MANAGING PESTICIDE WASTE
|Hazardous Waste Program fact sheet||
|Division of Environmental Quality Acting Director: Steve Feeler||
This fact sheet provides general information to help pesticide applicators determine whether their leftover, un-wanted pesticide is solid waste or hazardous waste and how to properly dispose of each type. Disposal is an important part of responsible pesticide use, as improperly disposed pesticide wastes can create serious hazards for human health and the environment. Businesses should refer to this fact sheet and Making the Decision to Discard a Pesticide Decision Tree as general guidance only and should review appropriate state and federal laws and regulations before making the ultimate decision of how to manage waste pesticides.
Keep these tips in mind to reduce the need for waste pesticide disposal:
- Use an integrated pest management (IPM) program to manage pests, therefore reducing the need to use pesticide.
- Always read the label carefully before you buy a product and make sure the product is intended for your specific use.
- Use the appropriate amount of pesticide for your job. Applying more pesticide than the label directions indicate is a violation of federal law can waste money and may harm people, pets or the environment. It may even be less effective at controlling the pest.
- Do not assume a pesticide purchased for one type of treatment can be used in another setting without first checking the label; many pesticides have similar names and ingredients despite being intended for very different uses.
- Always purchase the least toxic pesticide to get the job done.
- Buy only what you need. Storing and disposing of leftover pesticide can lead to unnecessary risks.
- Review the storage and disposal section of the label for information on how the product should be stored and disposed of, including the empty container. Store all pesticides safely out of reach of children and pets.
- Re-read the label before using or re-using a pesticide, do not rely on your memory.
- It is against the law to use pesticides in any manner other than those specifically listed on the label.
- Never remove a pesticide label from the container, or use unlabeled pesticides.
The federal hazardous waste regulations are in the Code of Federal Regulations, Title 40, Part 260 through Part 280 (40 CFR 260-280). The Missouri Hazardous Waste Law is in the Revised Statutes of Missouri (RSMo), Sections 260.350-260.575. The hazardous waste rules are in the Code of State Regulations, Title 10, Division 25 (10 CSR 25).
What is a pesticide waste?
Pesticide waste is any material which contains any concentration of pesticide which has been declared a waste or can no longer be used for its intended purpose. This includes such things as: rinse material from containers and spray equipment, left over spray solutions, excess pesticides, empty containers and banned, canceled or suspended pesticides.
Are all pesticide wastes considered hazardous wastes?
Under federal regulations, commercial chemical products such as pesticides become "solid wastes" and thus, potentially hazardous wastes, at the point when the pesticide's holder (i.e., end-user, dealer, distributor, or registrant) decides to discard them. If a pesticide product or the active ingredient of the product is listed in 40 CFR 261.31 or 261.33 (Table 1) or exhibits a hazardous waste characteristic identified in 40 CFR 261.21 through 261.24, it then becomes a hazardous waste at the point when its holder decides to discard it. Parts 261.21 through 261.24 identify the following criteria: ignitability, corrosivity, reactivity or toxicity characteristic. Most hazardous waste pesticides fall into the toxicity criteria due to the toxic organic properties.
An environmental consultant or licensed hazardous waste disposal contractor can help in making the determination if a waste is hazardous and can help dispose of the unwanted pesticide. The Missouri Department of Natural Resources maintains a list of Missouri licensed hazardous waste transporters. The department also provides a Missouri Commercial Hazardous Waste Facilities list (PUB 968) of companies with permits to accept hazardous waste. It is always recommended to call several consultants/contractors when obtaining bids for disposal.
More ways to help determine if a pesticide is a hazardous waste include:
- Checking the Material Safety Data Sheet for the pesticide
- Talking to the product supplier and/or manufacturer
- Reading the product labels—this should be done prior to purchasing any pesticide product
How to dispose of pesticide classified as hazardous waste?
Businesses generating hazardous waste must follow federal and state laws and regulations, depending on the type and amount of hazardous waste generated. Publications summarizing hazardous waste regulations include Handbook for Small-Quantity Generators (PUB 2174) and EPA’s guidance document, Typical Wastes Generated By Industry Sectors.
Determining how much hazardous waste pesticide is generated in any one month and accumulated at any one time is necessary information for determining generator requirements. Hazardous waste generator requirements can be found at 10 CSR 25-5.262 and a summary of the regulations can be found in a fact sheet titled Hazardous Waste Generator Status Guidance (PUB 2224).
Disposal of a pesticide should be the last option remaining when dealing with unused pesticide. To avoid the problem of dealing with unused pesticide products, purchase only what can be used in one year. Also, before disposing of a pesticide try to give it to someone, provided the pesticide is in its original, fully labeled container, who can use it for its intended purpose or use up the product per label requirements – if the product is still legal to use. If you cannot find someone who can use the pesticide and you no longer have a use for the product, below are options for disposing of an unwanted hazardous waste pesticide.
