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A NATIONAL REPORT CARD ON PESTICIDE STEWARDSHIP
by Robert L Denny II

ABSTRACT

This paper presents an assessment of how states compare in terms of their HDPE pesticide container collection programs and unusable pesticide/"Cleansweep" programs. States are grouped semi-quantitatively into four categories: "Competent", "Reasonably Effective", "Spotty", and " Inadequate." Reasons for the different rankings are discussed, providing a basis for further discussion as to how states may improve their programs.

INTRODUCTION

In my eight years associated with the Agricultural Container Research Council, and in my previous positions at the EPA and as Executive Director of Maine’s pesticide regulatory agency, I have had a unique opportunity to meet, correspond, and work with literally hundreds of men and women concerned about proper pesticide stewardship. Virtually everyone has a grasp on the concept of pesticide stewardship: that is, the ideal goal of preventing a potentially harmful substance from impacting humankind or the environment. What differs among individuals is 1) the setting of priorities for achieving pesticide stewardship, and 2) the effective resources that anyone can mobilize in order to realize any stewardship goal. I will not judge or comment here on the setting of priorities for what stewardship issues demand or deserve our attention. The history of this conference has judged and prioritized those issues for us. For one and a half decades this forum has aired, discussed, and disseminated information on two major pesticide stewardship topics: the disposal of unusable pesticides and the collection and disposal or recycling of pesticide containers.

The subject of this presentation, therefore, is the comparison of resources that are available to users of crop protection products or pesticides once the useful life of that chemical is past. This remaining "challenge" for a user takes the form of either unusable product or the residual packaging that originally held that product. Unfortunately, the user’s ability to meet this "stewardship challenge" may depend upon their geographic location.

THE GRADE

I have taken a bold step and categorized the 50 States into four levels of stewardship. Table 1 shows a ranking of State Unusable Pesticide Programs based on recent data from Cubbage and Potter (1999). Table 2 shows a ranking of State Container Collection Programs based on unpublished ACRC data. The data are also illustrated in Figures 1 and 2 respectively.I have no doubt that my perceptions may be wrong in some instances, and if a State’s level of service is more competent that judged here, I accept all blame. I suspect I will not hear from those who are actually less competent than judged. And like any professor grading a student’s performance, I recognize that some efforts are on the plus or minus side of the assigned grade. I opted not for a numerical or alphabetical score, but one of four descriptors of the general level of service provided. These are ranging from the highest to lowest: "Competent", "Reasonably Effective", "Spotty", and "Inadequate". A discussion may further illustrate the general status of our nation’s pesticide stewardship

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Table 1: RANKING OF STATE UNUSABLE PESTICIDE PROGRAMS, 1999

* Universal Waste Rule adopted, including for pesticides.

¹ California is difficult to compare to other states, as its volume is large, yet the coverage is dictated by the County Commissioner system. Some pesticides are undoubtedly going into the state’s extensive HHW programs. Ranking may verge on the competent level.

+ Could earn "competent" rating by increasing number of geographically dispersed collection sites.

Figure 1: RANKING OF STATE UNUSABLE PESTICIDE PROGRAMS, 1999 please click on image to see map Ê

Table 2: RANKING OF STATE CONTAINER COLLECTION PROGRAMS, 1998

¹ state may have sustainable levels of container collection given levels of pesticide use in region.

² increasing amount of plastic collected every year.

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Figure 2: RANKING OF STATE CONTAINER COLLECTION PROGRAMS, 1998 please click on image to see map Ê

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Competent Ranking

Competent means that most users of crop protection chemicals and other pesticides within that state have access to either free or reasonably priced unusable pesticide disposal and HDPE pesticide container recycling. This does not mean that these programs are perfect or that they have no room for improvement. "Competent" programs, in general, have moved away from pure "collection day" events held once or more frequently per year. These states recognize that individuals and businesses will better participate if the program is not only affordable, but is convenient.

The most important characteristics of a "competent" program are that the state has a stable source of funding and an infrastructure adept at handling the stewardship effort despite changes in the economy, personnel, or political climate.

Unusable Pesticides-Competent

Some of these states in their unusable pesticide cleanups, like Maine, North Carolina and Kentucky, emphasize the "milk run" approach. In this mode, the state accumulates calls for assistance during a year or shorter period, maps out a response route and sends inspectors or contractors out to the places of business to pick up the unwanted product. This approach minimizes chances for spills from inadequate or deteriorated containers.

The true epicenter for effective public support for pesticide users in the US has to be the upper plains of the Midwest. Iowa, Kansas, Minnesota, Michigan, North Dakota, Ohio and Wisconsin all have outstanding programs and the most northerly of these states have had exemplary programs for some time. Three of the four have poundage returns on a par with large agricultural states like California. And even North Dakota collects seven times the amount collected in Florida. Most of these states are trying out permanently manned sites for returning unusable pesticides during routine business hours.

