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The Plant Science Industry, represented globally byCropLife International, is committed to the propermanagement or Stewardship of their productsthroughout their lifecycle, from research anddevelopment, through use to disposal of waste. Theoverall aim of stewardship is to maximise benefits andminimise any risks from the use of crop protectionproducts (pesticides).
The present document is a summary of the mostrelevant aspects of a successful programme forhandling empty pesticide containers originating fromCropLife member companies. This summary shouldserve as a guideline for implementing newprogrammes and revising the on-going ones.
Introduction
Roadmap for establishing a container management programmefor collection and disposal of empty pesticide containers
IntegratedPest
Management
Storage,Transportation
andDistribution
Manufacturing
Research
ResponsibleUse
(‘Safe UseInitiatives’)
ContainerManagement
Disposal ofObsolete Stocks
FAO Code of Conduct & Industry Standard
National & International Regulations
Association Activities
Company Activities
Dev
elop
edC
ount
ries Least
Developed
Countries
Figure 1: Stewardship of Crop Protection Products: The responsible and ethical management of a crop protection orbiotechnology product throughout its lifecycle and beyond
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OVERALL GOAL OF A CONTAINERMANAGEMENT PROGRAMME
The programme should provide for the safe, effectiveand responsible management of all1 of the cropprotection industryÕs empty pesticide containers.
THIS PROGRAMME SHOULD:
• be initiated by our industry, with the industryrecognised as a leader
• be undertaken in collaboration with otherparticipants in the value chain, including non-CropLife members, retailers and farmers, localand national governments and other relevantstakeholders
• adopt “best practices”, based on industry’sexperience from across the world, which issummarized in this and other referenceddocuments
• be cost-efficient and continually seek andimplement cost reduction opportunities
• be based on solid technical science whichreduces risk to human health and theenvironment
• include an element of monitoring, evaluation andreporting that facilitates programme review andimprovement based on clearly defined andtransparent targets.
General Considerations regarding aContainer Management Programme
WHY IS A PROGRAMME NEEDED?
• To demonstrate industry’s commitment to healthand the environment
• To demonstrate the commitment of industry tosustainable agricultural practices
• To satisfy clients’ (farmers’) demands to eliminateempty containers
• To comply with national and internationalexpectations and regulations
• To fulfil our commitment to implement the UNFood and Agriculture Organisation’s InternationalCode of Conduct on the Distribution and Use ofPesticides (FAO CoC), which calls on industry, incollaboration with other stakeholders, to establishcontainer management programmes
• To meet certification needs for good on-farmagricultural practices
• To become a key, and visible, element of theindustry’s stewardship efforts.
WHAT ARE THE BENEFITS OBTAINEDFROM INDUSTRY SUPPORT OF ACONTAINER MANAGEMENTPROGRAMME?
• It helps to satisfy employee, shareholder andsociety’s demand for responsible businesspractices
• It helps maintain industry’s ‘licence to operate’through good business practice
• It helps to ensure industry’s expertise and know-how is utilised to develop cost-effectiveprogrammes
• It helps to avoid unnecessary regulation
• It considerably improves our industry’s image.
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1 A programme should have the ability to deal with all containers – however, in many situations only containersoriginating from companies that have agreed to support and participate in the container management programmewill be collected. All companies have the opportunity to join a programme.
Roadmap for establishing a container management programmefor collection and disposal of empty pesticide containers
• Programmes to be developed according to theneeds and capabilities of each country
• The programme is endorsed by local authorities
• That the programme is monitored by industry, andother relevant stakeholders, throughout all itsstages
• That programmes are initiated as pilot projects inthe first instances, with review and adjustmentprior to expansion
• That the programme be established under a soundbusiness approach, with:
A business plan
Clear processes
Long-term self-sufficiency
Sound financing
Availability of trained personnel (plus atraining plan)
• Establishment of a programme should bepreceded by a pre-programme aimed at training ofusers in, and the promotion of, proper rinsing ofempty containers.
WHAT ARE THE REQUIREMENTS FORSUCCESS AND SUSTAINABILITY?
