SOP 4.17: Ag-Generated Pesticides

SOP 4.17: Ag-generated

Household Pesticides Hazardous Waste

Contents 1. Introduction...... 1 2. Regulatory and contractual requirements...... 1 3. Training...... 1 4. Health and safety precautions...... 2 5. Processing pesticide waste...... 3 Attachment A: Waste Product Inventory Form

1. Introduction Pesticides are used to kill or control unwanted organisms and can be toxic to humans and wildlife. Attention to safe handling of this waste type is essential since exposure may cause nervous system damage and other long-term health effects. Household Hazardous Waste (HHW) Programs may choose to partner with the Minnesota Department of Agriculture (MDA) to accept waste pesticides. Pesticides are classified as Universal Wastes.

2. Regulatory and contractual requirements Pesticide processing procedures are established in the HHW program/state agency contract (Exhibit A and D), Minn. Rules 7045.0310, 7045.0320 subp. 5, 7045.1400 and Minnesota Universal Waste Rules, Department of Transportation (DOT) 49 Code of Federal Regulations, and MDA regulations. See http://www.pca.state.mn.us/publications/w-hw4-62.pdf. For more information, contact MDA at 800-657-3986 or see www.mda.state.mn.us/docs/agron/agronomy/wastpest or http://www.revisor.leg.state.mn.us.

3. Training 3.1 This Facility shall have a written training program that describes the management of pesticide wastes relevant to job duties and shall include function-specific training, safety, regulatory, and emergency procedures.

3.2 Thorough knowledge and training in proper pesticide processing is required. Staff shall be trained within six months of hire or starting a new position at the facility, or be supervised by trained staff until that occurs. Refresher training shall be conducted annually and be properly documented; see

SOP 1.4 HHW Training Requirements.

4. Health and safety precautions 4.1 Safety requirements 4.1.1 Staff shall assess unknown or abandoned pesticide containers to determine if a threat to life, health, or the environment exists (e.g., temperature sensitive, spontaneously combustible, bulging/leaking containers, explosive). Staff shall evaluate the proper management of the materials and/or situations on a case-by-case basis; see SOP 4.3 Managing Abandoned and unknowns and SOP 4.9 Explosive and Reactive Chemical Management.

4.1.2 Staff shall ensure proper ergonomic techniques are used while handling pesticide materials to minimize or eliminate risk. To prevent injury, avoid bending or twisting movements (especially while lifting materials). Use carts or drum movers to transport large or heavy containers; see SOP 2.11 Ergonomics.

4.1.3 Precautions for the overall health and safety of staff shall be addressed, especially concerning personal protective equipment (PPE) requirements. Pesticides are highly toxic and can easily pass through skin and lung tissue to enter the blood stream. Ensure adequate ventilation is provided in areas where pesticides are processed. Since each situation requires evaluation of unique environmental conditions, experienced staff is encouraged to implement an appropriate and stringent PPE policy. To determine appropriate PPE level; see SOP 2.4 Personal Protective Equipment. The following PPE shall be used for pesticide management:

 safety glasses with side shields or goggles  footwear protection  nitrile or chemically resistant gloves  long-sleeved shirt and long pants or equivalent body protection  protective tyvek suit, apron, or equivalent body protection  respirator (if this Program has respirator plan)

4.1.4 Ingestion of pesticides may occur when eating, smoking, or drinking with pesticide- contaminated hands or from residue left by handling contaminated containers without the use of PPE. Avoid direct skin exposure or inhalation of pesticide chemicals. Skin contact/absorption occurs through contact with dust, liquid, or contaminated surfaces. Inhalation of pesticides may occur when containers are opened or spilled which may generate dusts or vapors.

4.1.5 This Facility may accept pesticides from any generator size; agricultural pesticides may be in larger quantities compared to residential pesticides. Agricultural pesticides are frequently

more toxic and in larger volumes and thus may present a greater health risk.

4.2 Spill response 4.2.1 Staff shall handle leaking pesticide containers using extreme caution to minimize exposures or spills. Immediately place leaking containers into secondary containment. Prevent slipping hazards and potential environmental impacts by immediately cleaning up spills; see SOP 2.6 Spill Response.

4.2.2 Facility staff shall be responsible for cleaning up incidental spills that may happen in the course of managing pesticides as they may pose immediate safety or health hazards. Staff shall be trained and able to respond to small spill situations. Only designated and trained emergency response teams shall respond to spills requiring assistance beyond the capabilities of staff; see SOP 2.6 Spill Response.

