27. PLASTIC PESTICIDE CONTAINERS (PPC)
Mean plastic pesticide containers made of non-refillable high-density polyethylene (HDPE), symbol #2, plastic.
27.1 INTRODUCTION
This chapter of the Douglas County Comprehensive Solid Waste Management Plan (DCCSWMP) outlines the regulatory framework overseeing plastic pesticide containers (PPC), discusses the existing conditions and programs within the Regional Planning Area (RPA), establishes objectives in meeting the existing and projected needs, identifies alternatives, and recommends actions for achieving the established objectives.
27.2 REGULATORY FRAMEWORK
27.2.1 Federal Requirements
The Federal Resource Conservation and Recovery Act (RCRA) does not consider a container that has been emptied in accordance with CFR 40 264.7 and 33(c) to be a hazardous waste.
27.2.2 State Requirements
The Department of Ecology (DOE) has exempted empty PPC from the category of Dangerous Waste (DW) if they have been emptied in accordance with the Department of Agriculture guidelines. Under Department of Agriculture guidelines, PPC that have been rinsed three times (triple rinsed) can be disposed of as normal solid waste or be recycled. The rinse water (rinsaide) is considered a DW and must be handled accordingly.
27.2.3 Local Requirements
Douglas County
Any jurisdiction, agency, private corporation, individual or other entity wishing to import PPC into Douglas County must conform to the Douglas County Solid Waste Importation Ordinance (DCSWIO). As specified within the ordinance, a formal Letter of Request to the Douglas County Board of Commissioners requesting that their application for solid waste importation be reviewed is required. Only after the Douglas County Board of Commissioners has received a Letter of Request will the review and approval process begin. The Douglas County Board of Commissioners will review the information contained within the Letter of Request with county staff and others. If it is determined by the Douglas County Board of Commissioners that sufficient information has been provided and that all known potential adverse impacts have been identified, assessed and mitigated the request may be approved.
Within Douglas County no person shall deposit, discard or otherwise dispose of any PPC upon any public place within the county or upon a private residence or other private property not owned by him/her, or in any waters within the county except:
- when such property is designated by the state or any of its agencies or the county for the disposal of solid waste, and such person is authorized by the appropriate permitting authority to use such property;
- with the prior written consent of the landowner approving of such disposal upon their private property.
Additionally, within Douglas County all owners or persons in control of any private residence or other private property shall at all times maintain the premises free of any PPC that pose a risk to public health and safety, the environment or create a nuisance.
27.3 EXISTING CONDITIONS
Though state regulations allow triple rinsed PPC to be disposed of as normal solid waste, the Greater Wenatchee Regional Landfill does not accept any commercial PPC as company policy. Only triple rinsed household PPC are accepted.
27.3.1 Education
An education program has been in place since 1993 to inform generators of how to properly store, handle, dispose and recycle their PPC. The program has utilized resources through the media (radio, newspaper), posters, brochures and direct personal communications. Brochures and posters have been distributed throughout the RPA announcing the location, hours of operation, phone number and point of contact for each of the PPC collection facilities.
27.3.2 Private Sector Collection Programs
A number of local pesticide wholesale companies have commercial PPC take-back programs. Most of these companies offer this service only to their customers, however a few have open programs. Wilbur -Ellis, in conjunction with the Washington Pest Consultants Association sponsors a PPC collection program that is open to all generators throughout the RPA. Western Farm Service of Waterville, in conjunction with the Washington Pest Consultant Association sponsors a PPC collection program that is open to all generators as well.
27.3.3 Plastic Pesticide Container Collection Facilities
There are four PPC collection facilities serving the RPA. The four PPC collection facilities are open to agricultural, professional and commercial applicators with established days and hours of operation. The four PPC collection facilities serving the RPA are located at:
- Northwest Wholesale, Inc. of Wenatchee
- City of Rock Island Community Recycling Center
- Town of Mansfield Community Recycling Center
- Town of Waterville Community Recycling Center
Only agricultural, professional and commercial applicators are eligible for this program. This program is not intended for the recycling of triple rinsed containers resulting from consumer household use. In partnership with the Washington Pest Consultants Association the collected containers are ground up into flakes and shipped to selected recycling facilities. In order to qualify for the program all PPC must meet the following requirements:
- containers must be triple rinsed so that no residues remain;
- containers must be clean and dry, inside and out, with no apparent odor;
- hard plastic lids and slip-on labels must be removed (glue-on labels may remain);
- the majority of the PPC seal must be removed from the spout;
- half pint, pint, quart, one gallon, two and one-half gallon and five gallon containers are accepted whole;
- containers larger than five gallon must be cut into quarters.
