‘Speaking personally and as someone who works in the field, I do not think burning any waste out in the open is a good idea,’ said Patrick Dyke, a consultant in the by-products of combustion. ‘It is not appropriate in a developed country at the beginning of the twenty-first century.’
Although the agrochemical industry defends the practice, Patrick Dyke would like to see a risk assessment completed to show that pollution from the fires is safe.
While UK law still allows farmers to incinerate pesticide waste, new guidelines from the Food and Agriculture Organisation (FAO) advise farmers in developing countries that pesticide-related waste should not be buried, burned or dumped.
Even without this contradictory advice, the government decided some years ago to leave farming out of laws which would have stopped the burning. Back in 1994, ministers could have included farms in European Union (EU) waste management law which would have treated agriculture in the same way as any other industry.
| The Swedish collection scheme The worker below at the Sakab hazardous waste treatment plant in Sweden is preparing several drums of pesticides for disposal. Sweden runs a collection scheme for disposal of pesticides in both small and larger quantities. Local authorities provide collection depots, and regular pick-ups bring the chemicals to Sakab for proper disposal. Photo Barbara Dinham |
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In 1994, the waste framework directive came into effect in the UK,
and was transposed into law by regulations under the Environmental Protection Act in 1996. Most industrial wastes were covered, and burial was one example of a process which became licensed for the first time.
But wastes from farms, mines and quarries were excluded from the legislation. ‘That remains the case,’ said Mark Okuniewski, the Environment Agency’s policy manager for agricultural waste regulation. ‘The government has been working on new regulations to bring these wastes under control. He added: ‘There was a lot of activity about four months ago and we were expecting a consultation paper. But along came foot and mouth, and the work has been stalled. We are expecting a consultation paper and draft regulations this year.’ Meanwhile, the European Commission has lost patience with the government and begun infraction proceedings – taking the government to the European Court for failing to implement EU law.
On this issue, Britain is still the dirty man of Europe: other European countries have implemented the law and are running a variety of schemes to dispose of pesticide containers. Ross Dyer, technical manager for the Crop Protection Association (CPA) – which represents the agrochemical companies in the UK – said he was aware of collection schemes in Germany (see box), Holland and Belgium which were all driven by the EU’s waste management law.
| Recovery scheme in operation – a German example Germany’s equivalent of the Crop Protection Association has had a pesticide container recovery scheme running for years. In the early 1990s, the scheme was voluntary. But with the arrival of a new EU packaging law, the German government introduced legislation making farmers reclaim pesticide waste. Burning and burying this kind of waste is banned in Germany. ‘The other aspect of this was that before re-unification, large farmers in the former Communist Germany were already taking plastic material to collection centres because there was a shortage for industrial use,’ said Thomas Neck from the German Crop Protection and Fertiliser Industry Association, which represents agrochemical companies and distributors. ‘The farmers were already trained in the procedure so it made it easier for us to set up a similar system.’ The scheme is called Pamira – which means the German container disposal project – and is free to farmers. It is mostly used by larger farms within ten to 30 kilometres of the 200 collection centres. Pamira is a separate company from the association, and is paid for by adding between 4% and 5% to the price of pesticides. When the scheme began, it cost about 3,000 Deutschmarks (DM) a tonne: Mr Neck said this has now come down to about 2,000 DM a tonne. Currently, Pamira collects about 1,500 tonnes of solid pesticide container material each year – or about half the 3,000 tonnes which is sold by the industry each year. When he was asked what happened to the rest, Mr Neck said that some farmers used the containers in other ways, such as collecting water and oil. ‘The other point is that some of the packaging material can be re-used by returning them to industry. Some lander (states) organise their own collections within the agricultural waste laws: in Bavaria, for example, where the farming is less intensive and smaller in structure, local authorities have organised some collection programmes.’ he commented. At every collection point, there is a visual check to ensure that the containers have been rinsed and are empty. Containers are then transported to central collection sites where they are shredded and burned in cement kilns. ‘This is a sort of granulated oil with a high energy content,’ said Mr Neck. ‘The kilns burn at very high temperatures and the controls at the collection centres mean there is no problem with pollutants.’ The Pamira logo is on containers, so that farmers are constantly reminded about the scheme. Asked why farmers should use a scheme which can only cost them money, Mr Neck said: ‘Farmers are under constant watch from their neighbours and they know that being positive about society and the environment is part of having a good image.’ |
In general terms, the farmer takes the rinsed packs to a collection site where they are aggregated and taken on to a much larger collection site where they are shredded and sent for incineration with heat recovery.’ He indicated that there are various themes on that model: ‘some use council collection sites for doing this during a four-day window in the year. There are also collection schemes in the United States and Canada which are driven by a mixture of the law and industry stewardship. I am aware of the makings of another scheme in France.’ Fundamental to these schemes are the classification of rinsed packs as non hazardous. Ross Dyer says the CPA is pressing the Environment Agency on the issue and that the approach significantly reduces the risk to the environment and lowers the cost of disposal.
