decreased over the past decade. Based on
data from fifteen states, the cost per pound to
dispose of unwanted pesticides has decreased
significantly over the past decade. The major
contractual costs are usually the mobilization fee, the
collection and disposal costs, and the analysis of
unknown products. However, the cost of Clean
Sweep programs is minor compared to the cost of
cleaning up the pollution that can result from
improper disposal of unwanted pesticides.
Reliable estimates of uncollected
pesticides are elusive. No one knows how many
pounds of unwanted pesticides have yet to be
collected in the U.S. The difficulty in accurately
estimating the total amount is due to several factors.
First, many farmers are reluctant to fill out govern-
ment surveys, particularly if they have canceled
pesticides stored in their barns, and fear that the
survey may result in a fine or penalty. Second, some
stocks lie forgotten in bams for years until the owner
dies and the bam is bought or inherited. Third,
unwanted pesticides are continually accumulating,
duetฉ overestimates of pest populations, changing
crop patterns and new products. Fourth, in recent
years some uses of older products have been
canceled due to new risk assessments conducted
under the Food Quality Protection Act.
Only a fraction of the pesticides used in
states is disposed in Clean Sweep programs. For
collected over 70 percent of all Hie waste pesticides the immediate future, assuming pesticide manage-
collected nationwide. The principal advantage of ment practices are consistent across the country, it is
permanent funding is that program managers tend to reasonable to expect that the higher a state's
have predictable funds every year or every few pesticide usage, the higher wil be its quantities of
years, and can devote tiieir energy to program unwanted stocks. States which use the most
implementation. Wimrjermanemt funding, managers
Xll
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Executive Summary Tne Clean
f" r - - - -
Clean Sweep programs, indicating that these states Clean Sweep programs will continue to
recognize and are addressing the potential problem be needed for the foreseeable future. The amount
of unwanted pesticide stocks. States with longer- of unwanted pesticide collected per year depends
running programs generally have collected higher on many factors, such as funding, the number of
quantities of pesticides and a larger proportion of the collection events, the organization and timing of the
amount of pesticides used since 1961. Data show events, and the categories of people who are
that the quantities of unwanted pesticide collected allowed to participate. Since even states with long-
and disposed by Clean Sweep programs is only a term, comprehensive Clean Sweep programs are
fraction of the pesticides used. still collecting pesticides, EPA believes that Clean
Sweep programs will continue to be needed for the
foreseeable future.
xm
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Section 1 Introduction
For the past 20 years, state and local
governments have collected and safely disposed of
more than 24 million pounds of unwanted pesticides.
These efforts, now commonly called "Clean Sweep
programs," focus on agricultural pesticides but may
also include other pesticides, such as those used by
homeowners, golf courses, or highway departments
along their rights-of-way. There is no federal
statutory requirement or mandate to conduct these
collections. Clean Sweeps are state and local
initiatives, and the states have adopted a variety of
approaches to finance and implement their pro-
grams. However, all of the states have the same
goal: fostering environmental protection and pollu-
tion prevention by removing these potentially haz-
ardous materials from the environment.
This report is a salute to the states' success-
ful and largely unheralded contribution to cleaning up
the environment
1.1 What are the goals of this report?
Tell a great story of environmental protection.
The potential for soil and water contamination due
to the improper management of waste pesticides is
high and is widely documented. Many state and
local governments recognized and addressed this
possible problem and have removed and disposed
of over 24 million pounds of potential contaminants.
Recognize the efforts of state and local
governments. State and local governments have
taken the lead and largely used their own resources
to develop procedures for the safe collection and
disposal of unwanted pesticides. The federal
government has played a limited supporting role.
EPA wishes to recognize the states and counties for
their accomplishments.
Document Clean Sweep programs and provide
an accessible information database. State Clean
Sweep programs have many common features, but
each state has designed its program to meet its own
needs. This report presents information on each
state's program in a standard format. It also
consolidates all of the information, allowing national
totals to be calculated and providing a nationwide
perspective on the accomplishments of Clean
Sweeps. In addition, EPA plans an on-line version
of this report, which will be a living document,
periodically updated as established programs
change or new ones start.
Serve as a resource for regulators, lawmakers.
and the public. This report provides information
forfederal, state, tribal, county and municipal
officials and citizens interested in initiating or
improving the collection of agricultural pesticides.
Support national and international efforts to
prevent pollution and promote environmental
protection. Several national and international efforts
attempt to prevent persistent and bioaccumulative
toxics (PBTs) from reaching the environment and to
remove the PBT contamination that already exists.
Clean Sweep programs ensure that existing
pesticide stocks, including pesticides categorized as
PBTs, are properly collected and disposed.
1.2 How do Clean Sweep programs
mesh with EPA's priorities and
programs?
EPA's mission is to protect human health
and safeguard the natural environmentair, water,
and land upon which life depends. Clean Sweep
programs conducted and led by state and local
governments are consistent with this mission. These
programs have collected and properly disposed of
millions pounds of unwanted pesticides, thereby
ensuring that they will not be released as potential
contaminants in the environment. This section briefly
describes some of the specific EPA programs whose
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Section 1 Introduction
The Clean Sweep Report
goals coincide with the Clean Sweep goal of
properly collecting and disposing of unwanted
pesticides.
Pesticides
The Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) establishes standards for
the regulation, sale, distribution and use of pesticides
in the U.S. The Act authorizes EPA to review and
register pesticides for specified uses and to suspend
or cancel the registration of a pesticide if subsequent
information shows that continued use would pose
unreasonable risks. Much of EPA's work on
pesticides involves:
Registering, or licensing, pesticides,
Ensuring that pesticides, when used according to
label directions, can be used with a reasonable
certainty of not causing harm to human health
and not posing unreasonable risks to the
environment, and
Reviewing older pesticides to ensure that they
meet current health, safety and environmental
standards.
Section 19 of FIFRA establishes standards for the
storage, disposal, transportation and recall of
pesticides and requires EPA to publish regulations
on pesticide container design and residue removal.
EPA is currently developing these regulations on
pesticide containers and containment structures,
which are intended to facilitate the safe use, safe
disposal and safe refill of containers.
Persistent. Bioaccumulative and Toxic Chemicals
Persistent, bioaccumulative and toxic (PBT)
pollutants persist in ecosystems and accumulate in
fish and up the food chain, thereby posing health
risks. In 1998, EPA drafted a strategy1 to
overcome the remaining challenges posed by these
pollutants, which stem from their ability to travel long
distances, to transfer rather easily between air,
water, and land, and to linger for decades. Since
EPA's traditional single-statute approach is not the
full solution to reducing risks from PBTs, EPA
created a system that will address the cross-media
issues associated with priority PBT pollutants. The
priority PBTs are the Level 1 substances identified
by Canada and the U.S. in the 1997 Binational
Toxics Strategy.2 For each of the priority PBTs
listed in the box below, EPA is developing a PBT
national action plan.
Priority PBTs: Level 1 Substances under the
Binational Toxics Strategy
Pesticides
aldrin
chlordane
DDT (+DDD+DDE)
dieldrin
mirex
toxaphene
Non-pesticides
benzo(a)pyrene
hexachlorobenzene
alkyl-lead
mercury and compounds
octachlorostyrene
PCBs
PCDD (dioxins) and PCDF
(furans)
National action plans draw on the full array
of EPA statutory authorities and national programs.
EPA may use regulatory action where voluntary
efforts are insufficient. EPA may pursue, in the
'The draft strategy is titled A Multimedia Strategy for Priority Persistent. Bioaccumulative. and Toxic (PBT) Pollutants
(Working Draft), prepared by the US EPA Persistent, Bioaccumulative and Toxic Pollutants (PBT) Plenary Grouo and the US EPA
Office Directors Multimedia and Pollution Prevention Forum. November 16, 1998. It can be found on the web site of EPA's
Persistent, Bioaccumulative and Toxics (PBT) Chemical Program at http://www.epa.gov/opptintr/pbt/home.htm.
2The full name of the Binational Toxics Strategy is the Canada-United States Strategy for the Virtual Elimination of
Persistent Toxic Substances in the Great Lakes Basin. Information can be found on the Binational Toxics Strategy home page at
http://www.epa.gov/prtlakes/bns/.
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short-term or longer-term, activities for international
coordination, place-based remediation of existing
PBT contamination, research, technology
development and monitoring, community and
sector-based projects, and outreach including public
advisories.
In EPA's draft PBT National Action Plan
for Level I Pesticides^ one of the goals for
reducing risks from the Level 1 pesticides is to
"facilitate, encourage, and support states, tribes and
local governments in their programs to collect and
properly dispose of unwanted pesticides, including
stocks of Level 1 pesticides." The draft plan
acknowledges the important role Clean Sweep
programs play in safely removing pesticides -
specifically the Level 1 pesticides-from the
environment. In fact, this report on Clean Sweep
programs is partially financed by funds from the
PBT initiative.
Some Clean Sweep programs record
information about the specific pesticides collected.
This information currently provides the only record
of the volume of PBT pesticides collected and the
only basis for estimating amounts uncollected.
Minnesota, for example, has comprehensive data on
amounts of specific pesticides collected. From the
late 1980's through 1998, about 6 percent of the
pesticides collected in Minnesota were the PBT
Level 1 pesticides. The voluntary efforts by state
agencies to itemize the pesticides collected have
provided very useful data and EPA has urged that
these efforts continue.
Persistent Organic Pollutants
On May 23, 2001, the U.S. signed the
Convention on Persistent Organic Pollutants
(POPs)4 in Stockholm, Sweden. Underthe
Convention, countries commit to reduce and/or
eliminate the production, use, and/or release of the
twelve POPs of greatest concern to the global
community (see box) and to establish a mechanism
by which additional chemicals may be added to the
Convention in the future. The U.S. strongly
supported efforts to complete this agreement, which
will have wide-ranging environmental and health
benefits. The pesticides included in the Stockholm
Convention are commonly collected and disposed
during Clean Sweep programs.
Persistent Organic Pollutants in the
Stockholm Convention
Pesticides
aldrin
chlordane
DDT
dieldrin
endrin
heptachlor
hexachlorobenzene
mirex
toxaphene
Non-pesticides
PCBs
PCDD (dioxins)
PCDF (furans)
Solid and Hazardous Waste Management
EPA regulates solid and hazardous wastes
under the Resource Conservation and Recovery Act
(RCRA). RCRA's goals are to protect people from
the hazards of waste disposal; conserve energy and
'Draft PBT National Action Plan for the Level I Pesticides, Public Review Draft, prepared by the US EPA Persistent,
Bioaccumulative and Toxic Pollutants (PBT) Pesticides Work Group, August 24, 2000. An announcement about its availability and a
request for comments was published in the Federal Register on November 1, 2000 (65 FR 65314).
4 United Nations Environment Program for POPs: http://irptc.unep.ch/pops
-------
Section 1 Introduction
natural resources by recycling and recovery; reduce
or eliminate waste; and clean up. waste which may
have spilled, leaked, or been improperly disposed.
Because the RCRA regulations directly affect the
design and operation of Clean Sweep programs,
they are summarized in more detail in section 1.3.
Water
Water is essential for life and plays a vital
role in the proper functioning of earth's ecosystems.
Water pollution impacts all living creatures, and
adversely affects the use of water for drinking,
household needs, recreation, fishing, transportation
and commerce. EPA enforces federal clean water
and safe drinking, water laws, provides support for
municipal wastewater treatment plants, and takes
partinpollutionprevention efforts aimed at
protecting watersheds and sources of drinking
water. EPA uses both regulatory and voluntary
programs to protect the nation's waters. State and
local Clean Sweep programs dovetail with EPA's
efforts by removing pesticides from the environment
and properly disposing of them, thereby preventing
potential waterpollution.
EPA sees the removal of unwanted
pesticides from the environment as abenefitto its
efforts to maintain clean water and has assisted
Clean Sweeps using the following programs:
519 Program. The 319 program provides
grants to states and tribes to iniplementnonpoint
source projects and programs in accordance with
the Clean Water Act (CWA). Nonpoint source
pollution, such as runoff from agricultural lands, is a
diffuse pollution source that does nothave a single
point of origin or is not introduced into areceiving
stream from a specific outet. Nonpoint source
pollution reduction projects are used to protect
source water areas and the general quality of water
resources in a watershed. Examples of previously
fundedprojects includeinstallation ofbest
management practices (BMPs) for animal waste;
design and implementation of BMP systems for
stream, lake, and estuary watersheds; basin-wide
landowner education programs; lake projects; and
Clean Sweep programs.
CWA Section 106. Section 106 of the
CWA authorizes annual appropriations of funds for
federal grants to assist state and interstate agencies
in administering waterpollution control programs.
Section 106 grants have funded a wide range of
waterpollution control activities including water
quality planning and assessments, development of
water quality standards, monitoring the quality of
rivers, streams and aquifers, and the issuance and
enforcementof permits.
Coastal Water Protection. Under section
306 of the Coastal Zone Management Act, the
National Oceanic and Atmospheric Administration
(NOAA) provides funds for water pollution control
projects to the 29 states with approved Coastal
Zone Management Programs. In a separate but
related program, these states must submit a Coastal
Nonpoint Pollution Control Program to EPA and the
NOAA. The purpose of this program is to
implement measures for restoring coastal waters and
protecting them from nonpoint source pollution.
CoastalNonpoint Pollution Control Programs are
intended to update and expand existing nonpoint
source management programs and to coordinate
closely with the Coastal Zone Management
Programs. States and territories that border an
ocean,or the GreatLakes are included in coastal
protectionprograms.
Great Lakes Program. The Grea't Lakes
National Program Office (GLNPO), based in EPA'!s
Region 5 office, works in many ways toprotectthe
GreatLakes. One of GLNPO's priorities is to
implementtheBinational Toxics Strategy with
Canada to virtually eliminate certainPBTs from the
-------
I he Claan 8wes;:<
environment. To support this effort, GLNPOhas
consistently funded Clean Sweep programs over the
years through Great Lakes-wide initiatives and
projects that were specific to individuallakes.
Teams devoted to restoring and protecting each of
the Great Lakes also sponsor Clean Sweeps to
achieve specific toxin reduction goals.
1.3 What laws and regulations apply to
Clean Sweep programs?
The Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) and its related regulations
establish standards for theregistration (licensing),
sale, distribution, use and labeling of pesticides.
When the decision is made to discard a pesticide, it
becomes a waste and thereforeis subject to the
Resource Conservation and Recovery Act (RCRA).
Under the federalregulations established
under RCRA,5 a discarded pesticide is a solid
waste. Solid wastes are defined to include solids,
liquids and gases. Although there are regulatory
exemptions from being a solid waste, they generally
do not apply. The RCRA regulations establish
criteria for determining whether a solid waste is a
hazardous waste, and therefore subject to more
extensive and stringenthazardous waste regulations.
Some, but not all, pesticides are considered
hazardous waste when disposed. The criteria for
defining hazardous waste are complex and should be
consulted when determining if a discarded pesticide
is a hazardous waste, but some of the most relevant
parts of Deregulations include the following:
Some sold wastes, such as household waste,
are specifically exempted from the definition of
hazardous wastes. Regardless of the
composition of apesticide or its characteristics,
a pesticide that is discarded by a household is
not regulated as a hazardous waste.
A solid waste can be defined as a hazardous
waste if it is included on one of four specific lists
in the regulations. The two most relevant are the
list of discarded commercial chemical products
that are acute hazardous wastes (with codes
beginning with P, e.g., P004 for aldrin) and the
list of discarded commercial chemical products
that are toxic wastes (the U-coded waste). In
addition, the list of hazardous waste from non-
specific sources (the F-coded waste) includes
one relevant entry for certain discarded unused
formulations. Appendix n contains a table with
the RCRA-listed pesticides.
A solid waste can be defined as a hazardous
waste by showing one of four characteristics
definedin the regulations: ignitability, corrosivity,
reactivity or toxicity.
The hazardous waste regulations include
requirements for identifying, handling, storing,
transporting, tracking (manifesting), treating and
disposing of the waste.6 The regulations identify the
generator of the hazardous waste - the person who
first creates or produces the waste - as the party
responsible for correctly identifying it as hazardous
waste, complying with storage limits, and ensuring
proper treatment and disposal. This regulatory
requirement, like many others, affects the structure
and procedures of Clean Sweep programs. Some
of the key requirements in the hazardous waste
regulations are described throughout the report
when they relate to a specific aspect of Clean
Sweep programs. However, the regulations are
5 The federal hazardous waste 'regulations are located in 40 CER Parts 260 through 273. The definitions of solid waste and hazardous
waste are in 40'GER Part 261. The standards for universal waste management are in 40 CFR Part 273.
6 See RCRA web site at http://.www.epa>gov/epaoswer/hotline/rcra.htm
-------
extensive and a complete summary is beyond the
scope of this report.
The hazardous waste regulations also
include the Universal Waste Rule, a set of
streamlined hazardous waste management
regulations governing the collection and management
of certain widely generated wastes, known as
universal wastes. Universal wastes include batteries,
mercury-containing thermostats, certain hazardous
waste pesticides including those collected in
government-run collection and disposal programs,
and hazardous waste lamps. Since the Universal
Waste Rule is very important and helpful to the
operation of Clean Sweep programs, it is discussed
in detail in section 4.2.
In addition, the U.S. Department of
Transportation (DOT) has requirements for the
transportation, marking and packaging of hazardous
materials (which include some pesticides) and
hazardous wastes. These DOT regulations,
established under the Hazardous Materials
Transportation Act, also affect the structure and
operations of Clean Sweep programs as described
in section 4.1.
1.4 Why do Clean Sweep programs exist?
Overtime, pesticide users accumulate
pesticides that they no longer want. Improper
disposal of these pesticides can lead to
environmental problems such as contamination of
groundwater, soils, plants, and animals. There are
many reasons why pesticides become obsolete or
unusable and why quantities accumulate, including
butnotlimitedto:
Thepesticideproduetis canceled and its use
suspended;
* The farmer discontinued powing the crop for
whichithe pesticide was bought;
The pesticide user purchased an excessive
amount of the pesticide or has containers with a
partial amount of unused pesticide;
An alternative pesticide becomes available that
is safer, more effective and/or cheaper;
The pesticide formulation is damaged, for
example, due to caking or solidification;
The integrity and effectiveness of the pesticide is
compromised due to its age;
The pesticide container (e.g., an aerosol can) is
old and damaged or ripped (e.g., a bag) and can
no longer be used, or the label has been
obliterated and is unreadable;
The pesticide's use on a crop has been removed
fromnewer labels and, although farmers may still
legally use older products according to the label,
they may choose not to;
The user does not know how to properly
dispose of the unwanted pesticides or believes
disposal will be too expensive;
The pesticide is abandoned; for example, by
deceased users or found on purchased property.