Maine leaps back into this select company after a hiatus spawned by an early 1990’s cash-starved legislature. Only a handful of programs date from the early 1980’s and Maine now joins the rest of those innovators back in the top category.

Tiny Delaware deserves a great deal of credit here. Few Delmarva or Brandywine Valley farmers are ever far from the rotating solid waste facilities designated for yearly collection. Their total recovery in 1998 was more than many traditional "farm" states; more than Indiana, Illinois, Georgia, and Florida.

And last, but not least, the Texas Country Cleanup sponsored by the Texas Natural Resources Conservation Commission also merits high praise. Texas doesn’t just quit after collecting unusable pesticides, but collects batteries, tires, barb wire, used oil, filters, and yes, the kitchen sink!

Pesticide Containers-Competent

When discussing pesticide container stewardship, one might suppose that the access to proper stewardship options would be more uniform. Why? Because the Agricultural Container Research Council, a consortium of crop protection and pesticide producers, distributors, and packagers, equitably support and subsidize container collections throughout the United States. The ACRC pays the largest bills: the collection, granulation, storage, relocation, and monitoring of granulated pesticide container plastic. The ACRC even researches safe or acceptable end uses, and assures the public that the material is available only to appropriate end-users. Why then, do not all pesticide users live in areas judged to be fully "competent"? The answer lies in the simple truth that all container stewardship is a cooperative process. Truly competent programs must have a strong local advocate in order for proper coordination, education, and communications to occur. This local entity can be a state agency like the Department of Agriculture in North Carolina or the Texas Natural Resources Conservation Commission. In Nebraska, the competence and leadership mostly falls to one man, Dr. Larry Schulze of the Nebraska Cooperative Extension Service. Just this year, 1999, when container collections have fallen in most areas due to decreased exports or weather conditions, Nebraska has continued to grow in plastic container collection. In other competent states, the local drive comes from a combination of local government, state agricultural chemical associations, county extension agents, the ACRC’s regional contractor, and other organizations. One of the most unique examples is the cooperation of USAg Recycling, their local subcontractor and the Arkansas Future Farmers of America serving that mid-South state. The bottom line is that without someone or some consolidation of leadership, outstanding pesticide stewardship does NOT occur.

Reasonably Effective Ranking

Reasonably Effective most often means a program that is either on the way to "competency" or one that with a few changes could be very competent. States in this category provide access to the majority of users of pesticides, and they concentrate on the areas where pesticides are used the most. Some states are in this category due to the short time that they have achieved successful outcomes.

Unusable Pesticides-Reasonably Effective

Kansas and Iowa are examples of good programs that were in this category based on last year’s data. They were operated efficiently and provided reasonable services to their citizens and the environment. Their only problem was they lacked a track record and better distribution of their services. One year later, both states are in the "Competent" category. Several others probably just need a little time to achieve the status of the top group. Georgia, Massachusetts, and Nebraska are on their way up and appear in this category based on the very latest reported collections. I personally know how little Utah does with container stewardship, I was surprised at the efficient, effective unusable pesticide program in that state. Once again, a small agricultural area outdid many larger producing areas.

Pesticide Containers-Reasonably Effective

When it comes to categorizing state pesticide container collection programs, the "effective" ranking is clearly the largest group. To hammer home the opinion that local attention makes a large difference, you may note that the home state of the six current ACRC contractors are represented in these two top categories. These primary contractors are located in Texas, California, Missouri, Minnesota, North Dakota, and Washington.

There are some notable rising stars here, despite this seeming secondary ranking. Virginia is doing a commendable job, and has been one of the more innovative states in fitting the collection method to the local culture. Virginia was the first state that we are aware of, that utilized the "milk run" collection method in their orchard region. One small state, South Carolina, collected more pounds of containers in 1998(207,361lb.) than Florida, Illinois, Georgia, and many other much larger agricultural areas.

Spotty Ranking

Spotty is an off the cuff moniker that I gave to programs that sometimes have shown flashes of brilliance, but for one reason or another have just not provided consistent service, either in terms of geographical coverage or chronological, long-lived stability. In most instances, this designation is due to inconsistent funding, or inconsistent leadership, or both.

Unusable Pesticides-Spotty

Legislatures and county commissioners wax and wane in their appreciation of the importance of unusable pesticide disposal. This happens not just to

the mass of states listed in this category, but also to those listed in the "best" category. The difference, in some cases, has been that the leadership refused to let the program lapse. Some leaders in the Midwest, for

instance, tapped local agricultural chemical associations, commodity groups, chemical companies, and arranged modest shared expenses when funds disappeared. Their will kept their programs alive.

The saddest report, contained in this article, is on the once proud Mississippi program. From 1994 to 1998, the Mississippi Department of Agriculture collected 816,104 pounds of unusable pesticides from farmers and commercial establishments. The state raised the pesticide registration fees to cover these expenses and the program was on the way to the top of anyone’s list. However, the state legislature refused to lift a 1999 sunset provision and the Mississippi delta was shocked by the loss of an outstanding program. Today, only the Tennessee Valley Authority collects unusable pesticides in a few northern areas of the state. No one person’s will could offset the loss of an entire funding package.

