1

Workshop on Locusts in Caucasus and Central Asia (CCA)

Astana, Kazakhstan, 14-18 November 2016

Conclusions of the E-Committee on empty pesticide container management

-Item 12-b of the Provisional Agenda-

Under the "Programme to improve national and regional locust management in Caucasus and Central Asia

(CCA)” and more specifically Result 5 of its Roadmap, “Impact of locust control operations on human health

and environment mitigated and monitored”, Activity 5.1.3. refers to “Pesticide and empty container

management”. In this framework, it was agreed to review and critically analyze the management of empty

containers of pesticides used for locust control in CCA to identify mean features, challenges and needs and

then formulate recommendations to improve it.

The Terms of Reference for such review were presented and discussed with CCA Delegates during the

annual Technical Workshop on Locusts in CCA, held in the Russian Federation in October 2015. The

representative of the non-profit organization “Milieukontakt International” (MKI), identified to carry out

the requested work, was present and thus participated in the discussions and met the countries’ Delegates.

On this basis, in November 2015, a questionnaire was prepared by MKI and sent to the national technical

focal points of all CCA countries to collect information on the legal framework and practices concerning the

collection, cleaning, volume reduction and recycling/disposal of such empty pesticide containers. The

report was prepared based on the replies to the questionnaire as well as other sources of information,

including on best practices at the international level. The draft report was shared by MKI and reviewed by

FAO (April-October 2016) and it was submitted on 4 November 2016 to countries for comments as well as

in order to get some missing information. The Technical Workshop on Locusts in CCA to be held on 14-

18 November 2016 in Kazakhstan will also provide the occasion to MKI to present and discuss with CCA

Delegates the conclusions and recommendations of the draft Report.

To facilitate the discussions, this Working Paper provides an extract of the draft Report, i.e. the Executive

Summary as well as the summary of the recommendations (as provided in Annex III of the Report).

2

Extract of the Draft Report on Management of Empty Pesticide Containers used for Locust Control in

Caucasus and Central Asia (CCA)

Executive summary

“This report gives a review of the management of empty containers of pesticides used for locust

control in 10 Central Asian and Caucasian countries (Afghanistan, Armenia, Azerbaijan, Georgia,

Kazakhstan, Kyrgyzstan, Russian Federation, Tajikistan, Turkmenistan and Uzbekistan) and presents

recommendations for improvements. The report was prepared in the framework of the FAO

“Programme to improve national and regional locust management in Caucasus and Central Asia (CCA)”.

The report includes the following six chapters:

1. Introduction 2. Assignment objectives and methodology used 3. Internationally available best practices of empty container management for locust control 4. Legal and institutional frameworks on empty container management for locust control in CCA

countries 5. Empty container management for locust control in CCA countries 6. Conclusions

The following sources were used to review the management practice of empty containers in CCA

countries (Chapter 2):

Questionnaire on management of empty pesticide containers used for locust control in CCA,

prepared by Milieukontakt in cooperation with the FAO “Locusts and Transboundary Plant

Pests and Diseases” Team (AGPMM) and sent to all focal points in Programme countries;

A series of reports developed by the FAO International Environmental Policy Consultant Robert

Denny: Situation Analysis Pesticide Container Management [in] Armenia, Azerbaijan, Georgia,

Kazakhstan, and Tajikistan. All the above-mentioned Situation Analysis reports were

developed in the framework of the Project Preparation Grant (PPG) phase of the FAO GEF

project “Lifecycle Management of Pesticides and Disposal of POPs Pesticides in Central Asian

Countries and Turkey (GCP/RER/042/GFF)”. All reports are still in draft form and not finally

approved by FAO.

A Report developed by the FAO International Environmental Policy Consultant Robert Denny

in the framework of the “Programme to improve national and regional locust management in

Caucasus and Central Asia (CCA) GCP/SEC/004/TUR”: Situation Analysis Management of

Pesticide Containers used for locust control in Kyrgyzstan.