- Registering as a large quantity generator (LQG) or small quantity generator (SQG) if 100 kg (220 pounds) or more of non-acute hazardous waste and 1 kg (2.2 pounds) or more of acute (P-listed) hazardous waste is generated in one month or accumulated at any one time. Table 1 below lists some acute and non-acute hazardous waste pesticides with their specific hazardous waste identification under the “RCRA #” column. Hazardous Waste Generator Registration, Reporting and Waste Fees (PUB 2254) summarizes registration requirements.
- If you have less than the above mentioned weight of hazardous waste pesticide you may be able to dispose of it as a conditionally exempt small quantity generator (CESQG). A fact sheet titled Managing Conditionally Exempt Small Quantities of Hazardous Waste (PUB 128). CESQGs may transport their own hazardous waste within Missouri. Under this standard a manifest or a licensed hazardous waste transporter is not required if you do not exceed the regulated amounts of waste. However, you will need to follow applicable U.S. Department of Transportation requirements for the waste being shipped.
- Disposing of the hazardous waste pesticide under the universal waste rule in Missouri is an option that can reduce the regulatory burden on businesses allowing less stringent disposal requirements versus disposal under the more stringent hazardous waste regulations. The Universal Waste Rule in Missouri (PUB 2058) summarizes the requirements of the rule.
Pesticide Container Disposal
In addition to label requirements, some pesticide containers must meet the requirements set forth in 40 CFR 261.7, Residues of Hazardous Wastes in Empty Containers, to be considered empty. Empty containers that once stored pesticide classified as hazardous waste versus containers that stored pesticide not classified as hazardous waste may require different treatment methods for declaring the container empty. After the container is made empty according to 40 CFR 261.7 standards, the container can be punctured and then disposed of in a permitted solid waste landfill.
Disposal of Pesticides Not Classified As Hazardous Waste
If you are absolutely certain the pesticide is not classified as a hazardous waste the pesticide may be solidified and placed into the sanitary landfill if the landfill chooses to accept it. However, because all pesticides are made to destroy insects or other organisms harmful to cultivated plants or to animals, disposal should be done in a professional manner preferably following the hazardous waste or universal waste laws and regulations.
A listing of the pesticides from 40 CFR 261.31 through 40 CFR 261.33 is provided below in Table 1. Please note the table may not include all hazardous waste pesticides. Table 1 includes various Hazardous Waste Codes (RCRA #) that have special meanings and are defined as follows:
F-List hazardous wastes from nonspecific sources (40 CFR 261.31)
P-List acutely toxic hazardous wastes from specific sources (40 CFR 261.33(e))
U-List toxic hazardous wastes and other commercial chemical products (40 CFR 261.33(f))
Toxicity characteristic hazardous wastes that meet or exceed the regulatory level listed in the table (as shown by laboratory analysis)
Table 1. Pesticides in parts 261.31 and 261.33
|Pesticide/Chemical||CAS #||RCRA #||Toxicity Characteristic #||Regulatory Level (mg/L)|
|2,4-D, Salts, Esters and Acids||Various||U240||D016||200.00|
|2,4,5-T, Salts, Esters and Acids||Various||F027|
|Phenylmercuric Acetate (PMA)||62-38-4||P092|
|Silvex, Salts, Acids and Esters||Various||F027|
|Strychnine And Salts||60-41-3||P108|
|Zinc Phosphide (<10%)||1314-84-7||U249|
EPA Guidance document, Typical Wastes Generated by Industry Sectors http://www2.epa.gov/hwgenerators/typical-wastes-generated-industry-sectors
Handbook for Small-Quantity Generatory* (PUB 2174) http://dnr.mo.gov/pubs/pub2174.pdf
Hazardous Waste Generator Registration, Reporting and Waste Fees* (PUB 2254) http://dnr.mo.gov/pubs/pub2254.htm
Hazardous Waste Generator Status Guidance* (PUB 2224) http://dnr.mo.gov/pubs/pub2224.htm
Licensed Hazardous and Infectious Waste Transporter List* http://dnr.mo.gov/env/hwp/transporters.php
Make the Decision to Discard a Pesticide Decision Tree Z:\env\hwp\docs\16.01 HWP - Decision Tree 3.pdf
Making a Hazardous Waste Determination (PUB 919) http://dnr.mo.gov/pubs/pub919.htm
Managing Conditionally Exempt Small Quantities of Hazardous Waste* (PUB 128) http://dnr.mo.gov/pubs/pub128.htm
Missouri Commercial Hazardous Waste Facilities List* (PUB 968) http://dnr.mo.gov/pubs/pub968.htm
The Universal Waste Rule in Missouri* (PUB 2058) http://dnr.mo.gov/pubs/pub2058.htm
Pesticide Collection Web page http://dnr.mo.gov/env/hwp/pesticide/index.html
Code of Federal Regulations http://www.ecfr.gov/cgi-bin/ECFR?page=browse
Missouri Code of State Regulations for Department of Natural Resources http://www.sos.mo.gov/adrules/csr/current/10csr/10csr
Missouri Revised Statutes http://www.moga.mo.gov/mostatutes/statutesAna.html