• All participants – industry, retailers anddistributors, local and national government, aswell as farmers and other pesticide users – needto be convinced of the need for, and the benefitsof, the programme
• All participants accept shared responsibility forimplementation and/or costs
• All participants have clearly defined roles andresponsibilities
• The local industry remains fully committed tosupporting the programme
• Government and institutions interested in theenvironment get involved at the very onset of aprogramme
• Local and national regulations are adequate andappropriate – e.g. proper classification ofcollected waste
• Good scientific and technical informationunderlying all stages in the programme – e.g.rinsing of containers, risk analysis of final use ofrecycled material
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programmes around the world, determine thecollection potential and define what needs tobe done and where, how and when, and thecosts, investment and implementationrequirement.
This should draw on currently availabledocumentation that outlines the technicalrequirements for designing and establishingcontainer management programmes, including:
European Crop Protection Association (ECPA):Container Management Guidelines – buildingeffective and integrated strategies forpackaging reduction, design, rinsing andrecovery2,3.
FAO: guidelines available of the FAO pesticidemanagement website (www.fao.org)
These guidelines provide essential informationfor manufacturers on container designs, whichwill facilitate recycling, including mostappropriate materials 4. Additionally, theseguidelines provide details of the technicalrequirements for collection and recovery ofmaterial. The current document does not gointo the detail provided by the ECPA and FAOguidelines; it lays out the framework andactions that need to be taken to put aprogramme in place. It is essential, therefore,that reference is made to these otherdocuments, particularly the ECPA guidelines,which provide more of the technical details.
Additionally, there are more specific guidelineson rinsing of containers and wasteclassification (essentially the classification ofproperly rinsed containers – i.e. triple orpressure rinsed – as non-hazardous waste) andrisk analysis of end-uses for recycledcontainers. These need to be consulted whendetermining the possible routes of containerrecovery.
• CropLife International: Sustainablepackaging – the case for rinsing usedpesticide containers5
1 Prepare a situationanalysis
1.1 DEFINE THE CURRENTSITUATION BY COLLECTINGINFORMATION AND DATA FROM:
• Stakeholders
• Questionnaires
• Interviews
• Statistics
• Opinion polls
• Regulations
• Attitudes (e.g. willingness of stakeholdersto actively support/participate)
• Current practices.
The primary aim of this activity is toestablish:
• The size of the required programme –what product (containers) are enteringthe market, including size, type ofmaterial, pesticide ingredients
• Who manufactures or imports and sellsthe products
• Willingness and feasibility to participatein a programme – for farmers this meanswillingness to return containers, forretailers, distributors and/ormanufacturers, willingness to collect andfor all stakeholders willingness tocontribute to costs
• What are the regulations covering wasterecycling in general and containerrecycling in particular – do these need tobe adjusted to facilitate a feasibleprogramme?
1.2 DETERMINE THE FEASIBILITY OFTHE PROGRAMME
Based on the information collected above,and documented experience from established
Essential elements to implementa container management programme
2 Recovery covers all ‘end-uses’ i.e. material recycling (recycling into other products), energy recycling (use as afuel in, for example, cement kilns) and incineration.
3 http://www.ecpa.be/files/documentslive/14/14227_Container%20Management%20Guidelines.pdf4 From a recovery point of view the packaging should be designed so that it can be processed without contravening
health and safety requirements and is capable of one of the routes of recovery, however, there are many ofrequirements of packaging related to ease and safety of use, storage and handling that also needs to beconsidered.
5 http://www.croplife.org/PublicationDetail.aspx?Id={9024b07e-74db-4120-870f-a0733afd24b9}&wt.ti=Sustainable+packaging+-+the+case+for+rinsing+used+pesticide+containers+(332+KB)
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• ECPA: Crop Protection Plastic containers– The case for a non-hazardous wasteclassification6
• ECPA: From Discovery to Recovery –Waste classification gives new life to oldcontainers7.
1.3 COLLECT STATISTICAL DATA ONTHE ESSENTIAL VARIABLES
As part of developing a business plan, thefollowing information should be determined:
• Total weight of each container type to becollected
• Type of container (plastic bottles, metaldrums etc).
• Cost of collecting – this is dependent onwho is identified to collect (retailers, thecollection scheme), how (farmers bring toa fixed collection point, mobile collectionvehicles), what frequency etc.