A series of reports developed by the International HCH and Pesticides Association (IHPA):

Country Report – Legal and Technical Assessment of the Management of Obsolete Pesticides

[in] Armenia, Azerbaijan, Georgia, Kazakhstan, Kyrgyzstan, Russia, Tajikistan, Turkmenistan

and Uzbekistan and a second series of Working Documents – Management of Obsolete

Pesticides on the same above mentioned countries. All these IHPA reports are still in draft form

and not finally approved by FAO;

A report developed by the FAO International Consultant Amadou Diallo, Pesticide and Empty

Container Management Expert: Review of pesticide, empty containers and warehouse

management in Tajikistan based on a mission to Tajikistan carried out in June 2016.

3

Chapter 3 describes the internationally available best practices of empty container management for

locust control. Globally, there are over 31 countries with established empty pesticide container

management efforts in the field of recycling and reuse. In addition, new pilot programmes are initiated

almost every year. The western hemisphere and Europe make up most of the countries where

container management is routinely practiced with the addition of several Pacific Rim countries that

have now gained substantial experience in this field. Chapter 3 provides general observations from

empty container management programmes and at the end provides a summary of the best practices:

Pesticides are registered in the country;

Ample enforcement assures that there are few or no counterfeit products;

Alternative bio rational pest control techniques are researched and adapted to local

conditions, eliminating the risk of toxic residues wherever possible;

Packaging designs allowed in the registration process facilitate residue removal;

Packaging designed for producer refilling are encouraged and no packaging is left in the field;

Water dissolvable packaging where the pesticide does not come in contact with the outer

packaging is encouraged in the registration policy;

Pesticide labels in the appropriate local language(s) prescribe the rinsing or other disposal

handling procedures;

The State mandates a pesticide stock management system (PSMS) that tracks every container

or package from import or production through final disposal.

State approved training in pesticide and pesticide container stewardship is mandatory;

Pesticide users are held accountable for proper rinsing or other required disposal techniques;

The State designates and monitors all places that received properly prepared/rinsed empty

pesticide containers.

A properly rinsed pesticide container is a solid waste, not a designated “hazardous” waste.

The state encourages and facilitates packaging final dispositions according to the UN Hierarchy

of Waste Disposal (reuse – e.g. refillable; managed recycling; waste-to-energy; managed solid

waste disposal – e.g. landfilling in a secure managed site that meets international standards

for solid waste landfills).

The producer-distributors in a stakeholder agreement divide up the cost of collection, disposal-

recycling and management proportionate to the type and quantity of packaging that each sells

into the environment.

In most cases, the pesticide producer-distributors form a non-profit organization to act on its

behalf.

In Chapter 4, the legal and institutional frameworks on empty container management for locust

control in the CCA countries are discussed per country. In all involved CCA countries, there are laws to

regulate pesticide use. This can be concluded based on the responses to Milieukontakt’s questionnaire,

the IHPA, Denny and Diallo reports. In most of the ten CCA countries, management of empty pesticides

containers is regulated (in a more or less detailed way) under the hazardous waste legislation and plant

protection regulations. However, the existing legal and regulatory framework has important gaps and

needs improvements. In none of the ten CCA countries (except Uzbekistan) there is a special law,

regulation or guideline that regulates the management of empty pesticide containers used for locust

control. For the general agricultural practice in Kyrgyzstan there are regulations for the management

of empty pesticide containers, they are however incomplete or need improvements to be in line with

the internationally best available practices. In the cases of Turkmenistan and Uzbekistan there is

currently not enough information available in order to assess whether or not a well-functioning

legislative framework for sound management of pesticides and empty repackaging material is in place.

4

General recommendations for improving legislation and regulations are given in the last paragraph of

chapter 4 and focuses on the following elements:

Assuring clear authority to regulate;

Adopting Best Management Practices for pesticide registration;

Implementing or refining Pesticide Stock Management Systems;

Assuring adequate enforcement potential throughout the pesticide lifecycle.

In chapter 5, an overview is given on the management of empty containers per CCA country. In general,

it can be stated that there is no control over the full range of empty containers: according to the

answers to the questionnaires, percentages of collection vary from 60 to 100 percent.1 It is not always

clear what happens to empty containers that are not collected, although it is likely that many

uncollected empty containers are re-used for other purposes. In paragraph 5.2, recommendations are

given to improve empty container management in the countries under review. Empty pesticide

container management at the national level does contain the same elements as one specifically

organized for locust control. However, an important difference is that controls needed for a state-run

or state-sponsored effort are simpler and more easily administered than the general agricultural

practices where so many private entities have responsibilities that impact the success of empty

container management. Because locust control operations are conducted by the relevant national

service of the ministries of agriculture or under their supervision, this makes the management of empty

containers used for locust control easier. The recommendations in this chapter focus on the following

areas:

Planning;

Procurement that Considers Packaging (or Lifecycle Approach);

Operations Management;

Cost evaluation;

Pilot study.