Government officials and the agricultural
community had become increasingly aware that the
continued storage of unwanted pesticides was not a
deskable situation. They needed a safe way to
collect and dispose of canceled, outdated, degraded,
unusable or otherwise unwanted pesticides. State
and local officials took the lead in this effort, and
Clean Sweep programs are the result.
Clean Sweep programs for farmers are
analogous to Household Hazardous Waste (HHW)
collection programs for homeowners. Many homes
have places where unwanted materials such as
motor oil, antifreeze, paints, household disinfectants,
and lawn and garden pesticides accumulate. These
materials are typically stored in garages, basements,
storage rooms, and closets. State and local
governments have long recognized the need to
collect and safely dispose ฎfsuch materials, which is
-------
The Ciean Sweep - 2 . -
why many local governments conduct HHW
collection programs. Similarly, officials in many
states gradually developed disposal programs for
farmers, preventing millions of pounds of pesticides
from contaminating the environment.
1.5 What have Clean Sweep programs
accomplished?
North Carolina conducted the first Clean
Sweep in 1980. Today, Clean Sweep programs
conducted in 46 states have collected and destroyed
or recycled over 24 million pounds of unwanted
pesticides. Some of the collected pesticides had
been stored for decades in barns and basements. It
is possible that these pesticides would have seeped
out of their deteriorating containers and contami-
nated soil orgroundwater.
To date, 11 states have collected over one
million pounds of pesticides, with one state collecting
over three million pounds. Twenty-one states have
Clean Sweep programs with assured funding which
permits them to conduct annual collections, and
these states have collected more than 70 percent of
all the waste pesticides collected nationwide.
Twelve other states with less certain funding have
conducted Clean Sweep programs for several
consecutive years.
Participation in Clean Sweeps has expanded
from exclusively fanners and ranchers to include
residential and institutional pest control operators.
government agencies, golf course owners and
others. Collections have included nearly every
pesticide manufactured in the United States.
Although many of the collected pesticides were
canceled years ago. currently registered pesticides
predominate, with widely-used herbicides among the
most commonly collected products. Clean Sweep
programs have an excellent safety record, with few.
if any. incidents of unwanted exposure. Many states
provide guidance, either on their web site or in
printed form, on specific precautions for program
participation, and a few require participant training.
1.6 How has EPA categorized Clean
Sweep programs?
Forty-six states have conducted Clean
Sweep programs and 11 states have conducted
collections for at least 10 years. Program frequency
is an important measure of a state's program. A
second critical measure is reliable state funding.
This report uses these two factors to classify Clean
Sweep programs into five categories.
The categories, which reflect the frequency
or permanency of the program, are: permanently
State Clean Sweep Programs by Category
Permanently funded programs: Georgia, Idaho, Iowa, Kansas. Kentucky, Michigan, Minnesota. Montana.
Nevada, North Carolina, North Dakota, Ohio, Pennsylvania. South Dakota, Tennessee, Texas. Utah, Vermont.
Virginia, Washington, Wisconsin
Continuous programs: California, Florida, Illinois, Indiana, Maine, Maryland, Massachusetts, Mississippi,
Nebraska, New Jersey, Oregon, West Virginia
Intermittent programs: Alabama, Arkansas, Colorado, Connecticut, Hawaii, Louisiana, Missouri, New York,
South Carolina
One-time programs: Delaware, New Hampshire, Rhode Island, Wyoming
Never held a program: Alaska, Arizona, New Mexico, Oklahoma
-------
Section I Introduction
funded, continuous, intermittent, one-time, and
never. A permanently funded program is
continuous andhas reliable, consistentfunding in
place year after year. Types of permanent funding
include state pesticide registration fees, other fee-
based funds that support clean up programs and
consistent state appropriations. A continuous
program is defined in this report as one that has
been implemented for at least three consecutive
years, but withoutpermanentfunding. Although
continuous means "withoutinterruption", aprogram
may still be classified as permanently funded or
continuous even if it occasionally skips a year. An
intermittent program is not continuous but has held
more than one collection event. A one-time
program has held one collection event. Four states
have never had a collection.
1.7 What information is included in this
report?
This initial Clean Sweep Report summarizes
the significant accomplishments of the state Clean
Sweep programs. It contains yearly totals of
pesticides collected nationwide and by each state.
The report describes the state programs and
identifies state lead agencies, program participants,
and materials collected. The report covers
collection logistics, the states' various funding
mechanisms, constraints, problems andinnovative
solutions. It also includes a discussion of the
regulatory frameworkfor pesticide disposal.
This report is based on information
voluntarily providedby state andlocal governments
and on existing documents found on the Internet or
obtained from the state and local governments.
EPA provided draft state profiles to Clean Sweep
managers and incorporated the comments that were
received. These profiles, in Appendixl, contain
standard information on each state program.
-------
Section 2 Clean Sweep Program Operations
North Carolina conducted the first Clean
Sweep program two decades ago. Since then, 45
other states have undertaken Clean Sweeps but no
state has followed a set blueprint. This section
covers the states' various approaches, describing
the lead government agencies, funding sources,
allowable participants, materials collected, methods
of disposal, and contracting with hazardous waste
management companies. In general, the nationwide
information is presented in terms of the program
categories described in section 1.6.
2.1 Who organizes and oversees Clean
Sweep programs?
In most cases, the agency within state
government that regulates pesticides (usually the
state agriculture department) takes the initiative and
the responsibility for organizing and overseeing
Clean Sweep programs. In six states, the state
environmental agency (which regulates waste in
those states) is the lead agency. In a few states, like
New Jersey and New York, the counties have a
significant role with very little oversight from the
state government. Wisconsin offers grants from the
Department of Agriculture, Trade and Consumer
Protection to counties that provide a cost-share
match, a local coordinator, volunteers and a
collection site.
As shown in Table 1 and Figure 1, the state
department of agriculture or the pesticide regulatory
agency (if different than the department of
agriculture) lead Clean Sweep programs in 34
states, nearly 75 percent of the states with
programs. In addition, three states in the "other lead
agency or agencies" group share the program lead
between two agencies, one of which is the
agriculture department or a different pesticide
regulatory agency.
Regardless of which agency has the lead,
collections are nearly always a cooperative effort
involving the state extension service, other state
agencies, county and local governments, industry
associations, and other interested individuals. In
TABLE 1 Clean Sweep Lead Agency by Program Category
Each cell contains (1) the number of states with the indicated lead agency and (2) a listing of those states
^^^^^ Category
Lead Agency ^^^^
Department of
Agriculture
Other Pesticide
Regulatory Agency
Environmental Agency
Other Lead Agency or
Number of States
Permanently Funded
i
(18) GA, ID, KY, MI,
MN, MT, NV, NC,
ND, OH, PA, SD, TN,
UT, VT, VA, WA, WI
i** &
(2) IA, TX
1 **''
(DKS
21
Continuous
(6) IL, MD,
MA, MS, NE,
WV
(2) IN, ME
(2)CA,OR
(2) NJ, PL
12
Intermittent
(3) AL, HI, LA
(2) AR, CT
(1)MO
(3) CO, NY,
SC
9
One-Time
(2) NH, WY
(DRI
(DDE
4
Number of
States
29
5
6
6
46
-------
FIGURE 1 State Clean Sweep Lead Agencies
29 Dept. ofAg.
5 Other /'<>.
6 Oiht
6 ฃ/nv<
] Department of Agriculture: 2V states
|H Other Pesticide Regulatory Agency: 5 states
| Environmental Agency: 6 v/ซro
| Other Lead Agency or Agencies: 6 Males
many cases, local extension agents or industry
associations, like the Farm Bureau and state retail
associations, have a working relationship with
farmers and can build support for Clean Sweeps.
They may also have names and mailing addresses of
potential participants, and they may be able to solicit
volunteers or collection sites. Finally, the lead
agency (if it is the pesticide regulatory agency) must
develop a close working relationship with the state
waste agency to resolve any regulatory issues
involved with collecting, transporting and disposing
of waste pesticides.
2.2 What are the sources of Clean
Sweep program funding?
Clean Sweep programs are funded, to
varying degrees, by state pesticide registration fees,
other fee-based funds, state general funds.
participant fees, EPA grants, county funds, in-kind
services, and other grants. States often utilize more
than one funding source and the source or sources
commonly vary overtime.
Pesticide registration fees: States routinely collect
registration fees from pesticide companies for each
product sold within the state. A state undertaking a
comprehensive Clean Sweep program will often
raise the registration fee and use the additional
money to fund Clean Sweeps and other
stewardship-oriented programs. For example, the
North Carolina General Assembly enacted
legislation in 1993, creating an Environmental Trust
Fund to support a statewide agromedicine program
and pesticide environmental programs. This
legislation received unprecedented broad support in
North Carolina from environmental groups, industry
groups, commodity organizations, regulatory
agencies and legislators. Pesticide companies
supported paying additional fees in order to show
their commitment to environmental stewardship.
Seventy-five percent of the Environmental Trust
Fund budget is allocated to the Department of
Agriculture and Consumer Services for its pesticide
programs, including establishing an empty container
management program to enhance its pesticide
disposal program. The additional fees from
pesticide registration are earmarked for container
recycling rather than pesticide disposal.
Also in 1993, Mississippi enacted the
Mississippi Waste Pesticide Disposal Law, which
authorized an increase in state pesticide product
registration fees from $50 to $ 100 to fund a
pesticide collection and disposal program. A sunset
clause in the legislation limited the use of pesticide
registration fees for funding the disposal program to
five years. As a result, the program manager must
now seek annual funding from other sources to
continue pesticide collections.
In March 2001, the Arkansas General
Assembly approved legislation that established an
Abandoned Pesticide Disposal Program and
authorized the state Plant Board to collect $50 per
registered pesticide per year to fund the program.
The Abandoned Pesticide Disposal Fee must be
10
-------
The Ciesn
paid beginning in 2002 for products registered and
re-registered in Arkansas.
Table 2 identifies each state's funding
mechanisms and Figure 2 shows the number of
states that have used each kind of funding.
Fee-based funds: Several states dedicate fees
collected for certain activities to Clean Sweep
programs. For example, Texas uses fees on
hazardous waste and industrial solid waste
generators and waste management units;Montana
uses dealer and certified applicator fees; Iowa uses
a Groundwater Protection Fund generated from
tonnage fees at landfills andpermitfees charged to
retailers of hazardous materials; and Delaware used
a $2 per ton surcharge on solid waste disposal fees.
The Washington state program is funded under its
Toxics Control Account, which receives money
largely from a tax on hazardous substances,
including petroleum products, pesticides and other
chemicals. In fiscal year 2000, the Washington
State Department of Agriculture spent almost
$238,500 on pesticide disposal, which was less than
1 percent of the $26 minion expenditures of the
State Toxics Control Account:
Statefunds: Some state legislatures consistently
budgetfunds for Clean Sweep programs while
others budgetfunds intermittently. TheNorth
Carolina General Assembly annually funds the
Pesticide Disposal Assistance Program of the
Department of Agriculture and Consumer Services.
Tennessee beganits waste collection program in
1998 with funding for seven years as part of the
State ManagementPlan for Pfotectionof Ground-
water frompestieides. TheFIoridaDepartment of
Environmental Protection received an appropriation
of $300^000 for state fiscal year 2000-2001 to
pestieidie collection and disposalprogram.
EPA grants: As discussed in Section 2.3, EPA
funds have comprised a small percentage of the total
funding for Clean Sweep programs and have been
used to provide seed money for new programs,
implement targeted programs after the criteriain
cooperative agreements were satisfied, support the
goals of other EPA programs or support special
needs.
Participantfees: California, Colorado, Connecti-
cut, Massachusetts, Michigan, Montana, and
Oregon have charged fees to all Clean Sweep
participants to wholly or partially cover the cost of
collection and disposal, but such fees may be a
deterrent to participation. Massachusetts charges
from $1.10 to$1.35 per pound for solids and $9
per gallon for liquids, which is considerably less than
the cost of independent disposal by individual
farmers. However, during 1998, many Massachu-
setts farmers suffered significant losses and were
unlikely to give pesticide disposal a high priority with
mek limited incomes. The 1998 collection, the first
in eightyears, produced arelatively low collection
volume of approximately 39,000 pounds compared
with more than 85,000 pounds collected in 1990.
State representatives attribute this low total at least
partially to the participant fee. Colorado has
completely financed its Clean Sweep program with
participant fees of $2.25 to $2.65 per pound.
California wholly funds its program with participant
fees, while participant fees in Connecticut and
Michigan only cover a portion of the program costs.
In Montana, participants pay $ 1 per pound for the
first 200 pounds and $0.50 per pound for amounts
in excess of 200 pounds. This accounts for about
25 percent of Montana's funding.
County funds: In New Jersey and New York,
counties organize and fund farm pesticide collection
programs. Atleast 14New Jersey counties allow
farmers to participate in their household hazardous
11
-------
Section 2 Clean Sweep Program Operations
TABLE 2 Clean Sweep Funding Sources by State
$ indicates source of funds
^^^^Spurces
States ^^^^
Pesticide
reg. fees
Fee-based
fund
State
funds
EPA
grants
Participant
fees
County
funds
In kind
services
Permanently Funded Programs
Georgia
Idaho
Iowa
Kansas
Kentucky
Michigan
Minnesota
Montana
Nevada
North Carolina
North Dakota
Ohio
Pennsylvania
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
Wisconsin
Subtotal
$
$
$
$
$
$
$
$
$
$
$
$
$
13
$
$
$
$
$
5
$
$
$
$
4
$
$
$
$
$
$
$
$
8
$
$
2
0
Continuous Programs
California
Florida
Illinois
$
$
$
$
$
$
$
2
Other
grants
$
1
Unknown
0
/
$
12
-------
The Clean Sweep Report
^^-^Spurces
States ^^^^
Indiana
Maine
Maryland
Massachusetts
Mississippi
Nebraska
New Jersey
Oregon
West Virginia
Subtotal
Pesticide
reg. fees
$
$
$
$
4
Fee-based
fund
0
State
funds
$
$
$
$
$
$
$
9
EPA
grants
$
$
$
$
$
$
$
8
Participant
fees
$
$
3
County
funds
$
2
Inland
services
0
Other
grants
$
1
Unknown
1
Intermittent Programs
Alabama
Arkansas
Colorado
Connecticut
Hawaii
Louisiana
Missouri
New York
South Carolina
Subtotal
0
0
$
$
$
$
$
$
$
7
$
$
$
$
$
5
$
$
2
$
1
$
$
2
$
1
$
$
2
One-Time Programs
Delaware
New Hampshire
Rhode Island
Wyoming
Subtotal
0
$
1
$
1
$
1
0
0
0
0
$
1
All Programs (Permanently funded, continuous, intermittent and one time)
Total
17
6
21
22
7
3
4
3
4
13
-------
FIGURE 2 Clean Sweep Funding Sources by Source
FIGURE 2A Funding Sources for All States
Pest rsg fees
Fee-Cased fund
Stale funds
EPA grams
Participant tees
County funds
In kind services
Other granls
Unknown
FIGURE 2B Funding Sources for Permanently Funded Programs
5 10 15 20
Number ol Stales
25
Pest reg fees
Fee-based lund
Stale lunds
EPA grants
Participant fees
County funds 0
In hind services
Other grants 1
Unknown Q
1 3
4
0
5 10 15
Number of States
Permanently funded programs
20
FIGURE 2C Funding Sources for Continuous Programs
Fee-based fund ' 0
FIGURE 2E Funding Sources for One-Time Programs
Pest reg tees 0
EPA granls ^ '
Participant lees 0
County funds 0
In Kind services 0
Omer giants 0
Unknown ^H 1
10
Numcei erf Stales
15
15
20
20
FIGURE 2D Funding Sources for Intermittent Programs
Pest reg fees 0
Intermittent progra
15
20
waste collections, and a few charge a fee depending
on the amount of pesticide.
In kind services: While Louisiana and South
Carolina have used partnerships and in-kind services
to implement earlier programs, Texas is the only
state currently using this method. Texas has enlisted
regional recyclers to provide collection services for
materials other than pesticides, such as batteries and
used oil. and has obtained container granulation
services from a pesticide container recycler in
collaboration with the Ag Container Recycling
Council (ACRC).
14
-------
Other grants: Texas has successfully garnered
funds and partnerships from state agencies and
private organizations including the South Texas
Agricultural Chemical Association, the ACRC, the
Texas Agricultural Extension Service, the Texas
Department of Agriculture, and local environmental
groups. Alabama and Mississippi have received
grants from the Tennessee Valley Authority for their
programs.
2.3 To what extent has EPA provided
funding to Clean Sweep programs?
EPA has funded only a small percentage of
the total cost of Clean Sweep programs. Since
detailed cost and funding data for every state's
Clean Sweep program are not available, it is not
possible to provide the total amount and proportion
of EPA funding. However, information on Ohio's
funding is available and is typical of other states.
From 1993 through 2000, Ohio spent more than
$ 1.5 million to collect and dispose of over one
million pounds of pesticides. With the exception of
$80,000 received from EPA under the Coastal
Environmental Management Program for collections
in Lake Erie counties, the Ohio Department of
Agriculture has paid all program costs. The majority
of the project funding was generated from state
pesticide registration fees and the EPA grant
comprised less than 6 percent of Ohio's total
funding, as shown in Figure 3.
The limited EPA funds used to support state
and locally run Clean Sweep programs generally fall
into one or more of the following general categories.