Table 27-1 Quantity of Plastic Pesticide Containers Collected within the RPA
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# of Containers |
# of Containers |
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Community |
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In 1998 |
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in 1999 |
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Town of Orondo |
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225 |
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85 |
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Town of Waterville |
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1,410 |
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309 |
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Total: |
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1,635 |
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394 |
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Source: Bill Tinney II |
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Map 27-1. Plastic Pesticide Container
Collection Facilities within the RPA
27.4 OBJECTIVES
27.4.1 Ensure that Plastic Pesticide Containers are Properly Managed
With agricultural, professional and commercial applicators being responsible for the proper management of their PPC it is very important that they dispose of their containers properly. Failure of a generator to properly manage their PPC can pose a direct threat to the public health and safety and the environment.
27.4.2 Ensure that all Plastic Pesticide Containers being Disposed of Meet all Federal, State, and Local Regulations
With both federal and state regulations specifying how PPC are to stored, handled and disposed of, it is very important that the generators of this waste be properly educated. Failure of a generator to properly store, handle and dispose of their PPC can result in substantial penalties, fines and corrective actions.
27.4.3 Ensure that Programs Reflect Local Conditions
With the tendency of regulatory agencies to have a one-size fits all approach it is imperative that all programs be locally supported and accepted. Because of the rural character of Douglas County and its cities and towns all programs should reflect conditions that exist locally and not be driven by what the DOE deems as efficient or cost effective.
27.4.4 Ensure that Agricultural, Professional and Commercial Applicators have an Opportunity to Recycle
With restrictions placed upon how PPC can be recycled, it is imperative that generators have convenient and economical opportunities available. Failure to provide such opportunities may lead to improper disposal and possible enforcement action against the generator.
27.4.5 Establish a Plastic Pesticide Container Diversion Goal
It is the goal of the DCCSWMP to divert twenty-five percent of all PPC within the RPA.
27.5 ALTERNATIVES
27.5.1 Ban all Plastic Pesticide Containers from the GWRLF
Another way to increase source-separated recycling is to prohibit the disposal of PPC within the GWRLF. One problem associated with disposal bans is illegal dumping of the banned material. Therefore, an important component of a disposal ban is the development of alternative handling and disposal methods. For example, if PPC is banned from the GWRLF, a PPC collection and recycling facility must be available, convenient and reasonably priced to accommodate the diverted material.
27.5.2 Restrict Disposal to Only Permitted and Approved Facilities
By restricting PPC disposal to only permitted and approved facilities, proper disposal, diversion and recycling opportunities will be available within the RPA. This will ensure that the facilities are operated in a manner that protects the public health and safety and the environment. However, currently most PPC are being disposed of into the municipal solid waste stream or are being burned. As required under Chapter 173.304 WAC, all solid waste facilities are to be permitted by the Chelan-Douglas Health District (CDHD) and inspected at least annually. Facilities failing to obtain or apply for a solid waste facility permit are considered to be illegal dumpsites and are in violation of state law and local regulations.
27.5.3 Encourage Retailers/Wholesalers to Implement a Take-Back Program
Vendors who sell pesticides could be encouraged to implement PPC take-back programs for their customers. This would allow the customers a convenient opportunity to dispose of their PPC properly and at no or minimal costs. The DCSWPO should provide technical assistance to businesses that choose to implement PPC take-back programs. The DCSWPO could assist these businesses by developing PPC return specifications, promoting the take-back programs, coordinating the chipping and recycling of the collected PPC with the Northwest Ag. Pesticide, Inc. and by offering workshops and on-site assistance visits.
27.5.4 Site and Permit A Plastic Pesticide Container Collection Center within the City of Bridgeport
Bridgeport currently does not have a Plastic Pesticide Collection Center (PPC), whereas the participating jurisdictions of Mansfield, Rock Island and Waterville do. The Bridgeport PPC Collection Center would provide the residents of the City of Bridgeport and the Greater Bridgeport Area with a convenient opportunity to recycle their used plastic pesticide containers. A PPC container would be sited at the City of Bridgeport Community Recycling Center (CRC) and city staff would be trained to handle the PPC collected to make certain that they meet the return specifications. The PPC would be collected on a year- round basis and stored within the locked PPC container. The DCSWPO would contract with Northwest Ag. Pesticide, Inc. to service the PPC container on an as-needed basis, typically once a year. Once a collection schedule was developed by the DCSWPO and the participating jurisdictions, Northwest Ag. Pesticide, Inc. would be notified. Northwest Ag. Pesticide, Inc. would then arrive on-site, as per the schedule, set up their chipper and, with the help of the city/town staff, process the collected PPC into recycled chips.
27.5.5 Conduct an Annual Plastic Pesticide Container Collection Event for the Greater East Wenatchee Area
Under this alternative, Douglas County would sponsor an annual PPC Collection Event for Douglas County residents. This would allow Douglas County residents and commercial PPC generators a convenient opportunity to dispose of their PPC. In order to market the collected plastic pesticide containers, it is imperative that the collected containers be triple-rinsed, free of lids or foil seals and cut into a size allowable for chipping. As with any annual collection event, the three major draw backs are:
- non-compliance with collection specification;
- storage of the PPC until the annual collection event;
- what does the generator do with their collected PPC if they miss the one-day event.