FAO, as a specialized agency of the United Nations, has an important role in providing technical

assistance to improve empty container management within locust control. In order to gain more

experience on what needs to be done in practice, it is recommended that one of the CCA country

evaluates within a pilot study the costs and feasibility of implementing the general container

management principles as described in this report. Chapter 5.2.5 provides a list of recommendations

for this model pilot study based on empty containers of pesticides in Emulsifiable Concentrate (EC) and

Ultra-Low Volume (ULV) formulations. Additionally, some general considerations for the pilot study

are given.”

1 Afghanistan: 80 % collected and stored; Armenia: no data available; Azerbaijan: 60% collected and buried; Georgia: 100 % collected and stored; Kazakhstan: 100 % collected and stored; Kyrgyzstan: 15% collected and stored, 85% triple rinsed and buried; Russia: no data available; Tajikistan: 100% collected and stored; Turkmenistan 90% collected; Uzbekistan: no data available.

5

Recommendations2

“Overview of recommendations for improving management of empty

containers used for locust control in CCA countries This annex overview provides the reader with a fast reference to all 21 recommendations as

provided in the report “Management of empty pesticides Containers used for locust control

in Caucasus and Central Asia (CCA)”.

CHAPTER 4: Legal and institutional frameworks on empty container management for locust control

in CCA countries

4.3 Recommendations for improving the legal and regulatory framework

4.3.1 General recommendations

Recommendations to national services in charge of locust management in CCA countries to improve

the legal and regulatory framework in CCA countries:

1. Organize an analysis of the waste and the plant protection legislative regulatory in detail per

country and compare it to internationally available best management practices;

2. Based on such analysis, develop long term national strategies to update the national

frameworks in line with the internationally available best management that improve

environmental-health through plant protection and management of wastes;

3. At the same time, start in one of the CCA countries with pilot implementation of sound

management of empty containers used for locust control. The pilot should be structured in line

with best practices in other parts of the world and adapted to the local specific circumstances.

The practical experience with containers used for locust control with limited amounts of

containers will provide the countries with valuable lessons about what works in a specific

country and what does not work. This recommendation concerns primarily the practical

management of empty containers; however, the acquired knowledge and experience can also

be used to better adapt the legislative and regulatory framework for sound management of all

pesticide containers that are used in the country (Recommendations for the structuring and

design of a pilot are given in section 5.3 - Main challenges and methods to gauge the costs for

empty container management.)

4.3.2 Specific Areas for Assuring Compliance with International Best Management Practices

a) Begin with controlling what pesticides enter a country and assure that all requirements are met

Recommendations to national services in charge of locust management in CCA countries to improve

the legal and regulatory framework in CCA countries:

4. If not present already, form an executive oversight body to address legislative gaps and

overlaps in authority in conjunction with addressing empty pesticide container management.

5. Consider state alignment to FAO Guidelines for Legislation on the Control of Pesticides (1989),

FAO Legislative Study “Designing national pesticide legislation” (2007)3 and all international

conventions ratified by the country.

2 As provided in Annex 3 of the Report. 3 Vapnek, Jessica; I. Pagotto; M. Kwoko; “Designing national pesticide legislation” (2007) FAO Rome

6

b) Adopt Best Management Practices for Pesticide Container Registration:

Recommendations to national services in charge of locust management in CCA countries to improve

the legal and regulatory framework in CCA countries:

6. Publicly disclose the criteria and rationale for registration or non-registration. The registration

must accept or reject containers that promote or do not facilitate safe handling and disposal.

If the criteria are revealed that caused a selection decision to be made, it raises the bar for

future selections of formulation-container interfaces.

7. Standardize the criteria used to judge registration of containers and products.

8. Consider the hazard classification over the manufacturer’s risk assessment if the tools for

achieving acceptable handling of containers are not routinely available.