4.3 Medical monitoring. Staff exposed to pesticides at or above acceptable PEL levels for 30 or more days per year shall be part of this Programs’ Medical Monitoring Program. It is this employer’s responsibility to set up procedures to maintain a medical monitoring program and evaluate whether or not it meets the requirements of State regulations and sound risk management; see SOP 2.13 Medical Monitoring Program.

5. Processing pesticide wastes 5.1 Determining pesticide generation. Non-residential waste pesticides are generated from farms, farm applicators, or other licensed applicators. These materials may be commingled with HHW and are subject to the indemnification offered through the HHW program and state contract, provided the wastes are handled by the state agency’s authorized HW disposal contractor.

5.2 Pesticide management 5.2.1 Pesticides come in solid, liquid, or gaseous forms. Solid pesticides are often diluted with oil, water, or a solvent. Liquid pesticides are solutions or suspensions of the active ingredient in water or other solvent. Some liquid pesticides are produced in capsules; the active ingredient is encased in gelatin or plastic material. Aerosol pesticides deliver the active ingredient in a volatile petroleum solvent or other medium.

5.2.2 This Facility shall not accept bulk quantities of empty pesticide containers. MDA conducts collection events specifically for pesticide container recyclable material. Disposal of non- pesticide agricultural products (e.g., crop oil, surfactants, adjuvants, dye markers) may not be covered by the MDA reimbursement allotment.

5.2.3 Chemical recognition prior to waste processing is essential, as certain pesticides require special management; refer to the state-contracted HW disposal company for packaging

guidelines. Pesticides usually contain active ingredients and one or more inert ingredients; the percentages of these ingredients vary. Pesticide chemicals used to destroy forms of life are regarded as harmful or offensive and are classified by:

 the species intended to kill (e.g., insecticides, herbicides, fungicides, rodenticides).  their physical form (solid, liquid, or gas).  their chemical composition.

5.2.4 Carefully examine container integrity when accepting pesticides; older pesticides are often in leaking containers due to improper storage or age. Extra caution shall be taken by staff handling these pesticides to avoid exposures. While processing pesticide wastes:

 refer to the product label for specific heath and safety information.  ensure work areas have controlled or restricted access to the general public.  presort and place wastes into secondary containment before the end of the work week (preferably by the end of the work day); see SOP 4.4 Waste Packaging.  do not open containers or bulk contents.  do not place on product exchange or reuse shelves if the product is prohibited, banned, or restricted for use; only persons certified by MDA can apply restricted use products.

5.2.5 The EPA regulates the labeling and use of pesticides. Pesticide labels must specify handling precautions and include “signal words”, such as:

 DANGER – highly toxic.  POISON – may cause severe irritation; marked with skull and crossbones.  WARNING – moderately toxic; may also cause severe irritation.  CAUTION – slightly toxic; may cause moderate to mild irritation.

5.2.6 Each pesticide varies in its toxicity. Many act only as irritant, while others may be significantly more toxic. Common pesticides may include:

 Organophosphates – exposure to organo-phosphates reduces the cholinesterase level in the human body. Mild organophosphate poisoning may produce flu-like symptoms (e.g., headaches, fatigue, dizziness, sweating, nausea, stomach cramps, diarrhea). Slightly more severe poisoning can cause tightness in the chest, constriction of the pupils, and muscle twitching. Severe poisoning can cause difficulty breathing, loss of consciousness, and/or death. Symptoms of poisoning through skin absorption may be slower to occur. Exposure to very small amounts of organophosphates over a long period of time may produce these same symptoms.  Organochlorines – pesticides are persistent, they stay in the environment, and can build up in the human body. Symptoms of poisoning include dizziness, nausea,

abdominal pain, and vomiting. Severe exposure may produce irritability, convulsions, coma, and/or death. Long-term chronic overexposure to some pesticides may cause chronic health effects, including nerve damage, reproductive problems, allergic reactions, and cancer.

5.3 MDA contract utilization. This Program may choose to enter into a written agreement with MDA prior to accepting pesticides. If partnering with MDA, this Program shall receive a reimbursement allotment for processing pesticide waste materials. This Program shall comply with Universal Waste Rules when accepting waste pesticides from non-residential entities.

5.4 Tracking and reporting qualifying participants. Non-residential (agriculture- or business- generated) pesticides shall be recorded; see Attachment A of this SOP. Residential pesticide wastes shall also be recorded on a separate Pesticide Product Inventory form. Pesticide wastes are generally transported with normal HHW disposal shipments. Record the weight of each pesticide container; documentation shall also include: 1. the EPA Registration Number or 2. the product name and active ingredient(s)

Attachment A