With so many alternatives to burning, why has it taken the UK so long to act? No-one seems to know, but the Tories under John Major were reluctant to increase the amount of red tape on farms. More recently, the Labour Government took a similar policy line as farm incomes plummeted before foot and mouth. When
Pesticides News contacted the Department of the Environment, Transport and the Regions (DETR) to discuss this, we were referred to the Environment Agency and the Ministry of Agriculture green code on pesticides.
Up to now, the agency has been unable to do anything about incinerators on farms because the UK has not introduced the relevant law. Instead, this is left to part five of the green code, which is being revised. The 1998 edition allows containers to be buried ‘… to a depth of at least 0.8 metre below the surface and below the level of any land drains’ if they have been crushed or punctured and rinsed three times.’ Burning is ‘… allowed at a high temperature by using braziers made from old drums’ after the containers have been rinsed. It is this code which has allowed the CPA to advise farmers that using old 210 litre steel drums modified to meet a specific design standard with holes drilled in their sides will be enough to reach the kind of temperatures needed to incinerate pesticide containers. Ross Dyer said data on this type of incinerator from the Silsoe Research Institute in Bedfordshire and the Fire Research Establishment is available to anyone who wants to inspect it. ‘In general terms, it was found that the emissions were no worse than from a bonfire of pinewood sticks,’ said Mr Dyer. ‘The incinerator has only been tested for rinsed, clean pesticide packs – not for fertiliser sacks or animal carcasses.’
Patrick Dyke has his doubts. ‘It is possible to burn this kind of material, but the crucial thing is a peak burn at a sustained temperature in the presence of a certain amount of oxygen. It’s not an easy thing to do – even in a big municipal incinerator. He maintains: ‘We have plenty of data on the large incinerators. Now that the bigger plants are controlled, the smaller plants have more relevance from the point of view of dioxins and some other pollutants.’
When the new EU waste law is introduced, the Environment Agency will have to police it. Mark Okuniewski said there were discussions with the CPA about to what extent other measures can be put in place in relation to the regulations. These may include schemes which would put an onus on the suppliers or manufacturers of pesticides to take back a lot more of the packaging.
In addition, an EU landfill directive has been delayed by the UK General Election, but should come into effect by mid-July. This will close any waste dumps on farms and compel farmers to dispose of material such as pesticide containers to licensed landfill sites. ‘The directive will cover farms in due course,’ said Mr Okuniewski. ‘I am not clear whether it will relate to agricultural waste when it first comes in – bearing in mind that this is not controlled waste yet.’
There is a third directive coming in which will outlaw the CPA’s incinerators. Mr Dyer said this would be implemented across the EU by the end of 2005 and would set down the operating conditions for incinerators as well as the emissions they could put out. ‘We think the incinerator is the best practical, scientific and environmental option for cleaned pesticide packs,’ said Mr Dyer. ‘We will be making that point when the consultation comes up for all these regulations.’
In the UK, Mark Okuniewski said the Environment Agency had been pressing the government about burning and burial for some time. ‘There have been a number of alternatives taking place which we have had to deal with – without the legislation and without the powers. The waste regulations will bring the farming industry into line with other industrial and commercial sectors: in that sense, they will improve matters.’ But at the same time, it was important that farmers had help with waste management. ‘For example, there is a good scheme running in Wales where they recover silage wrap. We would like to see that kind of scheme set up across the country so that farmers have something to turn to to have this waste removed and, where possible, recovered.’
| Disposal in developing countries Some of the CPA’s incinerator designs have been used in other countries, in Asia and Africa. When Mr Dyer was told about the FAO’s advice on avoiding burning and burial, he said this was because the FAO was mainly concerned about disposing of containers which might have old chemicals in them. But in Vietnam, Patricia Matteson, a country programme officer with the FAO’s programme for community integrated pest management in Asia, said that it was clear that burning and burial were not an option. ‘The problem is that there is not yet any suitable technology for the disposal of empty pesticide containers in Vietnam.’ The provincial branch of the Vietnamese women’s union in two villages in the northern province is interested in collecting and disposing of used containers. ‘We are trying to figure out the best solution to their wish to dispose of these properly,’ said Dr Matteson. ‘They came up with the idea because of the hazard to people and the environment after they observed the containers had been discarded into streams and ponds.’ |
Conclusions
The UK is clearly lagging behind on the issue of pesticide container management and needs to take action to come into line with other European and even some developing countries. Current recommendations are not only unacceptable in terms of good environmental practice, but may even be illegal.
The CPA should divert its energy away from promoting incinerators for burning pesticide containers to developing and implementing effective container reuse and recycling schemes. Every piece of policy and legislation on waste management points in this direction. If reuse and recycling are possible for soft drink bottles in most developing countries, there is no reason why similar schemes could not be organised for pesticide containers in the UK.
The farming community need not be overburdened by better pesticide containers management schemes, since they could easily form an integral part of the pesticide supply chain. UK farmers are already suffering a serious image crisis following BSE and foot and mouth disease, and most recently environmental contamination from the carcass pyres fuelled by contaminated railway sleepers. Taking the right action in dealing with pesticide containers can only improve the image of farmers and the pesticide industry.
John Harvey is an agricultural writer and broadcaster.
[This article first appeared in
Pesticides News No. 52, June 2001, pages 6-7]