9. Register the sizes, materials and design of packaging since the amount of residue remaining

and the ease of disposal/recycling are dependent upon that design.

c) Implement or Refine Pesticide Stock Management Systems:

Recommendations to national services in charge of locust management in CCA countries to improve

the legal and regulatory framework in CCA countries:

10. Recommendation to FAO: If deemed appropriate and if no insecticide stock management

system already exists, provide technical assistance to install and implement the PSMS allowing

to know where the stocks are, which are the closest to expiry and to track location of filled and

empty containers.

11. In any case, maintain a record of every locust control insecticide and container throughout the

lifecycle. When any insecticide container comes into the country a unique number needs to be

assigned to that unit. In this way responsible authorities can track every step of the lifecycle of

the container including the final disposal or recycling of each individual unit and guarantee

sustainable handling of the insecticide container.

d) Assure Adequate Enforcement Potential Throughout the Pesticide Lifecycle:

Recommendations to the head of the national service in charge of locust management in CCA

countries:

12. Clearly require from all personnel to observe the requirements for security, handing, and

application of insecticide and disposal of any container or other residue-laden material.

e) Control the Final Disposition of Empty Pesticide Packaging:

Recommendations to national services in charge of locust management in CCA countries to improve

the legal and regulatory framework in CCA countries:

13. Recommendation to the national legislator: Treat all empty pesticide containers/other residue

laden equipment as managed solid wastes, not classified hazardous wastes. Otherwise

hazardous waste permitting will be required for every transportation or treatment step of the

containers, making safe handling needlessly expensive and unaffordable.

14. As far as possible, promote the recycling of metal or plastic containers into waste-to-energy

fuels or feedstock in post-consumer remanufactured products that are not to be used in the

7

food sector nor come into frequent human contact (i.e. recycling in steel and plastic industrial

products).

CHAPTER 5: Empty container management for locust control in CCA countries

5.2 Main challenges and recommendations on empty container management

5.2.2 Procurement that Considers Packaging (or Lifecycle Approach)

Recommendations:

15. Consider all aspects of the lifecycle of the locust control insecticide, including its long term

efficacy, ease of use, other resources (e.g. water/solvents) required.

16. Consciously factor in any impacts of any residues potentially left in the field.

17. Purchase, if possible, control products that are efficient for locust control, low or no risk to

humans or the environment and no residue-laden materials for destruction. Example: ULV

formulation known to provide good control with minimal damage to beneficial species, no

water diluent required and therefore fewer risks to handlers and materials - provided in drums

that are resealed and returned to the manufacturer or reconditioning/refilling.

5.2.3 Lifecycle management in locust control

Recommendations:

18. Implement a virtual chain-of-custody stock management system that tracks each insecticide

package from import to final destruction of each container or its removal from the country -

for instance by installing and implementing the PSMS; any chain-of-custody stock management

system should include a strict inventory from pesticide import to empty container disposal, with

a chain of responsibility clearly identified as well as the training of control operators in

appropriate storage, handling and transportation of pesticides, spraying, pesticide container

triple-rinsing, etc.

19. Implement best management practices for pesticide storage. Intermodal storage containers

are cheaper than purchasing or renting facilities and can be moved to locations where needed.

A paved apron for loading and unloading the storage facility and basic safety appliances4 are

desirable features.

5.2.4 Cost Evaluation of empty pesticide container management

Recommendation:

20. Design a locust control plan that maximizes protection and also minimizes public expenditures.

5.2.5 Model Pilot Study for disposal of locust control empty containers

21. As mentioned under 4.3.1, there is a recommendation to start in one of the CCA countries with

pilot implementation of sound management of empty containers used for locust control. The

pilot should be structured in line with best practices in other parts of the world and adapted

to the local specific circumstances. The practical experience with containers used for locust

control with limited amounts of containers will provide the countries with valuable lessons

about what works in a specific country and what does not work.