Providing Seed Money. In several cases, EPA has
funded pilot projects, which were intended to
demonstrate the necessity and effectiveness of Clean
Sweep programs to government officials and the
public. An EPA grant of $75,000 under the Clean
Water Act for a pilot project was coupled with
Figure 3 Ohio Funding Sources
State-based funds
EPA grants
State-based funds (mainly pesticide reg. tees):
$1.420,000(94.4%)
EPA grants: $80.000 (5.6%)
Colorado's commitment of a $50,000 in-kind match
to fund the state's first Clean Sweep in 1995. Since
then, participant fees have funded three years of
collections in Colorado. Similarly, Georgia received
an EPA grant in 1993 of $48,000 for a pilot
collection, and a second grant of $40,000 for a
1996 collection. These events were so successful
that the Georgi a Department of Natural Resources
provided a solid waste grant of $50,000 to conduct
the 1997 collection. State funds have funded
subsequent collections and the Georgia General
Assembly plans to allocate up to a total of $2.5
million. Maryland's Clean Sweep program began in
1995 with an EPA grant of $75,000 and state funds
earned the program through 1999. EPA's Region 5
provided seed money for Clean Sweep programs in
the late 1980's. and now most of the Region 5
states - Michigan, Minnesota, Ohio, and Wisconsin
- have programs that are funded through state
pesticide registration fees.
Satisfying Criteria in Cooperative Agreements.
FIFRA gives EPA authority to enter into cooperative
agreements with and to provide grants to states to
implement federal pesticide regulatory requirements.
15
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Section 2 Clean Sweep Program Operations
The grants support enforcement and compliance
efforts on the use of pesticides and field programs.
There are three examples of field programs: (1)
applicator certification and training; (2) ground
water programs; and (3) worker protection efforts.
If a state meets the standards set by the cooperative
agreement, it has the discretion to request funds for
activities outside the normal scope of the agreement,
provided the activity furthers the overall goal of
protecting public health and the environment from
pesticides. Some states have taken this opportunity
to request funds to supplement their Clean Sweep
programs.
Supporting the Goals of Another EPA Program.
As described in section 1.2, the objectives of Clean
Sweep programs are consistent with the goals of
several existingEPAprograms,includingremoving
PBT chemicals from the environment andprotecting
the nation's waters. Occasionally, these other EPA
programs have supported state Clean Sweep efforts
because EPA determined that such assistance would
benefitthe environment and support the specific
program's goals. For example, Kentucky's Clean
Sweep program, which has been continuously
funded since 1995 by pesticide registration fees,
received almost$17,000 of EPAfundingin 1999
fromthePBTMtiative. This incremental funding,
less than ten percent of Kentucky' s total funding,
providedanincentivefor Kentucky to begin tracking
quantities of certain PBTpesticides collected in the
state's Clean Sweep program. The Great Lakes
Mtiativeaeieomplished specific environmental goals
andseedednewpi0gi?ams throughits funding of
Clean Sweeps. In 1992, Region 5 prodded
assistance ranging from $27^000 to up to $174,000
affeetedbytheMississippiRiverflooding. In
addition, EPA's C^^^^vironmenlMli^anagenient
funds iradeiAeClean Water Aetprovided an
addit
regjoa
Supporting Special Needs. Occasionally, EPA
provides funding to states in an area that suffered a
natural disaster. In the Midwest, EPA goals have
been achieved by funding Clean Sweeps in areas of
concern in the Great Lakes Basin and along the
Mississippi River during flood years.
2.4 Who may participate in Clean
Sweep programs?
Since Clean Sweep programs are defined as
the collection of unwanted or waste agricultural
pesticides, they are directed - at least initially - at
farmers. In eight states, the programs are limited to
farmers and ranchers. Five states limit participation
to fanners and households. The other states allow
businesses other than farmers to participate,
although some businesses must pay at least part of
the disposal cost. Kansas allows dealers,
manufacturers and distributors to participate on a
cash-on-delivery basis and Maine and Florida
require payment of the contracted disposal rate
($1.30 to $2 per pound). In Colorado and Oregon,
larger businesses andretailers may participate and
must pay the same fee as farmers and other
pesticide users.
Otherparticipants allowed by various states
include golf courses, pest control operators,
government agencies (county, state and federal),
greenhouse and nursery operators, schools, and
parks. Permanently funded programs allow a wide
range of participants. As shown in Table 3 and
Figure4, allofthe21 permanently fundedprograms
allow fanners and atleast three other kinds of
participants in their Clean Sweeps. Sev,en, or 58
percent, of rne continuousprograms als|> al|ow a
will rangeof participants. The majority of
mtejinittentandone-timeprograms allow only
farmemoiifaBflieK andshouseholds.
-------
Many states began their programs with
farmers only and expanded to include other groups
as they gained experience and capacity. Florida
began with farmers in 1995 and has expanded to
include golf course superintendents, pest control
operators and other end-users. Pesticide retailers
and distributors may also participate, but must make
arrangements in advance and pay the contract price
for disposal. Illinois included only farmers until
1998. when it opened participation to the state's
structural pest control operators. Wisconsin has
opened its program from farmers only to include
agricultural businesses, government agencies, private
schools, manufacturers, independent and commer-
cial applicators, agricultural cooperatives, golf
courses, landscape companies, real estate manage-
ment companies, lumberyards, marinas, hardware
stores, and others. These businesses and other
FIGURE 4 State Clean Sweep Participants
30 Farmer-* & 3 other pan.
2 Farmer\ & one mher
^. Coitini. .-A/1/' << hh
Farmers only: K \M;CS
Farmers and households: 5 ,\/
-------
participants pay half the disposal cost for agricultural
pesticides and the full disposal costs for other
wastes. Even with paying the full disposal costs.
they generally save 20 percent to 30 percent of the
cost of having a waste hauler pick up waste
chemicals at their location.
2.5 What materials are collected in
Clean Sweep programs?
Clean Sweep programs are intended to
collect unwanted pesticides, and 34 of the states
with Clean Sweep programs collect only pesticides.
All of these states collect agricultural pesticides,
while Colorado, Idaho, Michigan, Montana and
North Carolina also collect pesticides from
households. Eight other states collect pesticides and
all kinds of household hazardous waste as part of
their Clean Sweep programs. Four states collect
items other than pesticides and household hazardous
waste. Texas collects empty pesticide containers.
batteries, used oil and oil filters, and, at several past
events, metal and wire. Wisconsin collects
unwanted chemicals from non-pesticide businesses.
In 1997. Oregon began to collect waste pesticides
as universal waste in conjunction with its household
hazardous waste collections. Oregon also included
wastes from businesses that generate small quantities
of hazardous waste, called conditionally exempt
small quantity generators (CESQGs). In Oregon's
program, one contractor collects the different waste
streams atone location, thereby reducing the
collection cost, but keeps the waste streams
separate. Mississippi has collected tires, waste oil
and batteries in the past.
In 2001. Wisconsin began accepting sludge
from mixing and loading pad sumps and weigh-scale
pits. As fertilizer trucks and pesticide application
equipment are filled or cleaned, dirt, debris.
fertilizers, pesticides and other chemicals collect in
the sumps and create disposal problems.
Agricultural cooperatives and farm chemical dealers
requested assistance in getting rid of these materials
in an environmentally sound manner. The state
agreed to accept this waste with the condition that
participants pay one-half of the disposal costs.
Companies are asked to remove as much water as
possible from the sludge before bringing it to the
Clean Sweep event.
Information on the materials collected by
each state in its Clean Sweep program is provided
in Table 4 and Figure 5.
Most states also conduct, or have
conducted, empty pesticide container collection and
recycling programs, often with the assistance and
collaboration of the Ag Container Recycling Council
(ACRC), a non-profit organization. The ACRC is
composed largely of pesticide manufacturers, who
each contribute to the Council an amount of money
proportional to the quantity of plastic containers the
company uses to distribute its pesticides. The
ACRC assists pesticide container collection
programs by providing training, funding, guidance
FIGURE 5 State Clean Sweep Materials Collected
34 Pfsl. onlv
4 A'tt. A mil, r mi/.'
Pesticides only: 34 stales
Pesticides and household hazardous waste: 8 states
Pesticides and other material: 4 states
18
-------
TABLE 4 Clean Sweep Materials Collected by Program Category
Each cell contains (1) the number of states which collect the indicated material and (2) a
listing of those states
Materials
Pesticides only1
(17) GA. ID.
KS. KY, Ml,
MN.MT, NV,
NC, ND.OH,
PA, SD,TN,
UT, VA.WA
Pesticides and household
hazardous waste
Pesticides and other material
(2) 1A. VT
(2)TX,WI
(9) CA. FL,
IL, IN, ME,
MD, MA,
NE.WV
(DNJ
(2) MS, OR
12
(5) AR, CO.
CT. LA. MO
(4) AL. HI.
NY. SC
(3) NH, RI,
WY
(DDE
34
Note: (1) All states collect agricultural pesticides. Several also collect pesticides from households (CO, ID,
MI. MT and NC). Depending on allowable participants, states may also collect pesticides from other sources,
such as golf courses, pest control operators and parks.
and public outreach materials. ACRC enters into
contractual agreements with independent companies
which consolidate containers from collection sites
and then ship them to facilities where they are
granulated and recycled into other products.
ACRC also conducts research to find more uses for
granulated plastic, such as plastic pallets for
pesticide storage. The ACRC has helped states and
counties collect and recycle more than 46 million
pounds of plastic pesticide containers since it was
founded in 1992.i
2.6 Are all pesticides accepted in Clean
Sweep programs?
While Clean Sweep programs accept a
broad range of pesticides, most programs will not
accept pesticide-contaminated material such as
rinsate, soil and debris. Also, many programs place
limits on pesticides that potentially contain dioxin,
which include 2,4,5-T, Silvex, Ronnel and
pentachlorophenol. Because of the difficulty in
disposing of these pesticides (discussed in Section
4.5), some states no longer collect them and others
only collect small quantities, typically less than 5
gallons, to avoid paying long-term storage costs.
State policy may change from year to year,
depending on contractor specifications and the
availability of an incinerator which accepts dioxin-
containing materials. States are concerned about
rejecting these pesticides, which might then be
discarded in an unsafe manner. However, states do
not want to commit their limited funding to long-term
storage while awaiting the availability of an
appropriate incinerator. Some states ask
participants to store the dioxin pesticides until further
notice and provide overpack materials to facilitate
their safe storage.
ACRC web site: http://www.acrecycle.org/
19
-------
Section 2 Clean Sweep Program Operation!
Some programs reject certain products or
containers. For example, South Carolina did not
accept gaseous fumigants or compounds containing
mercury. Texas will not accept unrinsed or
improperly rinsed containers. Many programs will
not accept compressed gas cylinders, explosive or
radioactive material, or large quantities of unknown
material.
2.7 How is the material collected during
Clean Sweep programs?
There are three basic collection methods:
Single day events: Single day events are well
advertised one-day Clean Sweep collections held at
convenient locations. The events are usually
carefully coordinated with the local authorities and
use a hazardous waste management contractor to
collect and dispose of the day' s collections. A
centrally located site, such as aDepartment of
Transportation facility, a fairground or a dealership,
is an ideal location.
Advantages of one-day events include the
economy of having all resources available and
mobilized for a single well-advertised date, not
needing apermanent site, the ability to include near-
by counties in the collections, and the possibility of
covering the whole state by scheduling one-day
events in differentregions. The main disadvantages
of single day events are time limitations and the
potential risk and regulatory issues which may arise
when participants transport the material. Partici-
pants unavailable on the scheduled day will miss the
event and other participants may be unwilling to wait
in line. In addition, one-day events are likely to be
conditions. Thepotential for pesticide releases
causing contamination at a neutral site may be a
disincentive for choosingtihis method. In spite of
these disadvantages, single day colections are the
most common collection method, and only seven of
the states that have had programs, Colorado^
Delaware, Kentucky, Maryland, Michigan, Rhode
Island and Virginia, have not used this method.
Over half of the states with programs - 25 states -
collect materials only at single day events. In states
which combine Clean Sweep programs with
household hazardous waste collection, the same
collection site is used but there is a separate line for
each waste stream.
Permanent sites: Participants take their material to
a "permanent" site, usually a household hazardous
waste collection f acility, or in the case of Vermont,
to alandfill. Out of the nine states thathaveused
permanentcollection sites, seven have permanently
funded Clean Sweep programs.
Permanent sites allow maximumflexibility to
participants who may not be available for single day
collection events and spread the volume collected
over time, which reduces waiting in lines. A
permanent site is more likely to be indoors or have a
collection area protected from the weather. A
permanent site entails the need for a faeility and
personnel to staff and maintain it. However,
because the volume is distributed over time, a small
staff can manage the logistics compared to the large
staff needed to handle a one-day event. Even when
permanent facilities advertise a collection event at
their site, there is little chance of being overwhelmed
since service is available year round. Permanent
facilities offer unique opportunities to sponsor
chemical exehangeprograms and increase local
hazardous waste education. Because these efforts
lead to improved pesticide management and
reduced waste disposal costs, states and local
governrnentsusepermanentfacilities to provide
extra educational programs and technical assistance.
As with single day events, potential risk and
regulatory issues may arise when participants
transport the material themselves. Thefactthat
-------
The Clean Sweep Report
participants may be unwilling to drive long distances
to a single facility is a likely reason thatMichigan is
the one state that uses only permanent sites to
collect pesticides.
On-sitepickup: For on-site pick up, the hazardous
waste contractor and/or the lead government agency
travel to each participant's site to collect the
material. In five states, Colorado, Kentucky,
Maryland, Rhode Island and Virginia, this is the only
method used. In other states, including Washington
and Florida, pre-visits and on-site pick ups are done
only if the pesticides pose a very high risk, such as
cylinders or deteriorated containers, or if there are
very large quantities. Before the material is picked
up for disposal, state employees and/or the
hazardous waste contractor visit the participant's
site to inventory and prepare the material.
On-site pick up presents minimal risk from
transporting or handling the pesticides, since it is
done by well-trained and equipped contractor
employees or state personnel. Other advantages of
this method include convenient scheduling for the
participant, no need for the participant to transport
the pesticides, and no requirement for a permanent
site. States can require the contractor to dispose of
any contaminated soilfoundunderfailed containers.
However, on-site pick up can be more expensive
than other collection methods. It is labor and time
intensive because the contractor must travel to each
site, unload empty overpack drums and load full
drums.
Information on the methods used to collect
pesticides at Clean Sweep programs is provided in
Table 5 and Figure 6.
At least 15 states have used more than one
collection method, and larger programs tend to use
severalmethods simultaneously. For example,
permanently funded programs in Minnesota, North
Carolina and Vermont have used all three methods
to conduct pesticide collections. Wisconsin has 19
counties offering season-long services and also
conducts one-day events and multi-county
collections. Wisconsin offers grants of up to
$30,000 per year to counties with permanent
collection facilities if the county contributes $3,000
in cash or services. Counties can select their own
waste hauler, although they are discouraged from
creating local fee schedules. All sites serve as
collection sites for businesses and very small
quantity generators. Many counties have found it
desirable to offer household hazardous waste
service at the same time they offer agricultural and
business service.
The method of collection can change over
time. For example, when North Carolina began its
program in 1980, state inspectors collected
pesticides from farm and home sites and transported
the material to storage facilities located throughout
the state. The material staged in the storage facilities
was consolidated at a central location in Raleigh,
where it was collected by a contractor. In January
1997, the state began to collect pesticides at both
designated single day events and at permanent
household hazardous waste collection sites. The
amount of pesticides collected annually has
increased since 1997. After 17 years of experience
with on-site pick up, North Carolina decided that
other methods are more efficient and effective, and
the state plans to use both the single day and
permanent site methods in the future.
Wisconsin expanded its collection methods
to reach new participants hi remote areas. The
location of permanent sites has posed a challenge to
the program because, contrary to expectations, few
farmers have been willing to drive wastes into cities.
Consequently, perrnanentfacilities have been
strongly encouraged to create satellite sites and hold
special "farm chemical collection weeks," which
have greatly improved collections.
21
-------
TABLE 5 Clean Sweep Methods of Collection by Program Category
Each cell contains (1) the number of states with the indicated collection method and (2) a
listing of those states
Collection Method
Single Day Events Only
Single Day Events and
Permanent Sites
Single Day Events and On-site
Pick-up
On-site Pick up Only
Single Day Events, Permanent
Sites, and On-site Pick up
Other Collection Arrangements'
(7) ID, MT.
ND. OH, SD,
TX. UT
(2) IA. KS
(5) GA, NV.
PA, TN. WA
(2) KY, VA
(3) MM. NC.
VT
(2)MI.WI
(9) CA. IL.
IN, ME, MA,
MS, NE. OR,
WV
(l)NJ
(DEL
(1)MD
12
(7) AL. CT.
HI. LA. MO.
NY. SC
(1) AR
(DCO
(2) NH. WY
(DRI
(DDE
Jumber
f States
Note: (1) The other arrangements are - MI: Permanent sites only; WI: Single day events, permanent sites and
multi-county collections; DE: Permanent sites and on-site pick up.
FIGURE 6 State Clean Sweep Methods of Collection
3 Single tlu\ e\enl\ di
nenn MIO
7 Single
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2.8 Do participants have to register
before the material is collected?
Twenty-six states require participants to
register with the state or contractor before
pesticides are collected. Seven other states
encourage pre-registration but do not require it or
require it only for certain quantities of material or
certain types of participants. Ten states do not
require pre-registration, including two that have
dropped the requirement in recent years.
Information on the requirement for pre-registration is
shown in Table 6 and Figure 7.
Registration is essential for on-site pick up
because the contractor has to know in advance how
many stops will be made and what quantities and
types of pesticide will be collected to determine the
number of trucks and personnel needed. For other
collection methods, such as single day events, pre-
FIGURE 7 State Requirements for Clean
Sweep Pre-Registration
26 Req.
k
3 Rt
-------
Section 2 Clean Sweep Program Operations
registration facilitates planning and helps ensure a
smoothly run event. When Clean Sweep program
managers can accurately estimate the amount of
material expected, the contractor can estimate the
amount of supplies and personnel required more
precisely and can assign appointment times to
prevent delays and back ups. In some states,
registration is neededforregulatory compliance.
For example, Washington and Oregon return the
approved registration form to participants, who then
use them as bills of lading for transporting the waste
to the collection site.
