Pollution Prevention Handbook - 7

ollution Prevention Handbook P Pesticide Management No. 10 in a Series of Fact Sheets.

Although you may not realize it, many of the activi- plicable waste management regulations. Wastes Department of ties that take place at your facility may pollute the should be disposed safely to minimize adverse im- the Interior environment and waste money. A facility such as pacts on the environment. yours can become more environmentally friendly Office of and cost efficient by reducing the amount of waste BENEFITS OF POLLUTION Environmental Affairs (OEA) generated. Everyone is interested in doing his/her PREVENTION & RECYCLING part to protect the environment, and simple steps Establishing a pollution prevention/recycling pro- such as recycling paper products and used oil prop- gram at your facility has many potential benefits for erly can help. Growing numbers of facilities are you. your facility, and the environment. Some of becoming aware of the environmental harm their these benefits are direct (e.g., cost savings from re- DEFINITIONS: operations may cause and are making a commit- duced raw material use), while others are indirect ment to reduce waste through a series of steps com- (e.g., avoided waste disposal fees). Source Reduction: monly known as pollution prevention. Reducing or eliminat- PURPOSE OF THIS FACT SHEET Pollution prevention is the use of materials, pro- ing the quantity and/or toxicity of a waste be- cesses. or practices that reduce or eliminate the This fact sheet introduces source reduction and recy- fore it is generated quantity and/or toxicity of wastes at the source of cling options that can start you on the road to elimi- (i.e., at the source). generation. Pollution prevention is a multimedia nating. reducing. or recycling wastes. This fact sheet approach that minimizes or eliminates waste re- describes many pollution prevention options that you, Recycling: leased to land, air, and/or water without simply as the manager of your facility, may adopt to reduce Recovering a waste shifting pollutants from one media to another. The wastes. The last page of this fact sheet is a list of from one process and Department of the Interior (DOI) considers source specific practices and techniques that employees at reusing it in the same reduction to be the most preferred environmental your facility can take to help implement your pollu- process or in another tion prevention/recycling program. The list of pollu- management technique for dealing with a waste process in an environment- tion prevention tips can be posted in your work area generation problem. In addition, pollution preven- mentally safe manner. tion is often the most cost-effective means to reduce to encourage employees to use environmentally-safe environmental and health risks associated with waste. practices. Pollution prevention is often cost effective because it may reduce raw material losses; reduce reliance DEVELOPING A on expensive “end-of-pipe” treatment technologies POLLUTION PREVENTION/ and disposal practices; conserve energy, water. and RECYCLING PROGRAM raw materials; and reduce the potential liability as- Recognizing the Need for a Pollution sociated with waste generation. The Pollution Pre- Prevention/Recycling Program vention Act of 1990 makes pollution prevention a The first step is to recognize the need for waste national policy for environmental management. reduction at your facility and secure staff com- mitment to achieve source reduction and recy- For wastes that cannot be reduced at the source, cling goals. Once you have convinced your staff DOI recommends that generators consider recy- of the benefits of a pollution prevention/recycling cling as the next best option. Wastes that cannot be program, use the steps outlined below to help begin reduced at the source or recycled should be stored, designing your program. Each step can be as basic treated, and/or disposed in accordance with all ap- or complex as you feel is necessary to meet the Implementing Your Pollution Prevention environmental goals that you set for your facility. Program The final steps in the process are implementation of Planning and Organizing the pollution prevention program and evaluation of The next step is to plan and organize your pollution its success. After the program is implemented, an prevention program. This involves establishing pro- evaluation can increase the overall success of the gram goals and objectives, as well as staffing a task pollution prevention program by identifying defi- force to conduct a pollution prevention “assess- ciencies that remain. Specifically. ment” of the facility. the evaluation may identify new assessment targets and additional pol- Conducting a Pollution Prevention lution prevention program options for investigation. Assessment The goal of a pollution prevention assessment is to If you are interested in obtaining additional identify opportunities at your facility where you can reference information about developing and reduce waste generation, emissions, and environ- implementing a pollution prevention program at mental damage. The assessment can involve col- your facility, contact EPA’s Pollution Preven- lecting process-specific information, setting pollution Information Clearinghouse (PPIC) at (703) Waste reduction can: tion prevention targets. and developing. screening. 821-4800. PPIC is a free service that provides and selecting pollution prevention options for fur- the public with technical, programmatic, and ther study. Pollution prevention assessments can be policy references about source reduction and extensive process examinations using scientific recycling. methodology, or they can be less formal evaluations of waste generation and management prac- We recommend the following documents that tices. discuss pollution prevention program options and waste assessments in greater detail. They Evaluating Pollution Prevention Options are available from PPIC free of charge: Once pollution prevention options are identified. Waste Minimization Opportunities Assesment evaluate the technical and economic feasibility of Manual, U.S. EPA, Hazardous Waste Engineer- each option. These evaluations can help determine ing Laboratory (EPA/625/7-88/003). July 1988. which pollution prevention options are most suit- Request PPIC document # WAM-3. able for implementation at your facility. Pollution prevention options range from simple and easy-to- Profiting From Waste Reduction in Your- Small implement techniques to detailed engineering or Business, Alaska Health Project, 1988. Request design changes. The options you choose will de- PPIC document # WAM-2. pend on your facility’s operations, needs. and environmental goals.