4 Hazard placards, fire extinguisher if needed, eye-wash bottle.

8

Chapter 5.2.5 describes in detail all elements for such a model pilot study, for both EC as well as ULV

formulations:

In any pilot study, a national oversight committee should be formed, headed by the national service in charge of locust control (in most cases, the Ministry of Agriculture/Plant Protection Division). The goal of this advisory or oversight group is to help assure the maximum amount of protection to the country’s biota (especially agriculture) within the practical limits of the resources available, and at the same time protecting the nation’s environment and public health from any off-target residue including those that come from insecticide contaminated media, including empty pesticide containers. This is not to take away authority of the primary implementation body, but rather an assurance that any governing body that could have any enforcement questions at any point of the lifecycle of either the pesticide used or the residues that result from this operation are included and well versed on exactly what is going on and why.5 Members of the oversight body include authorities that have responsibilities for the differing stages that a locust control pesticide pass through in its lifecycle, including entities that oversee environmental protection associated with any use/disposal/recycling operations. Persons in charge of training staff should also be included in the oversight committee.

As mentioned in this report several times, proper container management depends on attention to management at every step of the process from the initial planning and purchasing process to the final disposition of any remaining packaging.

Planning for empty container management begins with the purchasing selection and the formulation type or insecticide selected. If the locust control authority believes that the best control will be realized through the use of an EC pesticide (which is aqueous based and diluted to the proper spray concentration with water), the managers must question whether there is adequate water available in the field for mixing, loading and rinsing operations at each location. The alternative to water based insecticides are ultra-low volume solvent based formulations (ULV). The insecticides are usually applied in the form as removed from the original container without dilution with water. This choice solves the question of available water, but a significant residue remains in the ULV containers and the processing and disposal of those containers must be handled differently. One solution, becoming more common in other nations, is creating a dialogue with the supply chain managers of the providing industry and exploring the possibility of reusable/refillable packaging that can be returned to the manufacturer at the end of the season. This, of course, means that there are two shipping costs, but as we will see, there are costs to cleaning/processing these ULV containers in country as well. There are expenses and risks either way. Some European and North American suppliers are increasingly choosing to install one-way valves and tamper evident seals, rather than leave re-usable containers that once held acutely toxic insecticide in a country where there is concern for long-term safety.

Prior to purchasing the insecticide to be used, the planners need to know what recycling resources are available within the country. Latter should be made a mandatory criterion to be considered in the procurement process. For example, if there is an active steel recovery and recycling industry, the locust control planners may justifiably lean towards specifying steel drums for packaging (e.g. 200 l drums). If there is an active plastics recycling industry, it is important to assess exactly what type of plastic is used in this industry. Most 20-litre pesticide containers are made from high-density polyethylene resin (HDPE no 2). It is also important to determine what are the post-consumer products manufactured by these industries. Established programmes have determined that there is too much risk in producing household product from even well rinsed pesticide containers. However, certain industrial product as listed in the 2008 WHO FAO Guidance are perfectly acceptable to produce, although environmental

5 If there are any questions or concern of overlapping authority, it is far better to resolve those in the planning phase of the Oversight Committee versus questioning some step along the way and possibly slowing down the locust control effort when the insects are hatching or swarming.

9

oversight and employee workplace safety (including permitting and licensing) should still be monitored for these industries.

For both water- and solvent-based formulation, it is recommended that mandatory triple-rinsing takes place as soon as possible immediately after the last decanting of the pesticide. This reduces the amount of pesticide residue remaining in the empty packaging.

a) If pesticides in EC formulation are selected, the planners in a model programme should take the following into consideration:

Planners should assure that there is enough reasonably6 clean water available for dilution of the concentrate.

If the suppliers cannot or will not take the containers back for refilling (without rinsing), then the planners may wish to consider recapping the empty container at each field application site and removing these as quickly as possible to a centralized processing depot. It is important that the formulation does not sit in the sun for any time and cause the formulation to permanently adhere to the inside walls of EC formulation containers.

At these processing depots, the model programme may use the sanctioned triple-rinsing method mentioned above, using water for aqueous based (EC) formulations. Once the residue is removed, the processing depot may choose a consolidation method to reduce the volume of the material for more economical shipping. Methods often used include shredding of materials or granulation or crushing. Crushing is not ideal for plastic containers of large size because, due to a ‘’memory effect” plastic containers tend to spring back toward their original shape. Some balers do have tie-off equipment that wraps the bales with wire or metal strapping to prevent expansion.

Planners should initiate a mandatory manual or mechanical triple-rinsing or the equivalent procedure that follows accepted international practices.