Registration has probably kept some people
from participating in Clean Sweep programs
because of concern about how the information might
be used by government regulatory agencies. Some
rural residents do not accept the program's
"amnesty" or feel that the term itself implies guilt on
the part of the participant. Registration only
provides an estimate of the amount to be collected
because participants may underestimate their stocks
or may bring a larger quantity of pesticides than they
registered. In addition, people who did not register
may show up. For example, Louisianareported that
pre-registration for its 1996 program was for 26
tons of pesticide, but the state collected over 201
tons. State officials attributed the large amount of
undeclared materials to a fear of punitive fines. A
faimer pre-registered 100 pounds of unwanted
pesticides in West Virginia's pilot Clean Sweep
program. When he realized it was truly an amnesty
program, the farmer provided an additional 5,000
pounds. Turning people away who do not pre-
register has major disadvantages. Such participants
may be discouraged after making the effort to get to
the event and may be tempted to dump the material
mdisdiminantly rather than toeontinue storingit.
Several states that originally required or
reqmestedpre-registration changed theirprocedures.
Minnesota, for example, dropped the requirement
when they determined that more than half of their
participants were walk-ins. Similarly, North Dakota
dropped their pre-registration requirement and
Floridano longer requests it.
2.9 How is the material disposed of?
The vastmajoriry of material collected is
disposed in high temperature hazardous waste
incinerators. Pesticides that cannot be incinerated
are sent to permitted hazardous waste landfills. For
example, mercury products collected in Colorado
were stabilized and landfilled. Leadarsenate,a
commonly collected pesticide, is landfilled in
permitted facilities. Seventeen states listed
incineration as their sole disposal method, and 15
states reported using both incineration and landfilling.
States make decisions about whether to landfill
certain pesticides on a case-by-case basis,
depending on the quantities involved, the state's land
disposal restrictions, and the hazardous waste
contractor's expertise.
Five states reported using a third disposal
method in addition to incineration and landfilling, but
these methods disposed of a very small percentage
of the total. For example, Illinois held three one-day
events in 1999. Of the 14,392 pounds of pesticides
collected at one event, 13,357 pounds were
incinerated, 505 pounds were landfilled and 530
pounds underwent wastewater treatment. At the
other two events, all of the pesticides collected were
incinerated except for four pounds which were
landfilled. Iowa has used some collected waste
material in fuel blending, and Wisconsinhas
reclaimed or reprocessed approximately 3 percent
of the pesticides collected. Itisnotclearfw/hpther
such infrequently used disposal methods are cost-
effective. BothBlinois and Tennessee reported that
they recycle products when possible, but Tennessee
estimated that less than 1 percent of the collected
pesticides are recycled. South Carolina provided
24
-------
some product to a cement kiln for fuel, but this
accounted for less than 0.2 percent of the annual
collection.
Information on the methods used by the
states to dispose of pesticides and other materials
collected at Clean Sweep programs is provided in
Table 7 and Figure 8.
2.10 Can usable pesticides be
exchanged or donated to a party
which needs or can use them?
When unopened, legally usable products are
collected, common sense suggests that it would be
better and more energy efficient to use them than to
dispose of them. Tactics employed to accomplish
this include product exchanges, redistribution tables
and recycling centers.
Programs to find a user for collected
pesticides must be well-planned and orchestrated,
with good advertising, strong local leadership and
on-site logistics management. Regulatory and
liability issues may pose barriers to exchange
programs when pesticides are transferred from one
owner to another. For example, many agricultural
products are restricted use products, which can only
be distributed to applicators certified to use them.
This means that before such products can be
exchanged, someone has to check credentials at the
collection event. Additionally, the age, efficacy, and
previous storage conditions of the pesticides are
often unknown, so there is no guarantee that a
TABLE 7 Clean Sweep Methods of Disposal by Program Category
Each cell contains (I) the number of states with the indicated disposal method and (2) a listing
of those states
Disposal Method
Incineration only
Incineration and landfill
Incineration, landfill, and other
methods
Incineration and out-of-state
facilities only
Landfill only
Information not available
Funded
Continuous Intermittent
(9)GA, KY.
MI. MM, MT,
|NV. ND. SD.
UT
(9) ID. KS,
NC, OH, PA.
TX. VT. VA,
WA
(3) IA. TN. WI
(6)CA. IN.
MD, MS.
MA. WV
(2) NE, OR
(1) IL
(1)ME
(2) NJ. FL
25
(DLA
(3) AL. AR,
CO
(DSC
(4) CT, HI.
MO, NY
(DWY
(DDE
(DRI
(1)NH
States
17
15
46
-------
FIGURE 8 State Clean Sweep Methods of Disposal
15 /mm. &latuifill
/mm tml\
5 /mm, land.. &
other
7 Info, nor avail.
1 Ijtntifill nnl\-
1 Incin. and oul-of-state fac.
Incineration only: 17 stales
Incineration and landfill: 15 stales
Incineration, landfill, and other methods: 5 states
Incineration and out-of-state facilities only: / mate
1 .iiiHlfill only: / state
Information not available: 7 states
pesticide's composition remains within the specifica-
tions of its registration. As a result, it may be
necessary to have recipients sign waivers or letters
ofunderstanding.
Despite these considerations, Kansas,
Kentucky, Nevada, Pennsylvania, Utah, Vermont,
and Wisconsin allow exchange, generally on a
limited basis. Texas has an exchange program for
household hazardous waste collections and tried
having a "swap shop" for pesticides in sealed,
unopened containers that were neither banned nor
restricted. Ohio has donated useable products.
Illinois attempted a swap program in 1994, but
discontinued it because the Department of Agricul-
ture found that contacting the appropriate people to
facilitate the exchange was very time-consuming. In
addition, Illinois determined there was considerable
uncertainty about the quality of the products and
concluded that most products were in need of
disposal. It is possible that other programs also
allow pesticide exchange on a case-by-case basis,
especially if containers are unopened.
2.11 What is involved with establishing
a contract between the lead agency
and a hazardous waste
management company?
State and local governments typically hire
hazardous waste management companies to handle
the pesticides in Clean Sweep programs. In nearly
all programs, the contractor provides all materials
and services for collection, including manifesting.
packaging, transporting and disposing of the
collected material. In many cases, the contractor
will collect pesticides at end-user locations if
containers are sufficiently deteriorated to make
transportation dangerous. The contractor may
assume all responsibility as the generator of the
waste and may hold the state harmless from any
claims.
Contracts include insurance such as
worker's compensation, general liability, and
pollution liability. Contractors maintain a health and
safety program and are responsible for obtaining all
licenses, permits, manifests and other documents
necessary for compliance with federal, state and
local regulations, including those established by the
Occupational Safety and Health Administration and
Department of Transportation and EPA's require-
ments under the Resource Conservation and
Recovery Act, Comprehensive Environmental
Response Compensation and Liability Act (com-
monly called Superfund). and Superfund Amend-
ments Reauthorization Act. Site set-up and
restoration at single day events are the contractor's
responsibility. In states that conduct on-site
collections at participants' sites, the contractor may
also commit to stabilizing and cleaning up contami-
nated soil around deteriorated containers. Some
waste management companies do on-site ''finger-
26
-------
The Clean Sweep Report
print" analyses, rapid field tests conducted to
identify a chemical by pinpointing certain of its
baselinephysical characteristics, such as flash point,
to determine compatibility of unknown chemicals.
Contracts can vary greatly among states, but a
sample contract is provided in Appendix m. Table
8 displays the unit costs for Minnesota's current
contract.
Table 8: Typical Charges in Minnesota's 1999-
2002 Contract
Activity
Planning assistance
Mobilization/demobilization '
Incineration of hazardous waste
Incineration of nonregulated,
nonbazardous waste
Fuel blending of hazardous,
nonregulated or ndnhazardous
waste
Incineration of compressed gas
cylinders
Incineration of F-coded dioxin-
bearing waste
Landfilling
Identification of unknowns
Short term storage ([ess than 10
days)
Long .term storage (more than 10
days)
Units
per person per hour
per mile per person
per net pound
per net pound
per net pound
each
per net pound
per net pound
per analysis
per drum per day
per drum per day
Cost ($)
$0.00
$1.68
$1.43
$1.43
$0.50
$750.00
$2.00
$0.12
$1,200.00
$3.00
$5.00
Note: (1) Fee for traveling to and from the site, setting up the Glean
Sweep event, and .dismantling. ' '
In 1997, North Dakota collected
agricultural chemicals andhouseholdhazardous
waste to help'Clean up damage caused by the Red
River flood. Table 9 lists costs for the collection,
packaging, profiling, transportation and treatment or
disposal of feeฉlectedmaterials>
States ha&e avariety of methods for
dispose of waste pesticides. For example,
Michigan's Department of Agriculture (DoA) does
not enter into any contracts, but counts on its 15
county grantees to initiate and manage the contracts
for household hazardous waste and Clean Sweep
collections. The grantees, usually county health
departments or occasionally landfill authorities, are
reimbursed for their disposal costs. Michigan's
strategy is a 3-way collaboration: Michigan DoA
pays for disposal, the local grantee initiates and
monitors the contract with a hazardous waste
management vendor, and the permanent sites were
established with EPA grants. While this system
saves the DoA from managing the contracts, the
main drawback to this strategy is price disparity,
with disposal costs ranging from $0.75 per pound to
$1.80 per pound from county to county. The largest
cost disparity is for mercury disposal, which ranges
from $1.50 to $12 per pound, prompting Michigan
DoA to consider establishing a state-wide contract
Table 9: Charges in North Dakota's 1997
Contract for a Combined Household
Hazardous Waste and Clean Sweep Program
Activity
Mobilization '
Agricultural chemicals and
household chemicals
Household lab packs 2 for
incineration or landfill
Household reactive lab packs 3
for incineration
Motor oil
Antifreeze
Lead-acid batteries
Minimum contractual fee
Units
, not applicable
per net pound
per net pound
per net pound
per gallon
per gallon
each
not applicable
Cost ($)
$28,000
$1.90
$2.60
$6.80
$1.00
$2.00
$2.50
$85,000
Notes: (1) Fee for traveling to and from, the site, setting up
the Clean Sweep event, and dismantling. (2) Overpack
drums that hold small containers of non-reactive household
waste. (3) Overpack drums holding small containers of
household waste that show the RCRA hazardous waste
characteristic of reactivity.
27
-------
'-'roqran
for mercury alone. The three most active counties
(of 15 permanent sites) also run annual satellite
collections in areas which are distant from the
permanent centers.
Minnesota's strategy differs from
Michigan' s in that the state contracts directly with
the waste management company and is able to use
its services at any time, not only for scheduled
collection events, but also for special runs as
needed. Minnesota uses the same contractor for
Clean Sweeps and household hazardous waste
(HHW) collections and saves money because both
kinds of waste are collected at the same time and
there is only one mobilization fee. Minnesota has
learned that it is advisable to include a clause that
allows the parties to extend the contract after 1,2 or
3 years. If legally acceptable, this saves the
considerable time and effort involved in rebidding a
contract, particularly when the contractor is
performing well.
2.72 Which hazardous waste
management companies have been
or are actively involved with Clean
Sweep programs?
A limited number of contractors have been
involved with Clean Sweep programs because
hazardous waste vendors must have specialized
knowledge, experience and equipment and must bid
competitively for the state and county government
contracts. Thefollowing companies arelistedfor
informational purposes only. No endorsement of
any company is implied, and other companies are or
may soon be entering the field. In addition, the fact
that a contractor has been awarded contracts for
several years does not guarantee that the contractor
will continue to maintain quality control and win
future contracts. States have used the following
contractors:
AdvancedEnvironmentalTechnical Services
Care Environmental Corporation
Clean Harbors Environmental Services
ENSCO Services
HAZ-M.E.R.TInc.
Heritage Environmental Services, LLC
LWD,Inc.
MSEEnvironmental
Onyx Environmental Services
Philip Services Corporation
Safety-Kleen (Columbia, SC).
Addresses, phone numbers and websites for
these firms are provided in Appendix IV. These
companies can provide a starting point for states
wishing to identify potential hazardous waste
contractors, the types of services they offer and their
locations.
2.13 How can states reduce disposal
costs and improve program
efficiency?
The methods of collecting, identifying and
packing waste pesticides greatly impact the
operating costs and efficiency of Clean Sweep
programs. For example, a decision to move wastes
to an incinerator versus stabilizing them and sending
them to a landfill could increase disposal costs by a
factor of three to five. Similarly, costs can easily
double if a large number of partially filled metal
containers are lab packed rather than decanted.
Lab packs are o verpack drums that contain small
containers of waste.
A Clean Sweep program manager's ideas for
reducing program costs and improving
efficiency2 are summarized below. Many of the
administrative strategies require considerable
coordination and planning between the manager and
2 This discussion is based on presentations by Roger Springman, Wisconsin Department of Agriculture, Trade and Consumer Protection,
at the 1997 and 1998 Conferences of the North American Hazardous Materials Management Association.
-------
I he Clean S'-sio j-'&pcr;
the waste hauler and a level of sophistication which
is difficult to achieve with short-term contracts.
Chemical Waste Handling Strategies
Bulking. Bulking is most commonly applied to
paints and other general-purpose solvents, thinners
and cleaners, but can also be applied to pesticides.
When sufficient quantities of aqueous herbicides are
present, the waste hauler can begin herbicide
bulking, which reduces costs by nearly 50 percent
compared to lab packing. Another common
procedure is to move smaller quantities of
"bulkables" (products collected in high quantity and
which can be easily consolidated) to central
locations from satellite sites. Although a
considerable amount of insecticides are generated at
Wisconsin Clean Sweeps, the fumes associated with
insecticide bulking may create safely concerns.
Fuelblending. Diesel fuel, solvents, flammable
paint and old gas, which are occasionally brought to
waste collections, have monetary value to waste
haulers as fuel for incinerators and cement kilns.
Pricing credits may be given for these materials
based on their chemical characteristics (e.g., halogen
and sludge contents).
Cylinder bubbling. Greenhouses, nurseries, and
certain horticultural operations often have older, low
pressure insecticide andfumigant cylinders for
disposal. Since disposal costs can be $800 or more
per cylinder, this is one of the most expensive waste
streams at Clean Sweeps. Bubbling involves
releasing cyHnder contents underwater, usually in a
five-gallon bucket. The resultant waste stream can
typicaiyfitthepiofileofallqiidd-^poison, thereby
Kedifeing disposal costs by as much as 70 percent.
is absolutely eertainand whennotpjohibited (as
"HearmeMt")
-------
ection 2 Clean Sweep Program Operations
Waste stream -vs. lab pack option. How wastes
are initially defined for regdatorypurposes affects
what rules, paperwork and transportation options
apply. Accordingto49CFR 173.12b,chemicals
of the same DOT hazard class that meet certain size
or quantity limits may be placed into a specified
shipping container with the resultingmanifesting
requirements. However, if these same chemicals are
considered a "waste stream," drum inventory is no
longer necessary and some additional paperwork
and technical demands can be reduced, saving 5 to
10 percent in labor.
Use of the Universal Waste Rule. As discussed in
section 4.2, the Universal Waste Rule gives
managers and waste haulers aregulatory option that
can reduce paperwork and handling costs.
Joint program sponsorship. If programs are seen
as being sponsored by only one agency, it may be
hard to seek cooperative approaches. States have
overcome local sponsorship barriers by providing
financial incentives, such as reduced cost-share fees
andmobilizationfeesfor counties working together
in jointorrnobile collections. Michiganis amongthe
states thatfbund a suitable partner in industry when
looking for a collection site. By enlisting the
cooperation and sponsorship of a large Grower's
Cooperative, the state was able to establish a
permanent collection site.
Pre-registmtion. One way to facilitate good
decision-makingisthroiighpre-registration. Early
knowledge aboutthe types and quantities of
pesticides to be collected allows program staff and
waste haulers to estimate the level of resources
needed and to identify alternative management
options.
Vendor selection. Waste haulers must meet high
efficiency standards to run a suceessfulprogram.
Consequentiy,itisimportantfor program managers
to have a responsive vendor or to employ
contracting strategies that allow rapid adjustments
(e.g., annual contracting or performance-based
contracts). The price, indicated by the disposal cost
per pound and the mobilization fee, is one indicator
of efficiency, although expressing efficiency in dollar
figures only hides many importantnon-monetary
values. Vendor commitment, vendor service
abilities, liability protection, and vendor end-site
control should be as important as price when
selecting a contractor.
The effectiveness of contracts in responding
to efficiency demands depends largely on the extent
to which the vendor is made a partner in the
collection process. If the vendor is viewed as an
' 'outsider," there will likely be less incentive for
change. Strategies that build incentives or that view
vendors as partners are usually more successful.
The following questions canbe used for efficiency
evaluations:
Whatincentives arebuiltinto the contracting
process, including Requests for Proposals and
Requests for Bids, to encourage waste haulers
to lower costs and improve efficiency while
maintaininghighcustomer satisfaction?
Does the contracting process "test the
marketplace" across a wide range of
competitors?
How frequently do sponsors, program
management staff and waste hauling staff meet to
discuss contract compliance and efficiency
issues, and what happens as a result of these
meetings?
Whatlegal and administrative changes are
needed to give program managers and sponsors
more options in dealing with vendor selection,
contract compliance and program efficiency
concerns?
30
-------
Section 3 Clean Sweep Program Results
3.1 How many and what type of Clean
Sweep programs have been
implemented?
All but four states - Alaska. Arizona. New
Mexico and Oklahoma - have conducted at least
one Clean Sweep program. This report compiles
the information by state even though counties in
some states, such as New York and New Jersey.
conduct the programs. EPA is unaware of any
Clean Sweep programs implemented by tribes or
territories. As stated in section 1.6. EPA has
classified state programs into five categories. The
categories, which reflect the frequency or perma-
nency of the program, are permanently funded,
continuous, intermittent, one-time, and never. The
states in each category are identified in Figure 9.
Permanently funded: Twenty-one states have
continuous programs which are permanently funded.
A continuous program is defined as one that has
been implemented for at least three consecutive
years. Permanent funding is defined as a mechanism
that is reliable, consistent and in place year after
year, e.g., using a portion of state pesticide
registration fees, access to a fund that pays for clean
up programs, or consistent state appropriations.
Continuous: Twelve states have continuous
programs, meaning a program that has been
implemented for at least three consecutive years that
docs not have permanent funding. Although
continuous means "w ithout interruption." a program
may still be classified as continuous even if it
occasionally skips a year. Of the twelve
continuously funded states, ten have active
programs, that is. they have been implemented for at
least three years in a row and carried out a Clean
Sweep program in 2000 or 2001. Two of the
twelve continuously funded states have inactive
programs, because they did not conduct a program
in 2000or2001.