• Training costs – this will depend on whois responsible and whether it can belinked to current ‘responsible use’ or‘retailer certification’ training
• Promotion and advertising costs
• Transportation costs – depends on thegeography of a country and local/nationalinfrastructure, plus collection frequencyand location of collection points
• Final disposal costs – this is dependenton end-uses and whether the recycledmaterial has value (i.e. can it be sold?),as well as hazard classification (seesection 2.6)
1.4 EXPLORE THE INDUSTRY’SDECISION TO CARRY OUT THEPROGRAMME
Perform prior analysis on the industry’sinterest in, and commitment to,implementing a programme for collecting andrecycling pesticide containers.
Ask a series of questions relating to theprogramme:
a. are you familiar with CropLife’s containermanagement programme and itsbenefits?
b. do you think it is feasible to introduce sucha programme in your country (if no, why)?
c. do you think that companies in yourcountry are interested in starting acontainer management programme?
d. What would the reasons be:
• It is a responsible industry?
• Image building?
• Adherence to existing regulations?
• To act ahead of regulations?
• To seek business advantages?
e. Would you be willing to contributefinancially to the programme?
f. Are you aware of any current legislationrelating to pesticide containers?
These questions should be aimed at allpotential programme participants. On the basisof the responses a clear idea of the initialfeasibility of a programme, what educational,training or lobbying programmes are neededand what time-frame for initiation is possible,including what needs to be in place before aprogramme can be initiated.
1.5 REVIEW THE CURRENTREGULATORY FRAMEWORK
This includes shipping and storage regulations,waste control regulations that can often be thedriving force for stakeholder participation(although, if very lax, may be a negativeinfluence on participation) and regulations thatwould influence recovery options (e.g.incinerator/cement kilns emission standards,official approval of recycled products etc.).
This analysis will help determine if discussionsare required with authorities to introduce, oradjust regulations – e.g. classification of waste,see section 2.6.
This analysis will also give an indication ofwhether participation in a programme is likelyto be a legal requirement in the country forregistrants and other stakeholders. A legallymandated scheme ensures that all groupscontribute to the scheme (financially, by anobligation to return properly rinsed containersto a collection point etc.), however, it runs therisk that it will lack the drive for efficiency that
Roadmap for establishing a container management programmefor collection and disposal of empty pesticide containers
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6 http://www.ecpa.eu/files/ecpa/documentslive/23/16942_Report%20on%20Classification%20of%20Packagings.pdf7 http://www.ecpa.eu/files/ecpa/documentslive/23/16943_Leaflet%20''From%20Discovery%20to%20Recovery%20-
%20Waste%20classification%20gives%20new%20life%20to%20old%20containers'.pdf
voluntary schemes may have. Ultimately, anindustry-led scheme will push for maximising(cost-) efficiency. Current legally-mandatedprogrammes are shown in Table 1.
1.6 LOOK INTO THE ACCEPTANCEOF THE PROGRAMME
This will include local community acceptancefor the sighting of collection points,willingness of farmers and/or retailers tocollect and market for recovered products.
1.7 DECIDE ON COLLECTION SET-UP
Clean, properly rinsed containers are criticalto the cost efficiency of the programme –even in the absence of a programme it shouldbe promoted. Details of proper rinsingprocedures (triple rinsing, pressure rinsing)can be found in the ECPA guidelinesreferenced in section 1.2, and the CropLifeInternational guidelines on ‘the Safe andEffective Use of Crop Protection Products’(www.croplife.org).
The type of collection procedure needs to bedecided depending on the informationcollected from the actions above. Dependingon willingness, size of the ‘market’ andcountry/region, there are several differentoptions:
Farmers deliver rinsed (cleaned) containers toa collection point.
A mobile unit (vehicle) collects at predefinedtimes and delivers to a fixed collection point– this is likely to be more suitable whenfarmers are able and willing to safely storecontainers for a season, which are thencollected yearly. It can save on the cost ofbuilding numerous collection points (see noteon siting of container collection points,below).
Collection points can be:
• small, local, unmanned – mostly suitablefor small-scale farmers
• retailer/distributor sites
• medium sized or large sites that aremanned – these may also be the point atwhich inspection (for proper rinsing, i.e.cleanliness) is made, plus processingsuch as compaction and shredding.