Pesticide Containers-Spotty

Some of the states listed in this grouping are here because neighboring states that have essentially the same cropping practices have collected substantially more containers. Others are in this grouping because they have historically fluctuated significantly in their collections and those deviations cannot easily be attributed to weather or market conditions.

I also acknowledge that the ACRC does not have enough experience with certain high plains states like Montana and Wyoming. Their container collection effort to date in this rangeland or prairie area may actually be "effective" for that region, since few pesticides are for agricultural production.

Inadequate Ranking

Inadequate could just as easily be called "Hall of Shame."

Unusable Pesticides-Inadequate

I gave a few programs the benefit of the doubt and kept them out of this category, but we all can agree that states that provide NO ASSISTANCE to their agricultural industry are short changing not only the environment, but their citizen’s financial health as well. I can find no evidence that Oklahoma, Arkansas or Arizona have ever had any kind of consistent, state-wide programs. New York is the only large state to turn its back on this real problem. Ironically, agricultural states of the West and Midwest think of the Northeast as a bastion of environmental "correctness". This chart suggests otherwise.

Pesticide Containers-Inadequate

The Northeast does not fare too well when comparing pesticide container programs either. The uninformed may draw the conclusion that this is entirely due to the fact that these are traditionally non-agricultural states. There is some truth to this supposition, however the collection of less than 17 thousand pounds of plastic in the entire state of New York is unacceptable. To put this in proper perspective, some urban lawn care companies produce 10% of New York’s total EACH season. How many lawn care companies are in New York? Whether the user is a right-of-way maintenance contractor, a golf course superintendent, or a professional arborist, all of these users need access to proper pesticide container disposal.

CONCLUSION

Rankings are, at best, a subjective exercise; subject to errors due to variable reporting and inequitable comparisons. Despite this assertion, it can also be said that State legislatures, administrators, industry, and non-governmental organizations deserve recognition when a state’s pesticide stewardship is clearly superior. This combination of outstanding ranking for both unusable pesticides and container recycling is born at the highest level by only three states: Iowa, North Carolina, and Texas. If one allows for the inevitable errors in judgement, that "honor roll" can be increased to the states that are in either of the top two categories. Then, the recognition can be expanded to 16 out of the 50 states: California, Georgia, Iowa, Kansas, Kentucky, Maryland, Minnesota, Nebraska, North Carolina, North Dakota, South Dakota, Texas, Vermont, Virginia, Washington, and Wisconsin. Just barely missing the cut, if only 1998 data are used, were Maine and Pennsylvania; but these programs emerge as fully effective programs when their growing 1999 container programs are factored into the analysis.

Conversely, are there state attitudes toward environmental stewardship demonstrated by inadequate opportunities for proper disposal of pesticide wastes? Regretfully, this reverse assumption also appears to be true. For instance, in the charts ranking unusable pesticide programs, one can notice that a majority of the fully competent states (67%) have adopted the Universal Waste Rule. However, in the "inadequate" category, only four out of eleven or 36% have adopted the same ruling that facilitates small quantity collections of certain wastes. Within this listing of eleven states: Connecticut, New Hampshire, New York, and Rhode Island are also in the inadequate category for pesticide containers. With the arguable exception of New York, these entities are not considered "agricultural" states. Still, each of these four states has a neighboring state program with similar professional and commercial pesticide usage where credible pesticide stewardship is provided for their citizens.

After analyzing these charts, it is clear to me that there are at least clear advantages to pesticide users and their communities in a handful of widely scattered states. That advantage is that farmers and other users of pesticides have viable options for proper pesticide stewardship, and these options help them protect their families, their surroundings, their environment. The men and women who oversee these regulatory and other related programs know how to protect their communities. With slightly increased resources from responsive legislatures, and appropriate leadership, all of the United States can provide more uniform and proper options for unusable pesticide disposal and plastic pesticide container recycling.

BIBLOGRAPHY

Denny, R.L., 1999, "Access to Pesticide Disposal Depends on Business Location," Dealer & Applicator, May Issue.

Cubbage, C. P., and Harris, N. F., 1998, "National Survey of State programs for Unusable Agricultural Pesticide Collections: 1998 Update," Proceedings, 1998 Hazardous Materials Management Conference on Household, Small Business, and Universal Waste, SWANA, Washington, D.C., pp.13-23.

Cubbage, C. P., and Potter, A. L., 1999, "National Survey of State programs for Unusable Agricultural Pesticide Collections: 1999 Update," Proceedings, 1999 Hazardous Materials Management Conference on Household, Small Business, and Universal Waste, SWANA, Washington, D.C., (forthcoming)

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