The DCSWPO would be responsible for obtaining a suitable collection site, entering into an agreement with the Northwest Ag. Pesticide, Inc., promoting the collection event, preparing a site specific health and safety plan, notification of appropriate emergency management agencies, providing traffic control and other responsibilities as needed to assure a successful and safe collection event. Under this alternative, Northwest Ag. Pesticide, Inc. would set up their chipper on a specific date and for a specific time. All PPC
generators wishing to dispose of their PPC would be checked in to make certain their PPC conform to the collection specifications, complete a collection event survey and then drop-off their accepted PPC. All accepted PPC would be processed on site by Northwest Ag. Pesticide, Inc. and recycled.
27.5.6 Conduct Annual Mobile Plastic Pesticide Container Collection Events in Bridgeport, Mansfield, Rock Island, and Waterville
Because of the small volume of PPC generated and the long distance to travel to dispose of their PPC, the PPC generators within Bridgeport, Rock Island, Mansfield and Waterville are limited in their options. Under this alternative the DCSWPO would be responsible for entering into an agreement with Northwest Ag. Pesticide, Inc. to service these jurisdictions. Under this agreement, Northwest Ag. Pesticide, Inc. would spend a designated period of time in one location and then travel to the next, where they would collect PPC for another designated period of time before packing up and moving to the final location. This alternative does allow Bridgeport, Rock Island, Mansfield and Waterville an opportunity to properly dispose of their PPC without having to travel a long distance, though the time spent at each location will be limited. Additionally, in order for this alternative to be economical, a sufficient volume of PPC would have to be collected at each location to justify the costs of the equipment and staff.
27.5.7 Collect Plastic Pesticide Containers at PPC Collection Centers
27.5.8 Develop a Point-of-Sale Notification Program for PPC Retailers/Wholesalers
A point-of-sale notification program should be implemented to determine the quantity and type of PPC purchased annually within the RPA. The program would be divided into four elements:
- a public education element,
- a data collection and reporting element,
- a PPC retail notification element,
- an annual program review element.
The public education element should be developed by the DCSWPO in conjunction with the business community. The data collection and reporting element should monitor all retail sales of PPC within the RPA to establish a baseline to help determine how effective the used PPC collection, diversion and recycling program is. The PPC retail notification element would require PPC retailers to report annually to the DCSWPO on how much PPC and what type of PPC they had sold within the reporting year. Also, as a part of the PPC retail notification element, retailers would be required to post a public notice notifying its customers about how used PPC is to be disposed of and where they may dispose of their used PPC. The notice should be prominently displayed in the immediate proximity of where customers would find the PPC to purchase. Lastly, the participating jurisdictions should meet with the Douglas County Solid Waste Advisory Committee (SWAC) annually to review the effectiveness of the point-of-sale notification program. During this annual review the following program point will be discussed:
- effectiveness of the public education program. Suggestions for improving the public education program,
- effectiveness of the data collection and reporting program. Suggestions for improving the data collection and reporting program,
- retail compliance with the battery retail notification program. Suggestion for improving the PPC retail notification program,
- evaluation of the overall program and its effect upon retailers. This evaluation should be based upon the following:
a. effectiveness of the public education program upon the retailers,
b. burden placed upon the retailers to comply with the data collection and reporting program,
c. burden placed upon the retailers to comply with the PPC retail notification program,
d. effectiveness in determining the quantity and type of PPC purchased within the RPA.
27.5.9 Develop a Plastic Pesticide Container Education Program
The DCSWPO should develop a PPC education program. This program would specifically provide generators with the requirements, methods and options available to them to properly manage their PPC. The program could provide information on how PPC are regulated, how they must be triple-rinsed, how they may be disposed of, where they may be disposed or recycled, and similar information. The DCSWPO should develop brochures and information sheets to educate the public, generators and regulatory authorities about how PPC are to be managed properly. Existing PPC recycling opportunities should be promoted and the burning of PPC should be strongly discouraged.
27.5.10 Monitor and Track Plastic Pesticide Containers
The DCSWPO needs to monitor and track all PPC to determine who is generating the PPC, the volume of PPC being generated, where they originate from, where they are being disposed of, and how are they being disposed of. Without knowing these basic facts, it is impossible to properly manage the solid waste stream within the RPA. Therefore, the DCSWPO should establish a data tracking program that monitors and tracks all PPC disposal within the RPA annually.
27.6 RECOMMENDATIONS
27.6.1 Restrict Disposal to Only Permitted and Approved Facilities
27.6.2 Encourage Retailers/Wholesalers to Implement Take-Back Programs
27.6.3 Site and Permit A Plastic Pesticide Container Collection Center within the City of Bridgeport
27.6.4 Collect Plastic Pesticide Containers at Collection Centers
27.6.5 Implement a Plastic Pesticide Container Education Program
27.6.6 Monitor and Track Plastic Pesticide Containers