Table 1: Legal status of current container managementprogrammes (2008)
USA Voluntary
Canada Voluntary
Argentina Voluntary
Bolivia Voluntary
Brazil Legally mandated
Chile Voluntary
Colombia Voluntary
Costa Rica Voluntary
Dom Republic Voluntary
Ecuador Voluntary
El Salvador Voluntary
Guatemala Voluntary
Honduras Voluntary
Mexico Voluntary
Nicaragua Voluntary
Panama Voluntary
Paraguay Voluntary
Peru Voluntary
Uruguay Voluntary
Venezuela Voluntary
Australia Industry-GovernmentCo-regulation
New Zealand Voluntary
Austria Legally mandated
Belgium Legally mandated
France Legally mandated
Germany Legally mandated
Hungary Legally mandated
Poland Legally mandated
Spain Legally mandated
The Netherlands Legally mandated
Note: 75% of containers collected are under legallymandated schemes (including Australia).
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Funding of collection points can be by theprogramme itself, or by local authorities orretail/distributors, as part of their contributionto the programme.
Programmes should aim only to collectproperly rinsed containers – this is tomaintain the ‘non-hazardous’ nature of therecovered material, which has significantimpact on costs. Containers should, therefore,be visually inspected at collection points – ifmanned, dirty containers should be rejected,either to be properly rinsed by the owner ortaken to a hazardous waste site (where theowner may have to pay to dispose of thecontainer). Unmanned collection sites run therisk that dirty containers will be deposited –and therefore the suitability of this approachneeds to be considered. The problem isaddressed through appropriate training, and‘peer pressure’/policing by the localcommunity. If not carried out at initialcollection, inspection needs to be made atthe manned larger collection points (wherethe contents of the unmanned sites aredelivered). Dirty containers need to be eitherwashed at these sites, or directed to ahazardous waste stream.
1.8 DECIDE ON THE FINALDESTINATION OF THECOLLECTED MATERIALS
No collection and recovery programme can beinitiated before the final destination of thecollected material is established and therecycling application developed and approvedby relevant authorities. There are several waysto achieve final disposal. Each country shoulddetermine what is the most feasible and cost-effective option for their particular situation.
Possible options for final disposal:
• Re-use as pesticide containers
• Recycling of materials for otherapplications
• Energy recovery in cement kilns or powerplant
• Destruction at approved incinerationplants
• Sanitary landfills.
Containers SHOULD NOT be disposedthrough
• Indiscriminate dumping
• Open-air incineration, includingincineration in 200-litre drums
• Incineration in unapproved incinerators.
CropLife International/ECPA has undertaken arisk analysis of end-uses – this is available onrequest and its recommendations should beadhered to. A general principle is thatrecovered material should, ideally, be handledtwice – once at collection/processing andonce when put to its final use – this is thecase when used as a fuel source, or recycledas electrical conduit or concretestrengthening rods.
Re-use of containers for storing cropprotection products is only used forspecialised large (circa 200 litre) containers.It is not recommended for smaller containers(with the exception of caps, which arerecycled and re-used in some countries); thereasons are based on safety and security:
• To prevent inappropriate use ofcontainers (e.g. storage of other liquids,including drinking water) farmers shouldbe trained to puncture used containers
• The presence of numerous proprietarycontainers will facilitate their use forcounterfeit products.
Current end-uses for recovered containers aregiven in Table 2.
General criteria for end uses:
• Social and economical perception andimpact should be analysed beforeapproval
• Recycler and end product riskassessment
• Applications where products may not bein human contact on a routine basis,either by sandwiching in virgin plastic orembedding it in concrete or othersubstrates
Roadmap for establishing a container management programmefor collection and disposal of empty pesticide containers
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Table 2: End-uses for recovered plastic containers (2008)
CURRENT END USES REJECTED END USES
Agricultural drainage piping Flower pots
Curb stops Corner stacks for pallets
Treated lumber substitutes Blends with virgin material for unknown uses
Highway guard rail posts
Railroad ties
Truck sub-floor components
Liners for highway salting trucks
Fence posts
Electric conduit and boxes (buried in walls, floors etc.)