For containers small enough to shake:

Empty the remaining contents into the application equipment or a mix tank and drain for at least 30 seconds after the flow begins to drip;

Fill the container ¼ full with clean water;

Securely re-close the cap;

Shake, rotate and invert the container so that the water reaches all the inside surfaces;

Either add the rinsate to the application equipment or the mix tank; or

Store it for later use (e.g. spraying on areas already sprayed); or allow the container to drain for 30 seconds after the flow begins to drip;

The procedure should be repeated at least twice more until the container appears clean.

For containers7 that are too large to shake :

Empty remaining contents into the application equipment or a mix tank;

Fill the container ¼ full with water;

Replace and tighten closures;

Tip container on its side and roll it back and forth, ensuring at least one revolution of the container;

Stand the container on its end and tip it back and forth several times;

Turn the container over onto its other end and tip it back and forth several times;

Empty (usually by using a pumping device) the rinsate into application equipment or a mix tank or store rinsate for later application, use or disposal8

6 Free of sediment or other contaminants that might clog the spray equipment. 7 These are usually drums of various sizes constructed of polyethylene plastic or steel. 8 Spraying on an already treated field is an acceptable form of disposal.

10

Repeat this procedure at least twice more until the container appears visually clean.

As an alternative to manual triple-rinsing, services in charge of locust management may invest in mechanical rinsing device that are proven by manufacturers to clean containers at least as well as manual triple-rinsing. Examples of these devices are illustrated in the WHO-FAO Guidelines on Management Options for Empty Pesticide Containers (2008). One drawback of this approach is that pressure-rinsing equipment is not readily available in the region.

The oversight committee should identify the resources available for potential recycling or destruction of pesticide containers (e. g. recyclers, waste-to-energy plants) that could safely use clean plastic as a solid fuel for the production of power or rotary kiln produced cement clinker. Plastic recyclers must have the potential for producing a product that is only used for industrial purposes (not homeowner uses) (See WHO-FAO Guidelines on Management Options for Empty Pesticide Containers for a list.) Steel recycling is a desirable option in that residues remaining after careful triple rinsing cannot survive the heat from an open hearth furnace.

b) If pesticides in ULV formulation are selected, the planners in a model programme should take the following as an alternative strategy for empty container treatment:

Planners should assure that there is an adequate supply of the appropriate solvent onsite readily available for triple rinsing.

Immediately after emptying and thorough draining, the operators should triple rinse using the same procedure as the one used for aqueous formulation, but instead use the solvent9 or gasoil specified by the manufacturer.

For containers, small enough to shake:

Empty the remaining contents into the application equipment and drain for at least 30 seconds after the flow begins to drip;

Fill the container ¼ full with solvent or gasoil;

Securely re-close the cap;

Shake, rotate and invert the container so that the solvent reaches all the inside surfaces;

Use the counter-current method of rinsing to limit the quantity of solvent requiring disposal. Either add the rinsate to the application equipment or store it for later disposal (e.g spraying on areas already sprayed or waste to energy high temperature energy recovery.); or

Store it for later disposal (e.g. spraying on areas already sprayed); Always allow the container to completely drain for 30 seconds after the flow begins to drip.

Triple rinsing using the counter current method involves:

First rinsing is done with dirty diesel (i.e. already used for two other drums);

Second rinsing is done with slightly dirty diesel (i.e. already used for one other drum);

Third rinsing is done with clean diesel.

For containers10 that are too large to shake3:

Empty remaining contents into the application equipment or a mix tank;

Fill the container ¼ full with solvent or gasoil;

Replace and tighten closures;

Tip container on its side and roll it back and forth, ensuring at least one revolution of the container;

9 The disposal of the solvent wash is also a point to be considered in the planning. Typically, flammable solvents are used as fuels in waste to energy facilities. 10 These are usually drums of various sizes constructed of polyethylene plastic or steel.

11

Stand the container on its end and tip it back and forth several times;

Turn the container over onto its other end and tip it back and forth several times;

Empty (usually by using a pumping device) the rinsate into application equipment or a mix tank or store rinsate for later application, use or disposal11

Repeat this procedure at least twice more until the container appears visually clean.

A KEY difference for the procedure to rinse ULV formulation is that the rinsate cannot be used as diluent, but must be disposed separately according to hazardous waste rules or other procedures approved by the environmental regulatory authority of that State.