Types of Pollution Prevention Techniques and Options

Production Planning and Sequencing - Plan and Waste Segregation and Separation - Avoid mix- sequence production to maximize raw materials. ing different types of wastes. This makes the Process or Equipment Modificaton - Change recovery of wastes easier by minimizing the number the process, parameters or equipment used in that of different constituents in any given waste stream. process to reduce the amount of waste generated. Closed-Loop Recycling - Use or reuse of a waste Raw Material Substitution or Elimination - Re- as an ingredient or feedstock in the production pro- place existing raw materials with other materials cess on site. Recycling in which a waste is recov- that produce less waste, or a non-toxic waste. ered and reused in the same production process on site as an input is a form of pollution prevention. Loss Prevention and Housekeeping - Perform preventive maintenance and manage equipment and Training and Supervisor - Provide employees with the information and the incentive to minimize materials lo minimize opportunities for leaks, spills, OEA evaporative losses and other releases of potentially waste generation in their daily duties. Train employ,- toxic chemicals. ees to practice proper and efficient use of tools and Pollution Prevention supplies. and to understand and support the Handbook company’s pollution prevention goals. 2 ollution Prevention/Recycling Checklist Pesticide Management

This checklist is designed to encourage thought from outlasting their shelf life. Practice “first-in, OEA would like to on ways to reduce waste in your shop. By first-out” inventory control - use older supplies thank the following answering the following questions, you may iden- before new materials. for their documents tify some easy-to-implement pollution prevention that were used to and recycling options as well OS more comprehen- Is access to hazardous material supplies develop this fact sive approaches to reducing wastes. Q limited? sheet: For the purposes of this fact sheet, the term When possible. assign control over hazardous mate- “‘pesticide” refers to herbicide, fungicide, germi- rial supplies to limited numbers of people who are California DHS Fact cide, insecticide, and other substances or mixture trained to handle hazardous materials and who un- Sheet - “Waste Reduc- of substances intended for preventing, destroy- derstand the “first-in. first-out” inventory policy. tion for Pesticide For- ing, repelling, or mitigating any pest. Give one person the responsibility of maintaining mulating Industry.” the storage area. Limiting access to supplies prompts GENERAL PRACTICES employees to conserve raw materials. University of Is your facility in compliance with Is the hazardous material storage area California - “The Safe Q environmental regulations? Q routinely checked for leaks? and Effective Use of Pesticides” Pollution prevention can help keep your facility in The cheapest way to reduce pollution is to prevent compliance with environmental regulations by re- from reaching the environment in the first place. North Carolina Agri- ducing hazardous waste generation. storage. treat- Conduct routine inspections and identify and repair culture Extension ment, and disposal at your facility. If you are leaking containers to stop unnecessary waste gen- Service - “Disposal of uncertain of whether your facility generates hazard- eration and spills. ous waste. contact your state’s hazardous waste man- Unused Pesticides, agement agency. Are empty hazardous material containers Tank Mixes, and Q and expired hazardous materials returned Rinsewater," “Reduc- Have you conducted a pollution to the supplier? ing Pesticides and Q prevention assessment? Empty containers may contain residues that must be Saving Money Using A pollution prevention assessment is a procedure to treated as a hazardous waste. Return empty con- Integrated Pest Maw help identify waste sources. and identify, evaluate. tainers to the supplier for proper reuse or recycling. agement, “Protecting