Plastic lumber
Watermeter boxes
Car battery casing
Hospital trash Bags
Motor oil containers
Incineration barrels
Brooms
Caps for agricultural chemical containers
Motor oil containers
Road speed bumps
Parking cones
Highway signposts
Electrical pylon plastic cross-piece insulators
Concrete saver
Stakes
Marine pilings
Lighting posts
Industrial pallets
Construction nailing strips
Drainage/sewerage pipes and fittings
Roof tiles
New agrochemical containers8
Fuel substitutes
8 Recycled material is sandwiched between virgin material
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• Mainly outdoors and industrialapplications
• Ideally underground applications.
1.9 CARRY OUT A DETAILED STUDYON THE TOTAL AVAILABILITY OFCONTAINERS (INCLUDING WHENAND WHERE THEY ARE USED)
In order to start a programme, it is essentialto count on updated data on the totalquantities of available containers, includinginformation on type of material, and quantity(expressed in kilos or tonnes).
It is also important to determine wherepesticide (containers are used) and when(specific time of year, all year round) to helpdetermine location of collection points andcollection timing (every month? Once ayear?).
1.10 BRANDING OF SCHEME
It is recommended that a container recoveryprogramme should be ‘branded.’ This servestwo functions:
• Highlights the scheme, encouragingparticipation of stakeholders
• Excludes ‘freeloaders,’ i.e. containers ofscheme participants are recovered –others are rejected (note however, thatparticipation in the programme should beopen to all – this is a ‘must’ ifparticipation in a recovery scheme is alegal requirement in the country).
Roadmap for establishing a container management programmefor collection and disposal of empty pesticide containers
Current branded schemes (2008) are:
ACRC USA
Adivalor France
Phytofar Recover Belgium/Luxemburg
STORL Holland
Clean Farms Canada
inpEV Brazil
drumMuster Australia
Sigeru/Valorfito Portugal
Eko-Com Czech Republic
CSEBER Hungary
PSOR System Poland
RIGK-Pamaria Germany
Sigfito Spain
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2 Set the objectives
2.1 MAIN OBJECTIVETo accomplish the safe and (cost-) effectivedisposal and/or recycling of empty pesticidecontainers.
2.2 TO CARRY OUT A CONTAINERMANAGEMENT PROGRAMME
To establish programmes in the regionsdefined as having the highest potential/needs.
2.3 TO EXPAND THE PROGRAMME
To progressively expand the programme toreach optimal collection levels, and assurethe continuation of the programme in thefuture (initial high start-up costs – becomescheaper per kg up until over 90% recovery).
2.4 TO DEFINE POTENTIALPARTICIPANTS
Container management programmes cannotbe carried out only by the industry. Other
stakeholders should be approached:government officials, distributors, agriculturalorganisations, non-profit organisations andinternational organisations, as well as farmersand farmer organisations and ideally othermembers of the food value chain should alsobe involved.
2.5 TO DEFINE A ‘COLLECTIONPOTENTIAL’
The potential to collect containers dependson the degree of the development of eachcountry, since there are factors whichadversely affect collection activities, such asmeans of communication and transportation,lack of environmental awareness, culturalpractices, value of containers for other uses,lack of regulations etc.
Each country should estimate its owncollection potential on the basis of the totalamount of containers available, differentcrops and actual possibility of collecting. Thepotential shall be revised at least every twoyears after the initiation of the programme.
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2.6 TO ESTABLISH ACLASSIFICATION FOR EMPTYCONTAINERS:
Currently, many countries have adopted theirown regulations on ‘hazardous waste.’Pursuant to the Basle Agreement, empty,UNCLEANED, pesticide containers areclassified as hazardous waste. However, thereis considerable data available to demonstratethat properly rinsed containers (triple-rinsedor pressure-rinsed) should be classified asnon-hazardous; both FAO and CropLiferecommend this, and many countries haveadopted a non-hazardous classification.However, some countries still classify ashazardous – where this is the case it severelylimits the feasibility of a sustainableprogramme in the long-term. Appropriatelobbying should be undertaken.
The classification increases the recyclingvalue of the plastic, because non-hazardousmaterial is considered raw material ratherthan waste.