If rinsing is not practical at the site of use, the oversight committee may consider establishing a container processing facility where the empty containers are centralised and rinsed with the appropriate solvent. Although it is best to rinse emulsifiable pesticides in the field as soon as they are emptied, it may be desirable to invest in consolidation equipment for those formulas as well depending on the cost of reverse logistics and taking recovered container to a recycler. At this point size reduction could take place in the form of crushing (best for metal containers) or shredding/granulation for plastic 20-200 litre plastic containers.

NOTE: For both water based and solvent based formulation, it is recommended that mandatory triple-rinsing take place as soon as possible immediately after the last decanting of the pesticide. This reduces the amount of pesticide residue remaining in the empty packaging.

For ULV formulation containers, just as aqueous based packaging, the oversight committee should identify the resources available for potential recycling or destruction of pesticide containers (e. g. recyclers, waste-to-energy plants) that could safely use clean plastic as a solid fuel for the production of power or rotary kiln produced cement clinker. Plastic recyclers must have the potential for producing a product that is only used for industrial purposes (not homeowner uses) (See WHO-FAO Guidelines on Management Options for Empty Pesticide Containers for a list.) Steel recycling is a desirable option in that residues remaining after careful triple rinsing cannot survive the heat from an open hearth furnace.

c) General considerations for empty container management (for both EC and ULV pesticides):

As an alternative to the above procedures, the committee may develop a dialogue with supplier/producers to see if the supply chain manager in each company could furnish alternative packaging that could eliminate or reduce the quantity of containers remaining. If the supplier/producer were willing to allow the locust control customer to simply reseal the drums or large containers and ship back to the point of origin for refilling for another customer, this would eliminate the need for on-site disposal/recycling. Another alternative for removing contaminated containers is to package the insecticide in water dissolvable packaging whereby the inside of the outer open top drum would retain no residue. Both of these approaches would increase the initial purchase price but it would significantly shorten the time in the field if the need for container clean up were eliminated.

Inadequate storage is often a source of pesticide waste and the planner should address this by providing secure, logistically flexible, weather resistant storage containers that can be pre-positioned where pesticides will be used and leftover containers will be collected after use. Most successful container collection programmes use surplus intermodal (ISO) shipping containers for this task.

A fundamental principle for managing both the pesticide product and leftover containers is knowing where each unit is at all times (lifecycle of the pesticide). The planners should create a readily available online database (or use the existing web-based FAO Pesticide Stock Management System) that tracks each unit of insecticide from the time it enters the country

11 Spraying on an already treated field is an acceptable form of disposal.

12

until the empty container is properly disposed/recycled. It is recommended that the planners view this as a verifiable ‘chain-of-custody’ assigning the responsibility for the safety and location of each unit to a responsible individual reporting to the overall locust control programme. At the end of the season, each container must be accounted for.

The country should guarantee that all pesticides used for locust control will be applied directly from their original packaging and that no repackaging into other containers will be allowed. There should be full transparency and disclosure of the purchasing process and on the locust control operations in general. Relevant stakeholders should be informed and have full access to information on the locust control operations and the importance of empty container management practise. Intentionally shared information of any organisation on how the organization operates, on what policy choices are made and on what standards are complied with helps the organization to better perform, be accountable for what they do and assure their quality of work.

Costs and time and resources spent on pilot container management activities should be administered in detail to understand and analyse the efficiency of the full costs associated with the improved practice.

ADDITIONAL Hardware cost for model pilot (in USD)

Drum crusher 10,000-15,000

Plastic shredder 15,000- 20,000

Storage container 1,200-125000/unit + shipping from China

A monitoring programme should be in place to analyse the efficiency of the management operations of return shipment and refilling.

Training

It is important to include a training component into the pilot, including a system of refresher courses for relevant national stakeholders and operating personnel from one season to the next.

It is recommended to include a system to officially certify all operating personnel involved in locust control operations after training and examinations. This re-enforces the concept that each person’s employment depends on following the requirements for properly managing both the insecticides as well as the remaining containers.

Model Courses should include at least the following training modules:

Personal Protective Equipment for applicators and handlers of containers;

Residue Removal (triple-rinsing/equivalent);

Pesticide Stock Management-verifiable record keeping;

Inspection of rinsed containers (suitable for recycling).”

12 May be available locally much cheaper. These are China prices.