Intermittent: Nine states have programs which are
not continuous but which have held more than one
collection event. There are four active programs (in
2000 or 2001) and five inactive programs.
One-time: Four states have programs which have
held one collection event. All of these events were
held in 1990 or 1992.
Never: Four states have no existing program and
have never held a collection event.
State Clean Sweep Programs by Category
Permanently funded programs: Georgia, Idaho, Iowa, Kansas, Kentucky, Michigan, Minnesota. Montana.
Nevada, North Carolina, North Dakota, Ohio, Pennsylvania. South Dakota. Tennessee, Texas. Utah,
Vermont. Virginia. Washington, Wisconsin
Continuous programs: California, Florida. Illinois, Indiana. Maine, Maryland, Massachusetts, Mississippi,
Nebraska, New Jersey, Oregon, West Virginia
Intermittent programs: Alabama, Arkansas, Colorado, Connecticut, Hawaii, Louisiana, Missouri, New
York, South Carolina
One-time programs: Delaware, New Hampshire, Rhode Island. Wyoming
Never held a program: Alaska, Arizona. New Mexico, Oklahoma
31
-------
to
FIGURE 9 State Clean Sweep Programs by Category
| Permanently Funded -
continuous program tor at least
three consecutive years with
permanent funding
| Continuous - continuous
program for at least three
consecutive years without
permanently funding
| Intermittent - not continuous.
hut slate has held more than
one collection event
One-time - state has held a
single collection event
No programs
-------
North Carolina held the first Clean Sweep
program in 1980. Iowa. Maine and North Dakota
followed with programs in the early eighties. These
states recognized early on that farmers were
accumulating unwanted pesticides and that, without
an affordable method of proper disposal, the states
faced risks from contamination by these unwanted
pesticides. Other states initiated Clean Sweeps and,
as shown in Figure 10, the number of states with
Clean Sweep programs increased rapidly from the
late 1980s to the mid 1990s. Since 1995. the
number of states with programs has remained
relatively constant, ranging from 30 to 34 states.
The number of states with permanently funded
programs has followed a similar pattern. There was
a quick increase in the first half of the 1990s with a
steady but slower increase from 17 to 21 states
since 1995.
One measure of a program's success is
longevity. Figure 11 identifies the 22 states that
have operated Clean Sweep programs for at least
seven years. In addition. Table 10 lists program
information for each state, including the category,
active or inactive status, year of its first collection,
numberof years of collection and, for permanently
funded and continuous programs, the year it
achieved that status.
3.2 How many pounds of pesticides
have Clean Sweep programs
collected?
Based on the data states have reported to
EPA, it is estimated that Clean Sweep programs
have collected over 24 mi 1 lion pounds of unwanted
pesticides from 1980 through 2000.
FIGURE 10 Number of States with Clean Sweep Programs per Year
35
30
32 3
3 3,
32
30
18
18
20
20
21
Pre8686 87 88 89 90 91 92 93 94 95 96 97 98 99 00
Year
All Programs
Permanently funded programs
33
-------
Section 3 Clean Sweep Program Results
FIGURE 11 States with Clean Sweep Collections for at Least Seven Years
Each truck represents an annual collection "
Annual Collections
34
-------
The Clean Sweep Report
TABLE 10 Status of State Clean Sweep Programs
State
AL
AK
AZ
AR
CA
CO
CT
DE
FL
GA
HI
ID
IL
IN
IA
KS
KY
LA
ME
MD
MA
Ml
MN
MS
MO
Category1
Int.
None
None
Int.
Cont.
Int.
Int.
Once
Cont.
Perm.
Int.
Perm.
Cont.
Cont.
Perm.
Perm.
Perm.
Int.
Gont.
Cont.
Cont.
Perm.
Perm.
Cont.
Int.
Year
Category
Achieved2
n/a6
n/a
n/a
n/a
1989
n/a
n/a
n/a
1995
1998
n/a
1993
1998
1992
1991
2000
1995
n/a
1996
1995
1998
1990
1989
1999
n/a
First
Year*
1994
n/a
n/a
1992
1989
1995
1990
1992
1995
1995
1987
1993
1990
1990
1986
1996
1991
1990-
1982
1995
1990
1990
f 1989
1994
1990
Number
of
Years4
4
n/a
n/a
2
10
4
3
1
5
6
2
8
7
9
14
5
7
2
9
5
4
11
12
7
3
Status5
Active
n/a
n/a
Active
Inactive
Active
Inactive
Inactive
Active
Active
Inactive
Active
Active
Active
Active
Active
Active
Inactive
Active
Active
Active
Active
Active
Active
Inactive
State
MT
NE
NV
NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
Rl
SC
SD
TN
TX
UT
VT
VA
WA
WV
Wl
WY
Category
Perm.
Cont.
Perm.
Once
Cont.
None
Int.
Perm.
Perm.
Perm.
None
Cont.
Perm.
Once
Int.
Perm.
Perm.
Perm.
Perm.
Perm.
Perm.
Perm.
Cont.
Perm.
Once
Year
Category
Achieved
1994
1998
1995
n/a
1985
n/a
n/a
1986
1992
1993
n/a
1991
1993
n/a
n/a
1993
1998
1992
1993
1996
1992
1988
1994
1990
n/a
First
Year
1994
1995
1995
1990
1985
n/a
1993
1980
1980
1993
n/a
1991
1993
1990
1988
1993
1998
1992
1993
1991
1990
1988
1994
1990
1992
Number
of
Years
6
4
6
1
12
n/a
5
18
12
8
n/a
10
8
1
2
8
3
9
8
6
10
13
5
11
1
Status
Active
Active
Active
Inactive
Active
n/a
Active
Active
Active
Active
n/a
Active
Active
Inactive
Inactive
Active
Active
Active
Active
Active
Active
Active
Inactive
Active
Inactive
1 The program categories are permanently funded (Perm.), continuous (Cont), intermittent (Int.), one-time (Once) and never
(None)
2 The year the category was achieved applies only to permanently funded and continuous programs. It represents the
year the state received permanent funding or, for continuous programs, the first of the three or more consecutive
years.
3 The first year is the year of the state's first collection.
4 The number of years is the number of years that pesticides were collected.
5 Sitatus represents whether the state collected pesticides in 2000 or 2001. All permanently funded programs are
active and all one-time programs are inactive. Continuous and intermittent programs can be either.
6 n/a ='not applicable.
-------
Section 3 Clean Sweep Program Results
Several factors make it difficult to precisely
record the amount of pesticide collected. There is
no uniform method of recording the data, and there
is variation on how states characterize partially full
containers, especially drums. Some programs only
report round numbers, which are probably
estimates. Some states report on a calendar year
basis, while others report on a fiscal year basis.
When liquids are collected, their volume in gallons is
often reported, while solids are reported by their
weight This report converts quantities of liquids
from gallons to pounds by estimating 9 pounds to
the gallon, a close approximation but not accurate
for all liquids. Some programs use a conversion
factor of 10 pounds per gallon and these amounts
were not recalculated. In addition, some states limit
collections to farmers, while others include
residential pesticides or all household hazardous
waste. In states where collection events are run on
a county level, state officials may not have complete
data. Information from older collection events may
be missing or inaccurate. In spite of these caveats,
EPA believes the overall total of about 24.6 million
pounds and the totals for individual states are good
indications of the minimum amounts collected, and
are probably underestimates. Table 11 shows the
amount of pesticide collected per state, per year
from 1980 througb.2000.
While24millionpoundsis asignificant
amount, it is important to compare this quantity to
the amount of pesticides used. This analysis
indicates that the amount of pesticides collected and
disposed by Clean Sweep programs is significantly
in the U.S. Only a small proportion of pesticides
sold become obsolete or unwanted. The Clean
Sweep challenge is to collect and dispose of these
pesticides.
EPA estimates that917 to 1,025 million
pounds of active ingredientin conventional pesti-
cides were used in 1997.' Agricultural products
comprised approximately three-quarters of the
conventional pesticides (which also include home
and garden andindustry/commercial/govemment
pesticides), so approximately 750 million pounds of
active ingredient in agricultural products was used
annually during this time period. Because the
amount of active ingredient can range from less than
1 percent to over 80 percent of a formulated
product, the total weight of formulated agricultural
pesticides used per year is much greater. The most
common agricultural products are from 10 percent
to 50 percent active ingredient, which means that
approximately 1,500 million to 7,500 million pounds
(1.5 to 7.5 billion pounds) of formulated agricultural
products were used per year hi 1997. Assuming
thatthis amount of formulated agricultural pesticides
was used each year for the past 40 years, approx-
imately 60 to 300 billion pounds of formulated
agricultural pesticides have been used in the U. S.
over the past four decades. EPA chose 40 years
because many of the pesticides collected at Clean
Sweep events since 1980 are years or even
decades old. Therefore, the 24.6 million pounds of
formulated pesticides collected and disposed by
Clean Seep programs through 2000 is a small
fraction - 0.008 percent to 0.04 percent - of the
estimated quantity of formulatedpesticides used
during that same period.
1 U.S. EPA, Pesticides Industry Sales and Usage: 1996 and 1997 Market Estimates, November 1999.
36
-------
Table 11 Total Amount of Pesticides Collected by Clean Sweep Programs Each Year (in pounds)
State
AL
AK
AZ
AR
CA
CO
CT
DE
FL
GA
HI
ID
IL
m
IA1
KS
KV
LA
ME1
MD
MA
MI
MN
MS
MO
MT
NE
NV
Pre '86
10,835
30,000
1986
12.000
1987
12,471
1988
33,305
1989
87,820
5,000
77,480
44,000
32,400
1990
128,000
16,200
13,000
8,800
18,810
5,000
86,300
84.000
34,100
800
1991
188,380
6,550
49,772
50,600
84,000
35,800
1992
5,000
336,668
30,423
4,300
180,574
64,000
53.800
1993
157,514
30,861
6.000
230,923
84.000
135,300
1994
71,154
1.082
13,090
27,263
9,000
66,486
84,000
183,300
22,970
13,197
1995
55.246
137.384
17,000
6,900
70,000
5,000
43,668
107,727
8,064
51,912
8,700
33,368
60,000
236,500
257,621
14.506
595,541
14,647
1996
1 10.502
23,000
18,600
36,800
40,474
1,900
58,218
96,942
52,500
403,200
6,900
14,889
120.000
208,500
167,617
6,000
64,224
10,653
1997
33,910
6,400
25.600
43,760
5,164
83,320
46,197
43,800
9,025
13,433
63,940
283,800
153,463
3,000
26,335
17,058
1998
20,135
27,000
128,876
35,855
26,610
8.078
84.240
19,235
37,460
8,000
20,846
38,975
52,682
298,800
214,433
21,774
297,701
18,418
1999
50,344
19,343
17,755
373,851
36.436
55,586
103.709
40,975
50.836
7.062
4,454
21,840
59,281
410.718
23,623
249,065
4.986
2000
12,649
30,689
15.833
170.929
207,905
78.460
15.580
16.841
80.971
134.106
34.471
3,222
11.874
96,215
123,362
150.159
39,150
193,726
8.802
Total
189,393
0
0
35,689
1,186.828
84.498
46,100
30.423
292,929
778.032
17.471
322,604
252,316
68.147
1.130,555
337.455
278.367
408.200
120,209
86.990
158,989
852.118
2.036,380
989,886
9,800
179,186
1,336,033
74.564
rr
ct>
O
ro
0)
3
CO
CD
"D
!'ง
-------
Table 11 Total Amount of Pesticides Collected by Clean Sweep Programs Each Year (in pounds)
00
State
NH
NI
NM
NY
NC3
NDซ
OH
OK
OR
PA
RI
SC
SD
TN
TX
UT
VT
VA
WA
WV
WI
WY
Total
# states
Pie '86
39,809
17.800
98,444
4
1986
1.400
13,400
2
1987
132,729
145.200
2
1988
31,890
10.460
6,743
49.343
131.741
5
1989
10.535
29.120
13,740
400
35,212
335,707
10
1990
20,000
19,850
51,055
some
31,797
62,576
39,100
619,388
17
1991
15,841
32,708
59,776
17,900
86,724
9,622
637,673
12
1992
22,014
70,444
80,910
58,742
394,560
57,237
81,683
84,170
16.000
1.540,525
16
1993
39,741
13,860
26,467
9,000
95,773
29,700
31,059
678,460
11,453
68.146
55.581
143,558
1,847,396
18
1994
109.915
51.403
131.838
113,000
22,072
60,133
43,757
276,720
17,487
222,374
88,734
112,000
107,526
1,848,501
23
1995
88,798
59,300
100,980
48,222
126,000
56,096
82,084
23,867
133,040
14,095
62,156
51,526
60,000
158,087
2,788,035
32
1996
115,159
120,724
59,825
94,389
251,250
25,906
300,293
31,086
469,200
13,334
4,363
75,931
81,081
18,688
172,034
3,274,182
33
1997
137,648
81,045
174,275
214,600
69,206
174,048
50.282
277.960
18,903
3,640
74,271
101,895
17,500
240,499
2.493,977
30
1998
95,362
123,211
131,709
142,374
30,056
188,110
28,283
100,000
264,840
26,244
3,125
47,918
93,714
31,242
165,011
2,830,317
33
1999
52,459
24,610
133.313
158,938
123,390
67,017
86,189
23,069
100,000
551,380
17,145
8,925
97,618
152,237
150,388
3,276,542
32
2000
15,425
960
151,078
166,949
109,099
12,799
81,040
32,260
100,000
103,660
26,600
28.000
81,351
139,453
254,000
2.727,618
34
Total
20.000
722.747
0
219,454
1,116,477
1,029,230
1.088,713
0
497,443
1,001,597
some
7,143
263.663
300,000
3,149.820
145.261
65,953
818.799
1,079,759
239,430
1,523,995
16,000
24,608.646
46
*
ป*
o'
w
O
5"
OJ
3
ฅ
8
TJ
5
(Q
3
-------
Figures 12 and 13 track annual pesticide
collections and cumulative collection totals over
time. A relatively small amount of pesticides was
collected through 1991 -about 2.0 million pounds,
or 8.1 percent of the total. Since 1992, at least 1.5
million pounds of pesticides have been collected
each year and the annual total averaged almost 2.9
million pounds between 1995 and 2000. Variation
in the annual totals generally mirrors the variation in
the number of Clean Sweep programs each year,
shown previously in Figure 10.
FIGURE 12 Amount of Pesticides Collected per Year
3.500,000
3.000,000
, 2,500,000
"g
| 2,000,000
1,500,000
1,000.000
500.000
0 I
Pre-8787 88 89 90 91 92 93 94 95 96 97 98 99 00
Year
FIGURE 13 Cumulative Amount of Pesticides Collected
25.000,000
20.000.000
ฃ. 15.000.000
10.000.000
5.000,000
Pre8787 88 89 90 91 92 93 94 95 96 97
Year
99 00
Figure 14 displays the amount of pesticides
collected by states in each category. The 21 states
with permanently funded programs have collected
more than 71 percent of the nationwide total of
pesticides, primarily because they have the most
extensive programs and assured funding. Together.
they have conducted over 61 percent of the annual
collections.
FIGURE 14 Cumulative Clean Sweep
Collections by Program Category
(Quantity' in Pounds)
17,572.528
66.423
1.017.748
5.951.947
I j Permanently Funded:
Continuous:
Intermittent:
One-Time:
1 '7,572,528 pounds
5,951,947 pounds
1,017,748 pounds
66,423 pounds
71.41",,
24.19%
4.14%
0.27%
Through 2000,11 states have collected
more than one million pounds of pesticides, and
these states are shown in Figure 15. Two of these
states, California and Nebraska, have continuous
programs while the others have permanently funded
programs. As shown in Figure 16, the states that
have collected over one million pounds - 22
percent of the states - have collected almost 64
percent of the national total.
Figure 17 presents information on the
amount of pesticides collected by each state.
39
-------
FIGURE 15 Amount of Pesticides Collected by the States with More Than One Million Pounds
Each drum represents 100,000 pounds collected
Texas
Minnesota
Wisconsin
Nebraska
California
Iowa
North Carolina
Ohio
Washington
North Dakota
Pennsylvania
ฃ E E E;E E E S E'E & E E E:E S E
C3 ^-< ~ ' ^- .' - t_* ^3 . .- .. ^.. '_ ~_^ L^ i ^ -_ L_^ !
ES C3'{S ^5 ^3 ^ฃ ^3<1S S ฃS S tzi
tr B
^^ ซ7g ^ff t^.ti* ^9 ^^
t: E E E:5 iE i,mt,,82x
t: E E Sit; t i.uo.sss
! I 1,116,477
1,088.713
1,079,759
E E E E E:E E E E E;E 1.029,2311
i mill
2,036,380
3,149,820
I I I I I I I
500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000
Pounds Collected
Total Amount Collected - 15,679,387pounds
FIGURE 16 Amount of Pesticides Collected by Selected States through Year 2000
Eleven states that have collected more than one million pounds of pesticides each
D Remaining states
15,679,387 pounds
63.77< of total
8.929.259 pounds
36.3% of total
40
-------
FIGURE 17 Quantity of Pesticides Collected by State
I 1 million pounds or more
(11 states)
|Between4()(),()()Oand
999,999 pounds
(7 states)
| Bet ween 100,000 and
399,999 pounds
( 14 stales)
j Less than 100,000 poun
(18 states)
-------
3.3 How many pounds of pesticides
are collected from each participant?
States beginning or restarting Clean Sweep
programs frequently ask EPA, "How many people
participate and how much pesticide do they bring to
collections?" States want to know the experiences
of other states in order to estimate how much will be
collected in their own. The number of participants
and the quantities collected have a direct impact on
the number of people and resources the state and
the contractor must mobilize for the collection.
Direct comparisons between states are difficult
because the kinds of participants vary from state to
state. For example, states which allow participation
by businesses other than farmers may collect larger
quantities per participant than states which include
household participants.