and implement options to reduce or eliminate wastes. Rather than disposing of expired material, return it Mountain Springs EPA has developed a rigorous waste assessment to the supplier for recycling. Some suppliers pro- from Pesticide Con- methodology for use by waste generators. This vide credit toward your next purchase. tamintion, “Prevent- process is described in the Waste Minimization Op- ing Pesticide Pollu- portunity Assessment Manual, available from EPA’s Are your facility's segregated? tion of Surface and PPIC. Once a pollution prevention assessment is Q Ground Water, ” and complete, it should be reviewed periodically to de- Mixing wastes may increase their treatment cost and “Pesticide Container termine if operations or opportunities have changed. often make recycling more difficult. In particular. keep Disposal ” hazardous and non-hazardous wastes separate. Do not Are employees trained in the proper use, mix used oil, solvents, and pesticide residuals. Q recycling, and/or disposal of hazardous materials? GOOD HOUSEKEEPING Properly trained employees can help to ensure that the right chemical is used for the right job, and that chemi- Are lids kept closed and bungholes tightly cals are safely and properly handled and disposed. Q plugged on drums or containers of pesticides and other materials containing organic Do you have inventory procedures for raw solvents? Q materials? OEA Keeping lids closed and bungholes tightly plugged Strict inventory control is the most effective and cost- Pollution Prevention prevent the evaporation of solvents. reduce spill efficient way to prevent usable materials from need- Handbook incidents, limit contamination from dirt and mois- lessly becoming wastes. Improperly stored, labeled. or ture. and minimize health hazards and air pollution. outdated material can become hazardous \waste. Rou- 3 Trash can lids should also be kept tightly closed. tinely check the date of materials to prevent them Is equipment routinely checked for untargeted animal populations. and areas fre- Q leaks? quented by people. Small leaks can cause big problems. Routinely Develop special application patterns for the site inspect all equipment for leaks and perform regu- to accommodate hazards and environmental lar equipment maintenance. conditions. Are spills of materials common? Avoid spraying pesticides on wetlands or near Q water sources (most pesticides are highly toxic to fish and other aquatic organisms). Spills may be common, but preventable. sources From the White House of pollution. Avoid potential spills by keeping a Avoid using aerial applications and/or mists (October 31,199l): clean and orderly shop. Reduce the likelihood of near water sources; such applications may mi- liquid spills by using a gravity spigot or pump to grate and deposit in waters. Leave unsprayed Federal agencies and dispense bulk liquid. Always use a spout and buffer zones to protect sensitive areas and ani- facilities must initiate funnel when transferring liquid from a large con- mal habitats. programs lo promote tainer to a smaller one. When possible, scrape up cost-effective waste Are pesticides applied to minimize spilled material rather than using absorbent mate- reduction and recycling excessive spraying? rial. water, or solvents. Avoid washing material Q of reusable materials. It is important to ensure that your pesticide applica- spills down floor drains. Depending on the sub- Agencies that generate tion rate is uniform and does not exceed recom- stance spilled. this practice can harm the environ- energy from fossil fuel mended application rates, which are usually out- ment and may be illegal. Train personnel in spill system must, whenever management and have proper spill containment lined on packaging and are dependent on soil conditions. rainfall levels, and plant type. Calibrate possible. begin to use equipment available on site. energy or fuels derived pesticide application equipment to ensure that pesti- from solid waste as their cides are applied at the intended rate while avoiding