To provide confidence in the classification, itis important that containers be (visually)checked, preferably at collection, to ensurerinsing has been undertaken. Unrinsed, orimproperly rinsed, containers should berejected or directed to a hazardous wastestream.
2.7 TO AGREE ON GOALS TO BEREACHED IN THE FOLLOWINGTHREE YEARS
• Total amount collected
• Percent collected (= kg collected/amountentering the market)
• Elimination cost per kg (totalcost/eliminated kilos)
• Percent of programme self-financing(= revenues generated by the programmefrom sale of recycled material/total costof programme)
• Sources of income – includes levies onsales or amount of product enteringmarket, donor contributions (particularlyon start-up), sales of recycled material,contributions from local, national orregional governments, contributions fromother stakeholders etc.
Roadmap for establishing a container management programmefor collection and disposal of empty pesticide containers
Collection Schemes Classification (2008)
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Non hazardous classification
Special waste
No official classification
Hazardous classification
Classification unknown
3 Set up the programme
3.1 DEFINE
Priorities
Strategy
Funding sources and systems
Budget
Training programme
Collection points (centres)
Advertising and promotion programme
Ways of disposal
Ways of conditioning materials for disposal
Areas or regions where to set up the programme
Materials to be collected
Cooperation provided by each stakeholder andthe way to integrate that cooperation into theprogramme.
A communications strategy:
• Types of messages or information to bereleased
• Target audiences
• Frequency of information
• Media.
Examples of communication material can befound at:
CropLife Canada (Clean Farms):http://www.croplife.ca/web/english/managecontainers/
Inpev (Brazil):http://www.inpev.org.br/index.asp
AVIDALOR (France) :http://www.adivalor.fr/collectes/petits_bidons.html?code=
3.2 FINALLY DRAW UP ANACTION PLAN
• What, who, where, when, how
• Organisation charts
• Roles
• Areas
• Responsibilities of each party involved inthe programme.
3.3 SET UP THE WORK GROUP
Leading companies should appoint arepresentative who has the authority to makedecision/commitment.
3.4 APPOINT THE PERSONRESPONSIBLE FOR STAGE 2
Experience shows that the best candidate is aperson having expertise in the pesticideindustry, and full time availability to performprogramme activities.
3.5 DEFINE THE DURATION OFSTAGE 2
3.6 DEFINE THE PILOT PLAN,STRATEGY, OBJECTIVES ANDCOST
One or several pilot plans are needed to reachconclusions that would serve as a guideline toexpand the container managementprogramme in regions having the highestcollection potential within a country. The goalof a pilot plan is to achieve 15% of thecollection potential defined for a givencounty.
Discuss the funding of the pilot plan
Define the region(s) where the programmewill be carried out
Define the ways of collecting (manualcollection centre or unmanned mini-centre)
Define the final destination of the collectedmaterials
Define ways to condition the material
Define human resources
Draw up a budget for investments andexpenses
Define objectives and measurable goals
Obtain a formal approval of the pilot plan.For the plan to advance during all its stages,it is essential that the national ExecutiveCommittee first approves both the plan andthe budget.
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Roadmap for establishing a container management programmefor collection and disposal of empty pesticide containers
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OTHER SOURCES OF INFORMATION
USA (ACRC): http://www.acrecycle.org/order_discript.html
Canada (PCRC): http://www.croplife.ca/english/collectionsites/
France (AVIDALOR): http://www.adivalor.fr/collectes/emballages_vides.html
Belgium (Phytofar): http://www.phytofar.be/fr/ini_int2.htm
Australia (Drummuster): http://www.drummuster.com.au/
Germany (Pamira): http://www.pamira.de/en/index.asp
Spain (Sigfito): http://www.sigfito.es/
Portugal (Valorfito): http://www.valorfito.com/
Hungary (Csber): http://www.cseber.hu/
Latin America (Campo Limpio): http://www.croplifela.org/spip.php?article50
UK Crop Protection Association:http://www.voluntaryinitiative.org.uk/_Attachments/BPG%20Pesticide%20Container%20Disposal.pdf
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CropLife International aisbl
326 Avenue Louise, Box 35
1050 Brussels
Belgium
tel +32 2 542 04 10
fax +32 2 542 04 19
www.croplife.org
Date of publication: May 2010
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