Thirty-one states reported the number of
participants in at least some of their collection
events. As shown in Table 12, the average amount
collected per participant in nearly three-quarters of
these states was between 101 pounds and 400
pounds. Eleven states, 35 percent of the states with
information, collected an average of between 301
Table 12: Average Quantity of Pesticides
Collected Per Participant
States
11
ides Collected
articipant
Less than 100 pounds
Between 101 pounds and 200 pounds
Between 201 pounds and 300 pounds
Between 301 pounds and 400 pounds
Between 401 pounds and 500 pounds
Greater than 500 pounds
and 400 pounds per participant. Appendix V
includes comprehensive tables showing data on the
number of participants and the quantity collected per
participant by state.
Figure 18 shows the average quantity of
pesticides collected per participant i n Texas,
Virginia, Washington and Wisconsin from 1988 to
2000. These states were chosen because partici-
pant information was available for at least 10 years.
In addition, these states represent a reasonable
FIGURE 18 Clean Sweep Quantity (pounds) per Participant for Selected States
v 1400
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
Washington
Texas
Wisconsin
Virginia
42
-------
cross section of the range in average amounts per
participant.
3.4 Which pesticides are collected at
Clean Sweep programs?
Most pesticides sold in the U.S. have shown
up at Clean Sweep collections. Canceled
pesticides, some of which have not been sold in the
U.S. for decades, such as DDT and mirex, continue
to be collected along with currently registered
products. For example, 2,4-D, a widely used
herbicide, is one of the most commonly collected
pesticides. Some currently registered products are
brought in because they are old, deteriorated or
damaged, but others are still usable and are
unwanted for a variety of reasons, such as the
owner has died, ceased farming, or decided to use
other pesticides or grow different crops.
Some states track andreport the individual
pesticides collected, which is discussed in more
detail in Sections 4.6 and 4.7. Minnesota and
Virginiahave comprehensive data on the amount of
individual pesticides collected oyer the life of their
programs. Minnesota has tracked 55 pesticides
every year since 1988.
Table 13 lists the quantity of these pesticides
collected between 1988 and 1998 and the percent
this represents of all pesticides. The table also
indicates which of the pesticides are still registered,
which are considered hazardous waste when
disposed, and which are PBTs or organophosphate
(OP) pesticides.
From 1988 through 1998, Minnesota
collected almost 95,000 pounds of the Level 1
persistent^ bioaccumulative and toxic (PBT)
pesticides listed in section 1.2, specifically aldrin,
chlordane, DDT, dieldriii, mirex and toxaphene.
Minnesota also collected nearly 65,000 pounds of
the potentially dioxin-containing pesticides -
pentachlorophenol, 2,4,5-T, Silvex, Ronnel and
other dioxin materials - during this time period.
These two categories represent more than 10
percent of all pesticides collected between 1988 and
1998, with the Level 1 PBTs at 6.3 percent and the
potentially dioxin-bearing pesticides at 4.3 percent.
Tracking the quantities of organophosphates
collected may enable regulators to gauge one of the
impacts of the Food Quality Protection Act
(FQPA). FQPA requires EPA to reassess all
tolerances established before August 3,1996. EPA
has placed the organophosphates in the highest
priority group for reassessment, since they appear to
be among those pesticides which pose the greatest
risk due to both their toxicity and multiple routes of
exposure from application to ingestion of residues
on food. Organophosphates account for about half,
by amount sold, of all insecticides used in the U.S.
Cumulative and aggregate risk assessments are
being done on organophosphate insecticides due to
their common mechanism of toxicity, and EPA
continues to evaluate them for reregistration
eligibility.
Eight of the 55 pesticides that Minnesota
tracks are the following organophosphates:
malathion, chlorpyrifos, diazinon, phorate, terbufos,
fonofos,parathionanddisulfoton. A total of
104,601 pounds of these organophosphates were
collected between 1988 and 1998, about 7 percent
of all pesticides collected.
The VirgjniaDepartment of Agriculture and
Consumer Services maintains a database of the
quantities of individual pesticides registered by
participants in their Clean Sweep program. Virginia
collects pesticides from participants' sites, soitis
essential for participants to register with the state
and report detailed information about the quantity
andidentity of the individual pesticides. The
43
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Table 13 Specific Pesticides Tracked in Minnesota's Clean Sweep Programs 1988 -1998
A indicates that the pesticide is currently registered, a hazardous waste when disposed, a persistent, bioaccumulative and toxic (PBT) chemical, or an organophosphate (OP).
Pesticide
2,4-D
lachlor
DDT
atrazine
trifluralin
malathion
>entachlorophenol
carbaryl
2,4,5-T
lyrethrin
chlorpyrifos
arsenic
chloramben
cyanazine
BPTC
chlordane
dalapon
)endimethalin
indane
dinoseb
jropachlor
'lyphosate
carbofuran
diazinon
toxaphene , ^
captan
carboxin
triallate
Weight
(pounds)
141,834
83,816
52,653
52,501
44,195
34,859
31,211
28,629
27,956
27,409
24,074
22,802
22,619
20,047
19,427
19,357
18,683
17,771
17,603
16,999
16,561
16,110
16,069
153848
15,519
; ^15,5 is
13.522
13,047
% of All
Pesticides
9.44
5.58
3.50
3.49
2.94
2.32
2.08
1.91
1.86
1.82
1.60
1.52
1.51
1.33
1.29
1.29
1.24
1.18
1.17
1.13
1.10
1.07
1.07
1.05
1.03
1.03
0.90
0.87
Currently
Registered
__,
Haz Waste
when
Disposed
PBT
*
*
OP
Pesticide
propanil
metolachlor1
sodium TCA
jarban
dicamba
maneb
methoxychlor
MCPA
thiram
phorate
ethalfluralin
terbufos
fonofos
mercury
carbon tetrachloride
aldrin
parathion2
dieldrin
leptachlor
disulfoton
Silvex
ronnel
formaldehyde
aldicarb
endrin
bendiocarb
other dioxin
materials
ALL PESTICIDES
Weight
(pounds)
12,724
12,470
12,427
11,872
11,016
10,980
10,864
9,798
9,194
9,170
8,430
7,114
6,763
6,626
5,555
4,195
3,755
3,142
3,101
3,018
3,014
2,506
2,384
2,373
1,729
1,404
103
1,502,300
% of All
Pesticides
0.85
0.83
0.83
0.79
0.73
0.73
0.72
0.65
0.61
0.61
0.56
0.47
0.45
0.44
0.37
0.28
0.25
0.21
0.21
0.20
0.20
0.17
0.16
0.16
0.12
0.09
0.01
Currently
Registered
V
Haz Waste
when
Disposed
PBT
*
*
*
OP
CD
O
o'
3
co
O
CO
3
W
1
"O
TJ
3
(Q
(A
Notes: (*) Dioxins are Level 1 PBTs, and the pesticides 2,4,5-T, Silvex, pentachlorophenol and ronnel potentially contain dioxins, although these pesticides ate not listed as Level 1 PBTs per se.
(1) The original registrant for metolachlor is no longer supporting its registration, and it is uncertain whether an alternative registrant will be granted registration. S-metolachlor, an enriched S-isomer
of metolachor, was registered in 1997 for the same uses as that of (racemic) metolachlor, and is currently registered.
(2) Cancellation order effective September 13,2001. Use of existing stocks of end-use products will not be lawful under HFRA as of October 31,2003.
-------
"hi Clean 3'!-,
registered amounts in the database are only
estimates, so the total does not match the total in
Table 11. This information still provides a good
indication of the relative amounts of the specific
pesticides that are collected and disposed of in
Virginia. Table 14 lists information on the amounts
of the 57 most common pesticides registered for
disposal in Virginia from 1992 through 2000.
Table 14 lists the 57 pesticides with the
largest volumes in Virginia's database. Out of these
most commonly registered (and mostly likely
collected) pesticides, there were:
42,460 pounds of the Level 1 PBTs,
representing 7.8 percent of all pesticides in
Virginia's database;
12,311 pounds of potentially dioxin-containing
pesticides, 2.3 percent of the total; and
41,713 pounds of organophosphate
insecticides, 7.7 percent of the total.
3.5 What are the safety requirements
and procedures of Clean Sweep
programs?
According to information provided to EPA
by the states, Clean Sweep programs have
maintained an excellent safety record. This is
particularly impressive considering the large quantity
of pesticides transported and collected and the fact
that some, but certainly not all, pesticides were in
old or damaged containers. For example, Ohio's
report noted that in over 20 projects with 2,865
participants, there were no accidents. Illinois
similarly reported no accidents or spills in their 1999
and 2000 reports. EPA believes that this success is
due directly to the diligence and competence of state
employees and contractors. Many states provide
guidance, either on their website or in the form of
printedfact sheets, on safe participation in Clean
Sweeipprograms.
Several states provide materials to facilitate
the safe handling of pesticides. For example,
Mississippi, Utah and Washington distribute
overpack drums to participants who request them in
advance. Overpack drums can be filled with
containers in poor condition to assure safe transport
to the collection event. Idaho, North Dakota,
Oregon, Tennessee and Washington distribute bags
and other overpack materials. A number of states
require training for the handlers, volunteers and state
employees who will be involved in the collection
event, and three states (Massachusetts, New York
and Tennessee) require participants to participate in
pre-eventtraining.
The guidance for participation in Clean
Sweep programs provided on the web sites of
Texas, Idaho and Washington is particularly user-
friendly and is presented in the form of questions
and answers. Questions include:
How do I register for a collection in my area?
What products are accepted?
How should I store my pesticides?
How do I dispose of my empty pesticide
containers?
What can I do to prevent a pesticide from
becoming a waste?
How should I transport waste materials?
Whatifldon'tknowwhatsomeofmy
pesticides are?
Are there any regulatory consequences when
participating in these collections?
What should I expect at the collection site?
What health and safety precautions are taken?
South Dakota and Minnesota provide
detailed guidance on how to participate in Clean
Sweep collections, and several other states including
Montana, North Carolina, Tennessee, Virginia and
Wisconsin give background, schedules and other
relevant informationfor collection events. State
websites are listed in Appendix VI.
45
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fable 14 Quantity of the Most Common Pesticides Registered in Virginia's Clean Sweep Program from 1992 through 2000
A indicates that the pesticide is currently registered, a hazardous waste when disposed, a persistent, bioaccurnulative and toxic (PBT) chemical, or an organophosphate OP.
Pesticide14
DDT
2,4-D
dlnoieb
lulftlr
toxaphene
cSrboturan
1 ciplan
atrazine
: vemolate
carbaryl
malalhton
PGNB
. clilordane
lead Bnenme
trifliinUn
dlaiinon
pyrethrins
bmylale
creosote
atachlor
purathion 3
ethoprop
simazlne
endrin
ronofoi
tlvex
capper sulfate
proplontc acid
formaldehyde
Weight
(pounds)
16,069
14,976
14,282
14,162
13,824
13,745
12,380
11,821
9,044
8,935
7,441
7,357
7,274
7,109
6,892
6,741
6,482
6,450
6,376
6,090
5,604
5,581
5,474
5,458
5,250
4,972
4,769
4,740
4,644
% of All
Pesticides
2.96
2.76
2.63
2.61
2.54
2.53
2.28
2.17
1.66
1.64 ;
1.37 ;
:1.35
1.34
1.31
1.27
1.24
1.19
' f.19
U17
1.12
1.03
1.03
1.01
1.00
0.97
0.91
0.88
0.87
0.85
Currently
Registered
o
o
CD
I
tJ
o
5
CO
oil
33
0>
I/)
5f
Notes: (*) Dioiins me Level 1 PBTs and the pesticides 2,4,5-T, Silvex, pentachlorophenol and ronnel potentially contain dioxins, although these pesticides are not listed as Level I PBTs per se.
(1) The weight includes the amount of the pesticide as the only active ingredient and as one of several active ingredients if it was listed first. For example, the entry for DDT includes 14,845 pounds of DDT and 1,224 pounds of DDT and at least one
other active ingredient, e.g., DDt+copInn+paralhion. It is important to note that there were relatively large amounts of some the combinations, including but not limited to 3,200 pounds of trinuralin+bencfin (included with trifluralin); 2,507 pounds of
atrazine+metolnchlor (included with atrazine); 2,500 pounds of loxaphene+DDT+paralhion (included with toxaphene); and 2,274 pounds of toxaphcne+DDT (included with loxaphene).
(2) The (able lists the 57 pesticides in Virginia's database with the largest registered volumes. Only specific pesticides were listed in this table. The information registered with Virginia also includes 59,383 pounds of "unknown", 3,493 pounds of
"insecticide" and 1,800 pounds of "herbicide".
(3) Ganccllalion order effective September 13, 2001. Use of existing slocks of end-use products will not be lawful under FIFRA as of October 31, 2003.
(4)The original registrant for metplachlor is no longer supporting its registration, and it is uncertain whether an alternative registrant will be granted registration. S-metolachlor, an enriched S-isomer of raelolachor. was registered in 1997 for the
same uses as that of (racemic) raetolachtor, and is currently registered.
-------
The Clean Sweep
States have emergency plans or require the protective equipment including respirators, fire
hazardous waste contractors to develop and submit extinguishers, and decontamination equipment, as
them to appropriate authorities. An emergency plan well as first aid and spill response procedures. State
typically contains names and phone numbers of and contractor staff are the first responders to on-
contacts, schedules of collection events and pre- site emergencies, and other responders may be
eventtraining.alistofemergencyresponders, called if needed. Minnesota's Waste Pesticide
directions to hospitals, and an evacuation route. Collection: Site Safety and Emergency
Training addresses the location and use of personal Contingency Plan is included in Appendix YE.
47
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Section 4 Challenges and Opportunities
States and counties have encountered a
number of obstacles in their efforts to conduct and
improve Clean Sweep programs. The challenges
faced by Clean Sweep program managers include
obtaining funding, complying with the hazardous
waste regulations and related concerns about
liability, making potential participants aware of the
programs, overcoming a general distrust of
governmentprograms, and managing problematic
waste streams such as dioxin-containing waste. As
states are trying to increase participation in their
programs, they are also working to prevent the
build-up of unwanted pesticide stocks in the future.
Lack of funding is the principal reason noted
by states for not operating a continuous Clean
Sweep program. Without a permanent funding
mechanism, the scramble for funds requires staff
who are imaginative, persistent, and able to engage
partners. Often, success in fund-raising hinges on
how good of a salesperson the Clean Sweep
manager is, and how readily he or she can solicit
partners and in-kind contributions. The different
ways states have used to fund Clean Sweep
programs are discussed in detail in section 2.2.
4.1 How do states design their Clean
Sweep programs to comply with
the regulatory requirements?
The federal hazardous waste regulations
developed under the authority of the Resource
Conservation and Recovery Act (RCRA) are
extensive, and states may perceive some sections of
them as a hindrance to collection campaigns for
commonly-generated wastes such as pesticides.
Household hazardous waste is exempt from
regulation as hazardous waste, but agricultural
pesticides are not exempt The Universal Waste
Rule, discussed below, was specifically designed by
EPA to ease some of these regulatory burdens and
therefore encourage collection.
As an example of the implications of the
hazardous waste regulations, consider the require-
ments for hazardous waste generators, the people
who first create or produce that waste. First,
generators are responsible for identifying whether
their solid waste is hazardous waste. If it is
hazardous waste, generators are required to register
with EPA to obtain a generator number. When
generators transport or ship waste, they must ensure
that the waste is accompanied by a manifest to the
final disposal facility.
States have addressed the manifest
requirement in several different ways. In Washing-
ton, Clean Sweep participants must comply with the
full RCRA regulations. Participants register before
the collection events and provide a form listing their
unwanted pesticides. The state government returns
the approved form to the participants, who use them
as manifests for transporting the waste to the
collection site. Some states consider the pesticides
to be pesticide products under FIFRA, the federal
pesticide law, until the participant brings it to the
collection site. During the transportation, the
material is a pesticide, not a waste, so it does not
need to be manifested. At the collection site, the
pesticides are determined to be discarded and
therefore become wastes. Many other states have
adopted the Universal Waste Rule (UWR), which
offers an alternative regulatory structure for materials
defined as universal wastes. The UWR facilitates
the collection of hazardous waste pesticides by
removing some of the legal obligations, such as the
handling and paperwork associated with generation
and transportation of hazardous waste and the
associated costs.
48
-------
While the UWR eliminates the requirement
for participants to manifestpesticides before
transporting them to Clean Sweep collection sites,
compliance with the Department of Transportation
(DOT) Hazardous Materials Regulations is still
requiredfortransportingpesticidesbyroad. The
approaches taken by states to comply with DOT
regulations vary.' The Massachusetts Department
of Food and Agriculture developed an agreement
with the State Police whereby the police would
refrain fromrandomroad side inspections of carriers
participating in the 1998 Clean Sweep event. In
North Carolina, a two-year waiver from DOT
regulations was secured by the Department of
Agriculture and Consumer Services to facilitate
pesticide collections. In Maine, participants register
their inventories with the Board of Pesticide Control
which then issues DOT shipping papers. In
Pennsylvania and other states using on-site pick-up,
waste pesticide is collected by the contractor at
each participant's site so participants do not have to
transportit.
4.2 What is the Universal Waste Rule?
The Universal Waste Rule (UWR) is a set
of streamlined hazardous waste managementregul-
ations governing the collection and managementof
certain widely-generated wastes.2 Itwas intended
to ease the regulatory burden on businesses;
promote proper recycling or disposal of certain
hazardous wastes which appear commonly in the
municipalsolid waste stream, thereby reducing the
hazardous waste content of municipal landfills; and
provide for collection opportunities for communities
and businesses.
EPA promulgated the UWR on May 11,
1995 as an amendment to the regulations imple-
menting RCRA (40 CFR 273), to f acilitate the
environmentally-sound collection, recycling or
treatment of batteries, certain hazardous waste
pesticides, and mercury-containing thermostats. In
1999, EPA published a rule adding hazardous waste
lamps.
The major benefits of the UWR for Clean
Sweep programs are that it eliminates the need for
participants to obtain an EPA generator number and
participants do not need a manifest to transport the
pesticides to a collection site.
When EPA issues a new RCRA rule, states
authorized to implement the RCRA program must
adopt the new rule in a separate state rulemaking for
it to be effective.3 Because the UWR is less
stringent than the base or initial RCRA regulatory
program, state adoption is optional. EPA strongly
encourages state adoption, however, to foster better
management of universal wastes in each state.