PROCESS/APPLICATION primary or secondary excess and overlapping during application. Dyes MODIFICATION energy source. can be added to the chemical to facilitate uniform Does your facility utilize an Integrated application and monitor treatment results. In addi- Agencies are required Q Pest Management program? tion. choose spray equipment. such as microfoil to adopt “environmen- Integrated Pest Management (IPM) programs com- booms. that direct the chemical to the target. tally-affirmative” pro- bine chemical, cultural, and biological practices Consider using alternative pesticide fomulations curement program that into one program to manage pest populations. and applications, such as granular formulations and will enhance Federal IPM principles incorporate preventive practices soil injection application. Each alternative has ad- procurement of prod- (such as timely planting, crop rotation, and sur- vantages and disadvantages and should be used ucts made from recycled veying fields for pest density), remedial practices only when appropriate. and recyclable material- (such as timely and spot spraying of pesticides als. Do your pesticide application techniques only when required), and economic thresholds. minimize the potential threat of runoff In addition to required thus reducing the amount of chemicals used by Q and leaching of pesticides? standards, agencies are applying pesticides only when necessary at the encouraged to partici- minimum effective rate. DOI strongly supports Pesticides have the potential to runoff to surface water and to leach into and contaminate ground water pate in the delvelopment the use of IPM programs and many bureau facili- of voluntary environ- ties have already implemented such plans. Con- supplies. The following practices can help minimize runoff of pesticides: mentally sound, and tact your Bureau’s Natural Resources Manage- economically efficient Practice spot application of pesticides; don’t ment Division for additional information. waste reduction, recy- spray over an entire area unless treatment is cling, and procurement Does your facility have a safe pesticide required for the entire area. management program? standards. Q Use contact pesticides that do not have to be The following variables are important in development- incorporated into the soil. Tree injection methods, ing a safe pesticide application program at your though labor intensive. are very effective and mini- facility: mize negative impacts to the environment. l Consider the weather’s impact on pesticide Use row banding application techniques to limit migration (i.e., drift or runoff). the amount of pesticides applied. OEA l Control pesticide droplet size and deposition. Uncontrolled deposition may result in over Does your facility mix surplus Pollution Prevention application. Q pesticide? Handbook It is important to carefully calculate the volume of l Be aware of the application site and its haz- 4 ards. including locations of groundwater vvells. pesticide solution you will use on a given field and mix only this amount. Excessive mixing wastes l Install automatic enclosed cut-in hoppers for money and may cause disposal problems. Surplus bags of concentrated pesticide dust/granules to spray can be put back on the field. on the row ends. minimize fugitive dust emissions. on field borders. or on another appropriate location, l Use pumps and piping to transfer liquids to as long as the labeled rate is not exceeded. minimize potential for accidental spillage. Have you considered using alternative TREATMENT AND DISPOSAL Q pest management products? Using less-soluble, less-leachable, less-persistent, Does your facility treat pesticide and less-toxic pesticides whenever possible can help Q contaminated wastewater that cannot be reduce adverse environmental impacts and waste eliminated, disposed, or reused through disposal costs. Check with your local agricultural pollution prevention/recycling options? extension agent or chemical supplier on the availability of such products for your crops. Treatment options include:

l Chemical precipitation

WASTE MINIMIZATION l Biological treatment . Carbon adsorption Have you considered recovering, reusing, l Hydrolysis and recycling resources? Q l Chemical oxidation The key to reducing waste is to efficiently use all l Resin adsorption solvents and containers that have had contact with l Steam or air stripping. virgin pesticides. Some of the ways that you can reuse resources are as follows: Do you triple-rinse all pesticide containers before disposal? l Reuse spent solvents and waste waters from Q equipment decontamination as make-up water Federal regulations require rinsing empty pesticide in subsequent formulation of pesticides. containers at least three times before disposal. This rinsewater can be used in mixing and application l Collect (and, if necessary. treat) floor washwater or stormwater runoff from process areas for activities. Rinsewaters can also be reused in formu- use/reuse. lation of pesticides. Spray solution is often left at the bottom of the l Clean reusable concentrated pesticide containers (i.e.. 30- and 55-gallon drums). so that they spray tank and in hose lines. An in-field sprayer may be sold to scrap dealers as a non-hazard- rinse system, such as a gravity flow system or a ous waste and/or returned to the chemical dis- pressure flow system, can reduce the concentration tributors for reuse. and volume of this residual pesticide solution. Both systems involve mounting a clean water tank on a l Return drums to pesticide supplier for a refill of sprayer for rinsing the sprayer tank and lines before the same pesticide. leaving the field. The rinsate can be sprayed on the l Ship unrinsed drums to an offsite drum field borders, row ends. or over a portion of the crop reconditioner who is licensed to handle pesti- as long as you do not exceed application rates. cide containers. Does your facility dispose of pesticide/ Have you considered modifying the Q herbicide containers properly? Q processes that your facility uses to reduce Liquid formulation containers and dry formulation con- the volume of waste and solvent used for tainers (bags and boxes), after being emptied and triple- the decontamination of equipment and rinsed (and punctured in the case of cans). can be floors exposed to pesticides? disposed of at a licensed sanitary landfill (at the

l Minimize waste during decontamination by us- operator’s discretion). It is often necessary to clean, ing: high pressure spray nozzles; water knife puncture. and crush your cans and drums to make them spray nozzles; portable steam cleaners; wiper acceptable to landfill operators, who are liable for any blades to physically wipe down the sides of environmental or health problem that result from the mixing tanks: and dedicated mops/squeegees wastes they accept. for floor washing. The uses of reusable and returnable containers that OEA Pollution Prevention l Use dedicated mixing and application equipment promote waste minimization are new approaches to to minimize cleaning operations and wastes. the problems of container disposal . Several chemical Handbook companies have begun to market their pesticides in l Employ vacuum systems that allow reuse of 5 contaminated dusts. reusable containers that can be returned lo the dealer and refilled. The reusable containers are “dedicated” vent foaming and improve deposition, and check (i.e.. they can only be used for that same chemical). compatibility of pesticide tank mixes or fertilizer- Returnable containers are currently being investi- pesticide combinations. gated by the pesticide industry; check with your agricultural chemical dealer about such containers. CLOSING THE LOOP

