The Container Management Working Group was set up in 2009 to identify, document and promote expertise and best practice in relation to the design, storage and disposal of pesticide containers and packaging.
In order to do this the Working Group:
- Developed a time-tabled work plan to result in an interim report for the Pesticides Forum by June 2010.
- Where necessary, reported on progress to the Pesticides Forum at its main meetings.
- Reviewed existing good practice.
- Identified relevant new issues (including changes to regulations and practices) and recommended approaches as appropriate.
- Liaised with the Crop Protection Association, the Agricultural Industries Confederation and individual companies on ways to improve container design and production.
- Identified and engaged with other necessary stakeholders, including manufacturing companies, to improve practice in container design, management, use and recycling of the plastics.
- Considered how the volume of containers being disposed of via landfill might be reduced.
- Developed advice for farmers and operators on the range of disposal options available, defined best practice and sought ways to reduce illegal disposal of pesticide containers by working with stakeholders.
- Produced a specific set of recommendations and identify appropriate recipients, for actions to be taken immediately.
- Identified any areas where information is lacking or areas of uncertainty where the Pesticides Forum may decide to investigate further.
- Identified any resource implications arising from actions in this area.
- Identified any appropriate targets and/or indicators.
The 'On Farm' Situation
During 2005 and 2006 the waste control regulations became applicable to farms in the United Kingdom for the first time. From this date on-farm burning or burial of agricultural waste became an offence. The changes in the law meant that many previously recommended disposal routes, for example burning used pesticide containers in drum incinerators, were no longer permitted.
Farmers can choose a number of legal means of disposal including taking their waste to permitted recovery and disposal sites, commercial waste collection arrangements or more specialist farm waste recycling schemes. Farmers are free to decide which option they take and their choice will depend on cost, convenience or environmental motives. Any company collecting farm wastes must have the appropriate Environment Agency (EA) permits or exemptions to handle the particular waste stream and issue waste transfer notes to farmers supplying them.
As yet, and unlike many other European Union (EU) Directives, the Waste Framework Directive (75/442/EEC, as amended) is not part of Cross Compliance obligations which farmers need to observe to avoid being in breach of their Single Payment Scheme obligations. However many of the Farm Assurance Schemes do include waste management auditing so farmers involved in these schemes will be subject to inspection.
Progress and Recommendations
The Working Group considered the existing container design recommendations which are just short of 20 years old. Whilst many of the design requirements for the safe containment, transport and handling of the containers remain unchanged, no consideration is given in the recommendations to means of disposal beyond the then recommended norm of on-farm incineration. There was therefore a need for the Working Group to consider aspects of container design and packaging which impact on all other methods of disposal, including landfill or recycling.
The discussions involved all the Working Group members with contributions from other stakeholders. The following issues were raised, researched and discussed:
a) Use of foil seals, rinsing and disposal.
b) Container shape.
c) Labels, removal and disposal.
d) Polymer type used for containers.
e) Location of polymer type logo on the container.
f) Promotion of best practice for rinsing.
g) Training and advice.
To see the full report including recommendations follow this link.
Working Group Members from 2 July 2009
Alastair Leake (Game & Conservation Wildlife Trust (GCWT), Advisory Committee on Pesticides (ACP) and Chair of the sub-group)
Tom Bals (Agricultural Engineers Association (AEA))
Simon Barron (Environment Agency (EA))
Anne Buckenham (Crop Protection Association (CPA))
Hugh van Cutsem (Country Land and Business Association (CLA))
Hazel Doonan (Agricultural Industries Confederation (AIC))
David Edwards (Co-operative Farms)
Julian Hasler (National Farmers Union (NFU))
Alan Macdonald (Chemicals Regulation Directorate (CRD))
Jo Oborn (Farming and Wildlife Advisory Group (FWAG))
Nicola Parry (CRD) and secretary)
Joan Reeves (CRD and secretary)
Tania Tucker (EA)
Mike Ward (Transport & General Workers Union (TGWU))