Consistent programs among states will facilitate the
implementation of regional collection programs and
interstate transport of wastes. States may adopt the
entire rule or portions of it, including general
provisions; provisions for batteries, pesticides,
thermostats andlamps; and provisions allowing the
addition of new universal wastes. In other words, a
state may adopt all categories of waste included in
1 The information in this paragraph is taken from 1998 Massachusetts Pesticide Bureau Waste Pesticide General Clean Out: Final Report,
prepared by the Massachusetts Department of Food and Agriculture.
2 Universal Waste Rule web site: http://www.epa.gov/epaoswer/ha2waste/id/univwast.hlm
to states in lieu of EPA. Currently, 49 states and territories have been granted authority to implement the base-, or initial, program. Many
also are authorized to implement additional parts of the RCRA program that FJPA has since promulgated, such as Corrective Action and the
Land Disposal Restrictions. State RCRA programs must always be at least as stringent as the federal requirements, but states can adopt
more stringent requirements.
49
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na;;c.:-;oes end Qpporti
the EPA rule or choose only certain wastes and
exclude others. Missouri's website_ht|rฃ//
www.dnr.state.mo.us/deq/dap/pubs lists
publications in PDF format, including The Universal
WasteRuleinMissouri (TechnicalBulletin
PUB2058), which provides a good summary of the
UWR.
As of June 30,2001,41 states and the
District of Columbia had adopted the UWR and 22
have been authorized by EPA to implement it. The
UWR went into effect immediately in states and
territories that are not RCRA-authorized, including
Iowa, Alaska and Puerto Rico. Table 15 shows
which states have adopted the UWR, which have
received authorization from EPA, and the effective
date. States that have not adopted the UWR must
comply with the full RCRA regulations regarding
notification, labeling, marking, accumulation time
limits, employee training, response to releases,
offsite shipments, tracking, manifesting and
transportation.
4.3 How can states deal with liability
issues prior to, during, and after
collection?
Clean Sweep activities pose different
questions of liability to participants, the owners or
operators of facilities that host single day events, the
state government and the hazardous waste
contractor. For example, if apesticide is spilled
when the participant is driving to a one-day event,
who is responsible for clean up? If a spill occurs at
the location of the event, who must clean it up? If
the pesticides are improperly disposed, who is
responsible? If there is aproblem with the disposal
facility where the pesticides are shipped, who is
responsible? A full analysis of the legal implications
of Clean Sweep programs is beyond the scope of
this report This section briefly describes how
liability concerns affect the implementation of Clean
Sweep programs.
Prior to a collection, program managers
make sure that participants are aware of the danger
of transporting old, unwanted pesticides in their
vehicles to the collection site. Using web sites and
printed material, program managers inform
participants of the procedures to follow. For
example, Minnesota's web site instructs participants
to load pesticides in sturdy containers on a truck
bed (not a car), separated from each other by
cardboard inserts and tightly strapped down to
prevent sliding. Participants are cautioned to bring
their completed product inventory and drive safely,
as they are responsible for any spills along the way
to the collection site. Massachusetts' site provides
instructions on how to repackage damaged or
leaking containers and provides a transportation
safety checklist. The web sites of Idaho, South
Dakota, Texas and Washington also provide
detailed information for participants. Some states
distribute overpack drums, bags or other packing
material to participants forrepackaging faulty
containers. As aprecaution, three states require
participants to attend a pre-event training.
At the collection event, trained contractor
and government staff, not the participants, unload
and process the pesticides at the site. After the
collection, the hazardous waste contractor is
responsible for stabilizing andsecuringthe collection
site. At permanent sites, trained government staff
manage the security of the stored products.
Clean Sweeps are sometimes set up so that
the pesticide agency becomes the official generator
of the waste for the purposes of compliance with
hazardous waste regulations. South Carolina has
hadafewproblems with liability due to the unique
structure of the state's pesticide regulatory agency,
which ishoused in Clemson University rather than
theDepartmentof Agriculture. The University
Board of Directors did not want to be in the position
of incurring the role and liability of a generator. The
-------
Table 15: Status of Adoption and Authorization of the Universal Waste Rule re Pesticides
State
AL
AK
AZ
AR
CA
CO
CT
DE
PL
GA
HI
IA
ID
tt.
IN
KS
KY
LA
ME
MD
MA
MI
MN
MS
MO
Adopted l
Y
N (EPA administered) '
Y
Y
N'
Y
N
Y
Y
Y
Y
N (EPA administered)
Y
Y
Y
Y
Y
Y
Y (Not Pesticides)
N
Y
Y
N
Y
Y
Authorized 2
Y
N
Y
N
N
N!
N
Y
Y
Y
N
N
Y
N
Y
N
N
Y
N
N
Y
Y
N
N
N
Authorization Date
2/10/98
5/20/97
9/1 1/00
6/2/97
1/23/98
1/19/99
1 1/30/99
12/22/98
10/12/99
6/1/99
State
MT
ME
NV
NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
RI
SC
SD
TN
TX
UT
VT
VA
WA
WV
Wl
WY
Adopted
Y
Y
Y
N
N
Y
Y
Y
Y
Y
Y
Y
Y
N
Y
Y
Y
Y
Y
Y
Y
Y (Not Pesticides)
Y
Y
Y
Authorized
N
N
Y
N
N
N
N
Y
N
N
Y
N
Y
N
N
Y (Not Pesticides)
Y
Y
Y
Y
Y
Y (Not Pesticides)
Y
N
N
Authorization Date
g/23/96
12/22/98
1 1/23/98
1 1/27/00
6/8/00
1 1/15/99
10/18/99
3/15/99
1 1/23/99
9/29/00
I/I 1/00
7/10/00
H
rr
OJ
a
U)
fl>
0>
O
JU
fl>
"O
O
Notes: (1) Adopted = the state program office has notified the EPA of a state analogue to the UWR.
(2) Authorized = the EPA has authorized state implementation of the UWR.
(3) Not adopted (EPA authorized) = the state hazardous waste programs, including the UWR, are administered by the EPA regional office.
(4) Not adopted = the state may or may not have adopted an analogous state rule, but no notice has been given to the EPA.
(5) Not authorized in a state which has adopted the UWR = the authorization package has been received by EPA and evaluation is in progress.
-------
Section 4 Challenges and Opportunities
state pursued legislation that would allow the
university to have an active role but with limited
liability, but budget shortfalls have precluded the
resolution of this issue.
In some states, the hazardous waste
contractor assumes the status and liability of the
hazardous waste generator.
4.4 How can states increase
participation?
One of the biggest challenges faced by
Clean Sweep program managers is maximizing
participation. For example, Minnesota found that
82 percent of the participants in 1998 were taking
part for the first time, despite having run a state-
wide, well-organized program since 1990. There
are many reasons that people may not participate in
Table 16: Outreach Methods Responsible for Participants' Knowledge of Collection Event
Clean Sweep programs, including lack of awareness
of the program, fear of being "out of compliance"
with hazardous waste regulations, and distance to
the collection site.
Collection programs have tried a variety of
advertising methods, including newspaper ads,
posters at pesticide dealerships, letters to potential
participants, radio or TV announcements, and
information distributed by extension agents. States
may use the commercial or private applicator
recertification programs as a way to inform farmers
of the Clean Sweep program. Results of surveys by
North Dakota and Florida on the method by which
participants learned of the collection event are
shown in Table 16. As shown in this table, the most
effective way to reach participants varies, so most
programs use multiple advertising methods.
Outreach Method
Extension agent
Local newspaper ad
Dept. of Agriculture
Word of mouth
Newspaper story
Radio
Television
Newsletter
Trade associations
Brochure
Posters
Farm/ranch ad
Other
TOTAL
% of Participants Citing
Method in ND 1996
28%
24%
22%
14%
12%
12%
13%
11%
8%
10%
3%
157%*
% of Participants Citing
Method in ND 1998
19%
35%
1%
7%
11%
20%
7%
12%
118%*
% of Participants Citing
Method hi FL 2000
41%
14%
42%
11%
;'
108%*
* The total exceeds 100 percent because participants reported more than one method.
52
-------
The Clean Sw-aec- r-;?,.:.:>-
The impression of many Clean Sweep
managers is that a major obstacle to participation is
over-coming distrustof government agencies and
fear of retaliation. Many farmers have the
perception that they could be fined or otherwise
punished if it came to the attention of a government
agency that they were storing chemicals, particularly
canceled pesticides, on their property. Anotherfear
is that they may be subject to an unwanted site
inspection or be placed on a "list" for some future
enforcement action. Some states have found that
pre-registration, which helps them estimate the
volume of waste to be expected in a one-day
collection event, is a deterrent to those who prefer
to remain anonymous.
To promote participation by agricultural
communities, some state Clean Sweep programs
partner with industry. For example, Michigan
enlisted the cooperation of Vriesland Grower's
Cooperative, a 580-member cooperative with over
60 years of service to growers. The cooperative
agreed to allow their facility to become a permanent
collection site for the Clean Sweep program, and
during its first year, collected 20 percent of all the
pesticides in the entire state that year. States have
also relied on the good relationship between
extension agents and growers to gradually diminish
the distrust of Clean Sweep programs.
Many programs havelseen an increase over
time in the volume of older pesticides collected.
This may be due to the eventual participation by
faimers who heldbaek until they saw that their
neighbors experienced no penalties or fines after
taking part in a Clean Sweep program. Farmers
tend to store unusable or canceled products until
they have a safe way to dispose of them. Word of
mouth and other forms of communication eventually
filterthrough the agricultural community, and Clean
Sweepprograrn managers haveindicatedthatit may
take several collection-events in the same area
before tihe less trusting participate.
After its 1998 program, Massachusetts
concluded that trust can be built by having regular
and convenient collection events and developing and
highlightingpartnerships with agricultural and
pesticide user organizations. Under this approach,
when a government agency is the initiator, it is listed
as one of several sponsoring organizations. Ohio's
Department of Agriculture collaborates closely with
county extension services, Farm Service Agencies,
Soil and Water Conservation Districts, Health
Departments and Solid WasteManagement
Districts, and the Ohio EPA, with the Farm Bureau
and commodity associations helping to publicize the
program.
Another potential barrier to participation
may be the location of the collection site. Farmers
may be unwilling to transport large quantities of toxic
chemicals great distances to unfamiliar locations.
Wisconsin records show the maximum distance the
average farmer is willing to travel to participate in a
CleanSweepis 15miles. One option for increasing
participation is to expand service through satellite
sites or mobile collection units.
4,5 What are the disposal options for
dioxin-containing wastes?
Most pesticides can be disposed of at high
temperature hazardous waste incinerators or
landfilled atpermitted hazardous waste landfills.
The main exception is the small number of pesticides
that may contain dioxin, such as 2,4,5-T, Silvex,
Ronnel andpentachlorophenol. Underthefederal
hazardous waste regulations, these pesticides
generally fall under the "F027 code" (see box on
followingpage), whiehis identified as dioxin-listed
waste. Past Clean Sweep programs have received
small amounts of thesepestieides. Extrapolating
data fromprograms which report quantities of
specific pesticides eoleeted leads to an estimate that
53
-------
Definition of H127 Waste in Federal RCRA Regulations
40 CFR 261.31 (a) The following solid wastes are listed hazardous waste from non-specific sources...
P027 Discarded unused formulations containing tri-, tetra-, or pentachlorophenol or discarded unused
formulations containing compounds derived from these chlorophenols. (This listing does not include
formulatioas containing hexachlorophene synthesized from prepurified 2,4,5-trichlorophenol as the sole
component)
The problem for Clean Sweep programs is
that the only commercial incinerator in the U.S. that
is permitted to accept dioxin waste, in Coffey ville.
Kansas, closed in August 2000. Even prior to
August 2000, this incinerator operated intermittently
and therefore did not always accept the dioxin-
bearing pesticides from Clean Sweep programs.
Without an incinerator available to dispose of dioxin-
containing materials. Clean Sweep programs did not
and do not want to accept these pesticides because
storage is cost-prohibitive and not a long-term
solution. Therefore, most states (and hazardous
waste contractors) accept dioxin-containing material
only if a permitted dioxin disposal facility is
operating. However, rejecting such pesticides at
collection days creates ill will and the potential that
such products will be indiscriminately dumped.
Shipping dioxin wastes to incinerators in
other countries, such as Canada, has been done. A
Canadian facility is actively accepting F027 waste
for incineration, but this may not be convenient for
southern states. A solution to this problem is of high
priority to states, but highly dependent on private
incineration company management decisions.
4.6 What are the benefits of tracking
specific pesticides?
Although it costs more staff time and effort
to track quantities of individual pesticides, some
states want to know exactly what wastes they are
collecting. Tracking specific pesticides enables
states to identify trends in the quantities of old,
canceled, or currently used pesticides being
collected and to plan future strategies for waste
collection. Data on the quantity of canceled and
unregistered pesticides collected also helps convince
state legislators of the magnitude of the problem so
that funds will be budgeted for Clean Sweep
programs.
In addition, by conducting Clean Sweep
programs, state and local governments are
contributing to global efforts to eliminate PBTs.
Tracking information on the PBT pesticides
collected and disposed by Clean Sweep programs
enables the U.S. to quantify the nationwide
contribution, as part of its treaty obligations, to the
elimination of these toxic and environmentally
hazardous substances.
4.7 How do states track specific
pesticides?
States use a number of different ways to
collect information on the amount of specific
pesticides that have been collected. Vermont
requires its Solid Waste Districts to report the
specific pesticides collected in order to receive state
funding for disposal. Michigan recommends
instituting the practice of recording the specific
pesticides collected right at the beginning of the
program. Once a program is underway, habits are
hard to change, particularly if collections are
infrequent and attract many participants at once.
Permanent collection centers, such as Michigan's,
are open five days a week and do not have the
problem of time constraints when recording
information during extended busy times. It took
54
-------
several years for Michigan to convince every center
to record the weight and identity (either by EPA or
USD A registration number or by common name) of
all products collected. In some cases, reimburse-
ment was withheld until the information was
provided. North Carolina recently began to track
quantities of 15 to 20 different pesticides. Contain-
ers of these pesticides are placed aside as they are
dropped off and the quantities are tallied during
down times at the collection events. In Virginia,
participants provide detailed information about the
quantity and identity of the individual pesticides
when they register. TheVirginiaDepartmentof
Agriculture and Consumer Services maintains this
information in a data base. While the actual amount
collected differs from the amount that is registered,
the data base provides a good estimate of the
pesticides collected.
In an effort to encourage states to track
specific pesticides in 2000, EPA offered small grants
to states which already had Clean Sweep programs
but did notrecord amounts of individual pesticides.
Minnesota, Kentucky, New York and Massachu-
setts were awarded small grants. '
Minnesota had already been tracking
specific pesticides for ten years but had not analyzed
the cost of its data collection and management.
Therefore, the state proposed to explore ways to
more efficiently manage the data. Minnesota
compared the state's current, hand written method
of data collection by volunteers to three principal
types of datamanagement: optical recognition of
container bar codes, scanning drivers' licenses at
collection sites, and telephone number identification.
The bar code option required a pre-
programmed scanner and proved to be both time-
and cost-prohibitive, since itinvolved eommunicating
with all the chemical companies about information
they were hesitant to share. Even if existing codes
could be used, many containers are old and from the
pre-bar code era. Minnesota believes that by
developing a bar code for each of the most
frequently-collected pesticides, it would be possible
to use scanners without the container actually having
a compatible bar code. For this to occur, the
product would have to be identified and then located
on a product name sheet with the correct assigned
barcode. A three-ring binder containing the bar
code sheets would need to be carried while taking
inventory at on-site collections. Sheets of bar codes
representing only numbers would also be necessary
to scan in the weights of each pesticide collected.
Minnesota's program maintains a database
of participants' names and addresses, and they
investigated ways to make the data entry more
efficient. They tried several methods, including one
used by county household hazardous waste
programs which scan drivers' licenses, and another
using software from telephone companies. Neither
option was considered practical, because they
would require constant upgrading.
Minnesota also evaluated various equipment
(scanners, software, hardware) with the latest
technology which could be used under field
conditions at collection sites under conditions of
extreme weather conditions, dust, grime, heat, cold,
and rain. The investigators concluded that the
sensitivity andlimitedmobility of scanners would be
a problem, but that the bar code scanning option has
potential for the future. They developed a trial
program with bar codes identifying about 50
pesticides, but the budget did not allow for a trial.
Minnesota concluded that, currently,
enteringmeinformationlonghandis the most
appropriate, practical, reliable and least time
consuming (especially when several hundred bar
codes are involved) method of collecting the
information, provided the penmanship is legible.
55
-------
ienges and Opportunities
In Kentucky's program, aDepartment of
Agriculture employee visits the participant's site to
assess the pesticides or to pick them up if they
quantity is small and doesn't require special
containment. Most pesticides are placed into
overpack drums. To track certain pesticides, the
Departmentof Agriculture employee followed the
same procedure, but separated the tracked
pesticides from the others in either overpack bags,
drums or pails depending on the amount. This
allowed the state to measure and record the weight
of the tracked pesticides. Kentucky collected useful
information, but the process added additional effort
and time to the process and required additional
overpackmaterial.
4.8 What are states doing to prevent
future accumulation?
States are trying to prevent the future
accumulation of waste pesticides by providing
training and outreach for good management
practices and promoting integrated pest
management (IPM). States may provide
comprehensive guidance on good management
practices, either on their websites or in published
documents, for storing and disposing unwanted
pesticides, managing empty containers, and avoiding
the accumulation of unwanted pesticides. Appendix
VI lists state websites with information about
pesticides and disposal, and some that provide
Clean Sweep-specific information. Examples of
websites which address good management practices
forpreventing accumulation of unwanted pesticides
are Florida, South Dakota and Washington. North
Dakota's Web site4 gives guidance on prevention
and emergency response on pesticide storage
concerns during a flood. State and county extension
services continue to offer advice and training in IPM
to facilitate farmers' informed decisions about
pesticides.
http^/www-ag.ndsu.nodak.edu/flQtvi/pestidhb.htm
56
-------
Section 5 Observations
Using a variety of approaches, Clean
Sweep programs in 46 states have collected and
disposed of more than 24 million pounds of
unwanted pesticides, which may otherwise have
seeped out of deteriorated containers and
contaminated soil and groundwater. Using
predominantly state resources, 11 states have
collected over a million pounds of pesticides, and
the 21 states with permanent funding have collected
more than 70 percent of the waste pesticides
collected nationwide. Participation has expanded
from exclusively farmers and ranchers to include
residential and institutional pest control operators,
government agencies, golf course owners and
others. Although many of the collected pesticides
were canceled years ago, currently-registered
pesticides are the most commonly collected
materials.