l DO NOT BURY triple-rinsed pesticide con- Have you researched potential markets for tainers or other pesticide wastes on your land. recyclable materials? They may contaminate your ground water drink- Q Contact potential recycling markets to determine Make It Work! ing well and/or the environment. If possible, prices and available services. Learn about restric- Motivating employees reuse or recycle these containers. Otherwise, tions on contaminants and establish an acceptable to reduce waste gen- dispose of them in accordance with state or schedule for pickup. Seek outside technical assis- eration is key to a local waste disposal requirements. tance from consultants, waste haulers. local and state successful pollution l DO NOT BURN pesticide containers. Some government, and local recycling businesses to help prevention/recycling pesticides produce toxic fumes when burned, you with terminology, markets, and pricing. program. The lost which may be carried over great distances in page of this fact sheet Does your facility purchase recycled the smoke. Some pesticides, when burned, contains easy-to-follow materials? generate dioxin. an extremely dangerous mate- Q pollution prevention rial. Burning pesticide containers is not only When practical and cost effective, try to procure techniques that may be dangerous. but is also illegal. recycled and recyclable products instead of items implemented today. It composed of non-recycled materials. Consider en- Does your facility generate hazardous is designed to be re- ergy and resource issues associated with the manu- moved from this book Q waste? facturing, use. and disposal of the product. To deter- Certain leftover pesticide mixes are considered hazard- let and posted where mine the availability of recycled and reusable employees can see it. ous waste, and applicators who generate more than 2.2 products, examine the following: pounds of such waste in a month must dispose of it By discussing polloution l GSA’s introductory new product schedules. at an appropriately permitted facility within 90 days. prevention with your employees, you may be Contact your State RCRA Hazardous Waste Manage- l GSA publication “Market Tips.” which presents ment Agency for additional information. information on initiatives of the Federal Supply happily surprised with Service. their suggestions and enthusiasm for reduc- WORKER SAFETY l GSA Federal Supply Service contracts. some of ing hazardous wastes. which may include listings of recycled products. Are employees trained in the use of l Vendor catalogs, which may provide the most proper safety equipment? Q current information available. Training facility personnel in personal safety can Further. consider establishing procurement contracts help to prevent overexposure and resulting short- term or long-term illness or even death. Personal that require vendors to supply recycled products such as tires, batteries. and petroleum products. You safety equipment can include waterproof aprons, waterproof boots, face shields, goggles, full-face might also establish contracts that require vendors to purchase back spent packaging materials and con- respirators, waterproof gloves, and waterproof head gear. The most appropriate equipment will depend tainers (wood pallets, empty drums. cardboard boxes, on the nature of the work being done and the pesti- crates, etc.). cide being used. EMPLOYEE PARTICIPATION Workers should be medically examined and regularly tested to monitor exposure and health. Personnel train- Do you have an employee incentive ing should also include cleaning and maintenance of Q program to promote pollution prevention? safety equipment. People who have not been trained or The key to any pollution prevention effort is em- certified should not formulate and/or apply pesticides. ployee participation. Training and educational pro- Are safe pesticide mixing techniques grams can inform employees about pollution pre- Q used? vention concepts. Public recognition. awards programs, and a suggestion box can also encourage Safe mixing includes conducting mixing activities OEA in a clear and open area that can be easily cleaned their participation. Pollution Prevention should an accident occur. Employees should be instructed to wear protective equipment, use clean Handbook water, test water pH. measure pesticides safely and 6 accurately. use proper adjuvants to correct pH. pre- TOP POLLUTION! Pollution Prevention Tips for Pesticide Management

l Keep your shop clean and or- Use the right spray equipment derly to eliminate spills and leaks. for the job. Using improper equip- Check the shop for mislabeled, ment can result in over-application, leaky, and dripping containers. environmental damage, and extra costs for the operation. l Use a “first-in, first-out” inventory policy for raw materials to pre- Use spot application techniques. vent them from exceeding their Avoid spraying an entire area shelf life prior to use. when it’s not necessary. l Wear the correct personal safety Avoid spraying pesticides in envi- equipment for the job and the ronmentally sensitive areas, such chemicals you are using. as wetlands and ground water wells. l Be informed. Read the pesticides label and Material Safety Data Always triple-rinse containers Sheet (MSDS). and hoses that have been exposed to pesticides. Use the rinse water l Put a lid on it! Make sure that for other appropriate mixing and container and trash can lids are application activities. sealed to prevent evaporation, contamination, and spills. Never mix different wastes. l Stop Spills! Don’t pour materials Never bury or burn pesticide con- directly from one container to an- tainers. Dispose of them properly. other. Use dedicated and labeled Talk to your manager about new spigots, pumps, and funnels. ideas for pollution prevention and l Mix only as much pesticide that waste reduction. will be necessary for the job at hand. Surplus mixtures can become wastes.

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