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PESTICIDE WASTE VERSUS HAZARDOUS WASTE

What is a pesticide waste? Are all pesticide wastes considered hazardous wastes? If I have excess pesticide, how should I dispose of it? These are some of the recent questions we have had concerning this confusing question. The following will, hopefully, answer these questions.

What is a pesticide waste? A pesticide waste is any material which contains any concentration of pesticides which has been declared a waste. This includes such things as: rinse material from containers and spray equipment, left over spray solutions, excess pesticides, canceled/suspended pesticides.

Are all pesticide wastes considered hazardous wastes? Under the Resource Conservation and Recovery Act (RCRA) regulations, commercial chemical products such as pesticides become "solid wastes" (and thus, potentially, hazardous wastes) at the point where the pesticide's holder (i.e., end-user, dealer, distributor, or registrant) decides to discard them. If a pesticide product is listed in 40 CFR 261.31 or 261.33, or exhibits a hazardous waste characteristic identified in 40 CFR 261.21 through 261.24, it 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.

The holder who makes the decision to discard, controls the point at which the pesticide becomes a solid waste; if the pesticide is a hazardous waste, RCRA regulations govern its transportation and storage from that point on. Thus, if an end user decides to dispose of the pesticide in his possession instead of returning them to the registrant through a recall program, the pesticide would be considered a solid waste subject to RCRA.

A listing of the pesticides in parts 261.31 and 261.33 are listed below. You will note that there are various Hazardous Waste Codes (RCRA No.) listed in the table. These codes have special meanings and are defined as follows:

F-List Hazardous wastes from nonspecific sources (40 CFR 261.31).

K-List Hazardous wastes from specific sources (40 CFR 261.32).

P-List Acutely hazardous wastes from specific sources (40 CFR 261.33(e)).

U-List Toxic and other commercial chemical products (40 CFR 261.33(f)).

D-List Products containing residues, by analysis, that exceed a minimum concentration.

If I have excess pesticide, how should I dispose of it? This depends on the source/type of excess pesticide. If the excess pesticide is rinseate, it should be disposed of at the application site or reused as diluent for the next pesticide application. If the pesticide is an unopened container of a commercial product, this should be coordinated for re-utilization (e.g. the DRMO for the military). However, if this unopened commercial product happens to be a canceled/suspended product or is marked for military use only, DRMO/DRMS cannot legally sell or redistribute this material. If this canceled/suspended/military-use-only product contains any one of the ingredients listed in the attached list, it, by definition, becomes a hazardous waste and must be disposed of in accordance with the RCRA regulations. With the re-registration requirement in the 1988 amendment to FIFRA, there have been many pesticide product cancellations. In general, these canceled products may be used at the user level until the stock is exhausted. However, if these products are turned in through DRMO, they will have to dispose of them as hazardous wastes. This cost then gets charged back to your installation.

A text version of the table is available.

From: Ken Olds (kolds@aeha1.apgea.army.mil), Pesticide Hotline, PEST MANAGEMENT BULLETIN, DEPARTMENT OF THE ARMY, US ARMY ENVIRONMENTAL HYGIENE AGENCY, ABERDEEN PROVING GROUND, MD 21010-5422, Date: Wed, 16 Jun 1993 14:19:43 GMT