After examining the states' programs, EPA
has made observations about several major issues
facing these programs nationwide. This section
discusses the advantages of permanently funded
programs, the costs of Clean Sweep programs, the
amounts of unwanted pesticides still needing
disposal, the relationship between quantities used
and quantities disposed, and the continued need for
Clean Sweep programs.
5.1 Permanent funding has many
advantages.
The 21 states with permanently funded
programs have collected over 70 percent of all the
waste pesticides nationwide while conducting over
60 percent of the annual collections. The obvious
principal advantage of permanent funding is that
program managers have predictable funds every
year or every few years, and can, therefore, devote
their energy to program implementation. With
permanent funding, managers can think long-term,
can plan for phased state-wide collections, and can
establish long-term contracts with waste haulers.
An established, funded program builds trust
in the community and gives farmers and other
participants a sense of confidence that Clean Sweep
programs are beneficial to participants and the
environment. Participants learn through the
experiences of neighbors, and program staff can
plan successful outreach efforts and target different
geographical areas each year so as to cover an
entire state.
Permanently funded programs give program
managers greater waste management contracting
flexibility, including options to negotiate long-term
contracts. As discussed in section 2.13, the
administrative strategies that allow for program
efficiency require considerable coordination and
planning between the manager and the contractor.
The more stable the program and vendor
relationship, the greater the chance that the
advantages of administrative options can be fully
realized. When managers have the time to research
and understand administrative options, they can
move from low-bid contracts to "request for
services proposals." Short-term contracts leave
little room for vendors to work toward more
efficient, long-term solutions, and put the burden on
program managers to identify all needs in the bid
documents.
Also, program managers of well-funded
programs have the flexibility to alter or expand
service formats. For example, satellite sites,
permanent sites, combined household and
agricultural collections, multi-county andmulti-day
collections, and on-site pick ups to reduce customer
travel time and increase convenience are options
available only to those states with established,
assured funding.
57
-------
Section 5 Observations
5.2 The unit costs (on a per pound
basis) of Clean Sweep programs
have decreased over the past
decade.
The cost of a Clean Sweep program (and
the way cost is calculated) varies from state to state
and over time. In some cases, programs may cite
only the cost of the contractor, while the consid-
erable internal expenditures, including agency in-kind
and personnel costs, may be omitted from the
reporting. The major contractual costs are usually
the mobilization fee (cost attributed to the
contractor's expenses in arriving at the site and
settingup forthe collection), collection and disposal
costs, and the analysis of unknown substances
broughtto the collection. However, the cost of
Clean Sweep programs is minor compared to the
cost of cleaningupthepollutionresulting from
improper disposal of unwanted pesticides.
Some states have provided yearly cost
information on their Clean Sweep programs and that
information is provided in Table 17. The data from
these states are incomplete, making it impossible to
analyze the total cost of Clean Sweep programs in
the U.S.
Another way to evaluate the cost of Clean
Sweep programs is to consider the cost per pound
of disposed material. Based on the data from fifteen
states provided in Table 18, the cost per pound has
decreasedsignifieantlyoverthepastdecade. When
Ut^?sDeparlMentฎfAgrieidttffeandFood began
the state paid $4.50 per pound to dispose of the
collected material. In 2000, due to the
Department's ability to get various disposal
companies on a state contract, the cost was reduced
to $1.55 per pound, a decrease of over 65 percent.
Using vendors that were on a state contract saved
more than $230,000 in four years, and decreased
both cost and paperwork for farmers and ranchers.
Similarly, Ohio's disposal costs went from $6 per
poundinl993to$1.25perpoundin2000. The
cost per pound over time for Georgia, Maryland,
Mississippi, Utah and VirginiaisshowninFigure 19.1
In states with successful long-term
programs, the current perpound cost ranges from
$ 1.98 per pound in Washington to less than $ 1.00
per pound in North Carolina, with other states in
between, for example $ 1.80 in Wisconsin, $ 1.60 in
Minnesota, $ 1.30 in Nebraska, and $ 1.21 in Texas.
The unit cost for Clean Sweep programs in 1999
and 2000 in 26 states averaged $ 1.56 per pound
and ranged from $0.85 per pound to $2.98 per
pound.
In its Progress Report for Operation
Cleansweep of March 2001, the Florida
Department of Agriculture and Consumer Services
summarized the benefits of Clean Sweep programs
and analyzed the difference in cost between their
2000/2001 state-run program and the cost that
would have been incurred if each of the 374
participants had contracted and paid for disposal
separately.
.The collection and proper disposal of
unwanted pesticides provides a benefit to both end
users of pesticides and citizens of the sta^e.
1 Note: EPA believes that this cost decrease is due partly to increased efficiency by the programs and partly to the general changes hi
incine^jL^sGOSts over the decade. Althougli'dattadBDSim the early 1990s was not available, the Environmental Technology Council web site
(http://www.etc.or.g) lists the average cost for disposing of lab packs at commercial 'incinerators (on a per pound basis))!, as follows: $2.17
in July 1999, $2.42 in January 2000, $1.62 in September 2000, and $1.63 in May 2001.
58
-------
FIGURE 19 Cost (per pound) of Clean Sweep Collections for Selected States
1990 1991
1992 1993
1994
1995 1996 1997 1998
1999 2000
Virginia
Maryland
- Utah
-- Georgia
Mississippi
Program participants benefit by the removal of a
potential financial liability. Citizens benefit by the
removal and disposal of potential pollutants from
theirenvironment.
In addition, there are significant cost savings
based on comparing the cost of Clean Sweep
programs to the costs of each participant contracting
for disposal separately. Typical costs for removing
hazardous wastes from private property include both
the costs of hiring a professional, properly-licensed
firm to characterize the products for disposal and the
costs to transport and dispose of the material.
Costs for professional services are on the order of
one hundred to several hundred dollars per hour,
depending on the number of professional staff
assigned. Transport and disposal costs paid by the
Florida Department of Environmental Protection for
emergency clean-up services run $2.15 per mile for
transport and $300 per 30-gallon overpack drum.
The average amount of unwanted pesticides per
participant in the Florida program was 630 pounds,
which would translate to at least three 30-gallon
overpack drums. Assuming a trip of 50 miles to the
transfer/storage facility, the cost per participant
would be about $ 1,000, or at least $374,000 for
the 374 participants for transportation and disposal
only, i.e., not including the costs for professional
services. Assuming a minimum cost of $ 1,500 for
professional services per participant, the cost for
participating businesses to dispose of their unwanted
pesticides increases by $561,000 to a total of
$935,000, if they had each contracted for disposal
individually. In comparison, the cost to the state for
the 374 participants to participate in the December
2000 to February 2001 Clean Sweep program was
$270,033. In other words, environmentally sound,
privately-arranged disposal would have cost an
estimated 3.5 times more than the state paid,
showing the benefits from the increased efficiency,
economy of scale and single mobilization and
professional services fee that are part of Clean
Sweep programs.
59
-------
Table 17: Total Program Cost per Year for Selected States (in dollars)
State
AL
FL
GA
HI
ME
MD
MS
NE
NH
NY
SD
UT
VT
VA
WV
1987
50.062
no data '
1989
17,300
no data
1990
75,000
158,977
1991
no data
1992
225.264
1993
71.800'
no data
51.539
222,100
1994
99.000
71,960
no data
78,692
624,983
no data
1995
132,590
no data '
no data
50.052
311.964
744,000
no data
no data
49.333
174.132
150.000
1996
39.035
73.600
no data
30.820
170.832
213,804
no data
46,669
<60.000
144,024
29.340
1997
no (Jala
35,070
no data
23,508
222,667
no data
47,258
<60,000
86.073
no data
1998
no data
128,880
15.280
36.481
259,876
no data
no data
44,090
<60,000
60.559
no data
1999
64,400
37.1.850
9.180
12,604
29.485
no data
50.708 '
38.525
36.832
<60,000
116,150
2000
16.800
195.507
207,910
15,000
no data
252,020
no data
42.062
40,474
60,000
103.620
Total
3 1 2.790
NA!
>8 1 9.310
67,362
NA
153,465
> 1,066.784
>996.000
75,000
>336.3I2
NA
394.887
NA
1,915.882
NA
o
3
en
O
i >
VI
2
o>
ซ-*
o'
VI
Notes: (I) No data = the state collected pesticides that year, but there are no data on costs. (2) NA = not applicable. If there were more years (or the same
number of years) with no data than with data, a total was not calculated because it would be misleading. (3) For Maine, there are no data for 1982, 1984,
and 1986. (4) For New York in 1993, the overall costs were $71,800; the disposal costs were $31,800. In 1999, the overall costs were $50,708; the
disposal costs were $39,990.
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Table 18: Average Cost per Pound for Selected States (dollars per pound)
State
AL
PL
GA
HI
1987
4.01
ME | nodata4
: M0 fe
JfT
MS T
NE
NH
NY
SD
UT
VT
VA
WV
Average6
4.01
1989
3.46
nodata1
3.46
1990
3.75
5.00
4.52
1991
nodata
1992
3.94
3.94
1993
2.29 5
nodata
4.50
3.26
3.27
1994
1.39
3.13
nodata
4.50
2.81
nodata
2.62
1995
2.40
nodata1
nodata
1.50
1.21
1.25
nodata
nodata
3.50
2.80
2.50
1.50
1996
2.10
2.00
nodata
2.07
1.02
1.77
nodata
3.50
nodata
1.90
1.57
1.60
1997
nodata
1.37
nodata
1.75
1.45
nodata
2.50
nodata
1.16
nodata
1.45
1998
nodata
1.00
1.91
1.75
1.21
nodata
nodata
1.68
nodata
1.26
no data
1.22
1999
1.28
nodata
1.00
1.30
2.83
1.24
nodata
1.62 5
1.67
2.15
nodata
1.19
1.16
2000
1.33
1.14
1.00
4.66
nodata
1.30
nodata
1.30
1.52
2.14
1.27
1.23
Total
1.65
NA2
1.06 3
3.86
NA
1.76
1.27 3
NA
3.75
1.79
NA
2.72
NA
2.34
NA
Notes: (1) No data = the state collected pesticides that year, but cost data are not available. Therefore, the cost per pound could not be calculated. (2) NA = not applicable. If there
were more years (or the same number of years) with no data than with data, an overall average cost per pound was not calculated because it would be misleading. (3) This
represents the average quantity for the years with data. (4) Maine does not have cost information available for 1982,1984, and 1986. (5) For New York in 1993 and 1999, this
represents the cost of disposal per pound, not the overall cost per pound. (6) This is a weighted average that was calculated from the total cost and total number of pounds for the
states with data for that year.
3"
(0
O
CD
ฃ0
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5.3 Reliable estimates of uncollected
pesticides are elusive.
No one knows how many pounds of
unwanted pesticides remain uncollected in the U.S.,
and accurately estimating me total amountis difficult
due to several factors. First, many farmers are
reluctantto fill outgovernment surveys, particularly if
they happen to have canceled pesticides stored in
their barns. Some people may fear that a survey,
even if anonymous, may be tracked back to them
and that they might be subject to afine or penalty.
Second, some stocks lie forgotten in barns for years
until the owner dies and the barn is bought or
inherited by someone who does not need the
pesticides and wants to getrid of them. Third,
unwanted pesticides continually accumulate. Ideally,
all pesticides bought in a single year would be used
during thatyear's growing season. In reality, some
amount may be left over every year and many never
be used, if farmers change crops or need different
pesticides. Fourth, in recent years, some uses of
older products have been canceled due to new risk
assessments conductedunderthe Food Quality
Protection Act, In such cases, a farmer may choose
not to use existing stocks of a specific pesticide.
Several states have conducted surveys to
attemptto estimate the amount of unwanted,
uncollectedpesticide. Georgia sent out printed
surveys in 1997 to help determine (1) if they should
continue the Clean Sweep program and (2) if so,
which areas of the state they should target. A cover
letter explained the purpose of the survey and
ensured the recipient of absolute confidentiality,
recording only the name of the county where the
pesticides were stored. Postage-paid return
envelopes were provided, A total of 4,741 one-
page surveys were sent to randomly selected farms
throughout the state. A total of 1,446 responses
(30.5 percent response rate) were received. The
survey consisted of the following questions:
What county do you live in?
Do you have unusable waste farm chemicals in
need of disposal?
Why have these chemicals become unusable?
Approximately how much do you have?
How long have you had these chemicals?
How far would you be willing to travel to
dispose of these chemicals?
Would you participate if you had to pay a
portion of the disposal cost, and if so, check the
highest amount/pound you wouldbe willing to
pay?
What is the best way to inform you if a program
is started in your area?
Georgia officials then extrapolated the
survey results to estimate that 43,000 farms in the
state had approximately 544,000 pounds of
unwanted pesticides. The Clean Sweep advisory
committee believed that this estimate was
approximately half the actual amount. For
comparison, between 1998 and 2000, Georgia
collected more than 710,600 pounds of pesticides.
Florida's Department of Agriculture and
Consumer Services enlisted the collaboration of
other state and federal agencies, grower groups,
environmental groups and other interested parties in
athree-countypilotprojectinl996. County
agricultural extension agents conducted surveys and
identified over 5,000 pounds of unwanted
agricultural pesticide in the three counties. In the
Clean Sweep collection thatfollowed, some
growers .had apparently underestimated the amount
they had for disposal, while other growers who had
not pre-registered for th&collection were f
accommodated. Over 7,500 pounds of pesticides,
or 50 percent more than estimated, were collected
in the three pilot counties. All participants were
satisfied with the process, and the rapport and trust
between growers and extension agents were found
to be key elements in the success of the program.
62
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A random sample survey of South Dakota's
3,800 farmers and ranchers in 1997 indicated that
73 percent of them were familiar with the Unusable
Pesticide Collection Program. The survey also
showed that one in 20 had unusable pesticides on
hand, which translated into approximately 190
farmers andranchers. Further survey results
indicated that farmers and ranchers held approxi-
mately 20,750 pounds and 9,540 gallons (a total of
106,610pounds, assuming a conversion of 9
pounds per gallon) of unwanted pesticides. Survey
respondents with pesticides reported a willingness to
travel an average of 30 miles to apesticide
collection site. August and October were the most
popular months to hold a collection event, but one in
five of those responding had no preference. As a
point of reference, from 1998 through 2000, South
Dakota collected more than 83,600 pounds of
pesticides in their Clean Sweep collections.
5.4 Only a fraction of the pesticides
used in states is disposed in Clean
Sweep programs.
Section 3.2 includes a discussion comparing
the amount of pesticide collected and disposed by
Clean Sweep programs to the amount of pesticide
usednationwideffoml961 to2000. Appendix VUI
provides the estimated amount of pesticides used in
each state and amount disposed in its Clean Sweep
program. Assuming thatpesticidemanagement
practices are consistent across the country, it is
reasonable to expect that the higher a state's
pesticide usage, the higher will be its quantities of
unwanted stocks.
The table in Appendix VUI shows that
states whiehuse the mostpesticides have
permanently funded or continuous Clean Sweep
programs, indicating that these states recognize and
pesticide stocks. The table also shows, as
expected^ thatstates wiMonger-rurinrng programs
generally havecollected higher quantities of
pesticides and a larger proportion of the amount of
pesticides used since 1961. A notable exception is
Nebraska, which has collected a large quantity of
pesticides in only four years.
Texas has collected more than 3.1 million
pounds of unwanted pesticides in its 9-year Clean
Sweep program. As Appendix VIE shows, this is
an estimated 0.06 percent of the quantity of
pesticides used in Texas over the past four decades.
This means that for every 1,000 pounds of pesticide
used in Texas during this time, less than a pound
(0.6 pound) has been collected and disposed by the
state's Clean Sweep program. Information for all
the states is listed in Appendix VIE.
5.5 Clean Sweep programs will
continue to be needed for the
foreseeable future.
Even states with long-term, comprehensive
Clean Sweep programs are still collecting large
amounts of pesticides. For example, seven of the
11 states that have collected over one million
pounds in total, collected more than 100,000
pounds of pesticides in 2000.
The amount collected per year depends on
many factors, including the available funding, number
of collection events, organization and timing of
events, and categories of people who are allowed to
participate. Examining the charts for the quantity of
pesticides collected in each state in Appendix I
indicates the difficulty in tryingto define along-term
general trend in amounts collected per year. In
some states, such as Minnesota and North Carolina,
the amount collected has increased almost every
year, although the amount collected in Minnesota in
2000 decreased from the peak in 1999. Other
states, such as California, Georgia, Ohio, and
Pennsylvania, have had apeak year and declining
collections since. Idaho collected about the
63
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Sscrton 5 Observations
sameamount annually for five consecutive years, In addition to the typical amounts collected
then spiked to an increase of about 60 percent in from farmers and others, unpredictable special
2000. Indiana had a peak year, then declining situations are always possible. For example, a
amounts, and after skipping two years collected "Virginia widow recently auctioned her estate's farm
almostdoubleitshighestannualcollection. equipment, which included pesticides. Thestate
Basically, there is no clear pattern in quantities of requested that she remove the pesticides (almost
pesticides collected over time. 6,000 pounds) from the auction and arranged for a
contractor pick up during the 2000 Clean Sweep
Some states evaluate their own programs for program.
trends. For example, "Virginia is in a four-year
"maintenance phase" following a nine-year program Because of the significant volumes of
in Which all state localities were scheduled for pesticides that continue to be collected by long-
collection events. The report of the 2000 program term, comprehensive programs and special situations
noted that in 18 of 25 participating localities, the like the one described above, EPA believes that
quantity of pesticide collected was less than the Clean Sweep programs will continue to be needed
amount collected during the first phase. The for the foreseeable future.
reduction, an overall decrease of almost 29 percent,
was observed in the 1999 program, continued in the
2000 program, and appears not to be affected by
the length of time between collections.
64
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