Pesticides and the RCRA Resource Conservation and Recovery Act

Transcription

1 PESTICIDE RISK REDUCTION EDUCATION Pesticides and the RCRA Resource Conservation and Recovery Act August 2014 FOR PERSONS SEEKING CERTIFICATION BY THE STATE OF HAWAII DEPARTMENT OF AGRICULTURE TO BUY, USE, OR SUPERVISE THE USE OF RESTRICTED USE PESTICIDES This study guide was developed for the Pesticide Risk Reduction Education program, a program of the College of Tropical Agriculture and Human Resources, University of Hawaii at Manoa. Please direct any question or comment about this guide to: Charles Nagamine Department of Plant and Environmental Protection Sciences 3190 Maile Way Room 307 Honolulu, HI Telephone: (808) cynagami@hawaii.edu DEVELOPMENT OF THIS GUIDE WAS SUPPORTED IN PART BY THE STATE OF HAWAII DEPARTMENT OF AGRICULTURE.

2 Table of Contents About This Study Guide... 2 Know the Law... 3 Information and Rules for Hawaii... 3 Categories of Generators of Hazardous Waste... 4 Conditionally exempt small quantity generator... 4 Small quantity generator... 5 Large quantity generator... 5 Acutely hazardous waste... 5 Acutely hazardous waste... 5 Selections from EPA s List of Lists... 6 References... 7 About This Study Guide Purpose This study guide was developed for persons preparing for the State of Hawaii Department of Agriculture s restricted use pesticide certification examination. Scope This study guide gives more information about pesticide disposal as described in Unit 11 Transportation, Storage, Disposal, and Cleanup in the booklet titled Applying Pesticides Correctly: A Guide for Private and Commercial Applicators. 2 Pesticides and the RCRA

3 Know the Law Information in the box below is the basis for the rest of this leaflet. It is a copy of the box on page 9 in Unit 11 Transportation, Storage, Disposal, and Cleanup in the booklet titled Applying Pesticides Correctly: A Guide for Private and Commercial Applicators. Information and Rules for Hawaii Who regulates hazardous waste in Hawaii? Hawaii Department of Health. For information about hazardous waste rules, contact the Solid and Hazardous Waste Branch, Hawaii Department of Health, 919 Ala Moana Boulevard #212, Honolulu, Hawaii Phone Fax What can I do about old and unused pesticides in Hawaii? Consult an environmental health specialist at one of the Hawaii Department of Agriculture s Pesticides Branch offices: Hawaii island applicators call Hilo direct or Maui applicators call Honolulu direct or , or toll-free x or followed by #. (Continued on page 4) December

4 (Continued from page 3) Lanai and Molokai applicators call Honolulu direct or , or toll-free x or followed by #. Oahu applicators call Honolulu direct or Kauai applicators call Honolulu direct or , or toll free x or followed by #. The environmental health specialists have offices separated from those of the pesticide enforcement inspectors. Can I burn pesticide containers in Hawaii? No. Fire departments do not give permission to burn any trash in open air fires. Toxic smoke comes from pesticide residue in burning containers. Open air fires can spread and cause other fires. Can I bury pesticide containers in Hawaii? Burying pesticide containers is not recommended because it could cause two kinds of long-term problems: contamination of soil and groundwater investigation if contamination is suspected and requirement for clean up if serious contamination is found. Categories of Generators of Hazardous Waste Three categories of hazardous waste generators are set up by the Resource Conservation and Recovery Act: Conditionally exempt small quantity generator Small quantity generator Large quantity generator These categories are based on the amount of hazardous waste involved. Rules for storing and shipping hazardous waste get more complicated as you generate and keep more of it. Here are some examples: Conditionally exempt small quantity generator If you generate not more than 100 kilograms (about 220 pounds or 25 gallons) of hazardous waste or no more than 1 kilogram (about 2.2 pounds) of acutely hazardous waste (explained below) in any calendar month, you are required to: 1. Identify all hazardous waste you generate. 2. Send this waste to a hazardous waste facility or a landfill or other facility approved by the state for industrial or municipal wastes. (None are in Hawaii. Rubbish dumps are called sanitary landfills and are not approved for hazardous waste.) 3. Never accumulate more than 1,000 kilograms of hazardous waste on your property at any time. If you do, you become subject to all the requirements applicable to a Small Quantity Generator (described below). 4. If you plan to ship hazardous waste, you are advised (but not required) to fill out and use a form called the Uniform Hazardous Waste Manifest. 4 Pesticides and the RCRA

5 Small quantity generator If you generate more than 100 and less than 1,000 kilograms (between 220 and 2,200 pounds or about 25 to under 300 gallons) of hazardous waste or no more than 1 kg of acutely hazardous waste (explained below) in any month: 1. You are required to obtain an EPA Identification Number. (Contact the Hawaii Department of Health for details.) 2. You may store no more than 6000 kilograms of hazardous waste on your site for up to 180 days, or for up to 270 days if the waste must be shipped to a treatment, storage, or disposal facility that is located over 200 miles away. (There are no such disposal facilities in Hawaii.) 3. If you plan to ship hazardous waste, you are required to fill out and use a form called the Uniform Hazardous Waste Manifest. This is a multi-copy shipping document designed so that shipments of hazardous waste can be tracked from their point of generation to their final destination. Large quantity generator If you generate more than 1,000 kilograms (2,200 pounds or about 300 gallons) of hazardous waste or no more than 1 kg of acutely hazardous waste (explained below) in any month, you are required to comply with all applicable hazardous waste management rules. (Contact the Hawaii Department of Health for details.) Acutely hazardous waste To learn if EPA classified your unwanted pesticide as acutely hazardous, check these sources: Label (on the pesticide container). Look in the Storage and Disposal section for the statement: Pesticide wastes are acutely hazardous. MSDS. Look in the Regulatory Information section of your product s MSDS for a RCRA code beginning with the letter P, such as P070 and P194. Hazardous waste managers often call these chemicals P listed or P coded wastes. ( U listed wastes are not acutely hazardous wastes.) Internet. Find the RCRA code for your pesticide s active ingredient on the web pages for the U.S. Environmental Protection Agency s List of Lists, On the next two pages are samples of what you would find there. December

6 Selections from EPA s List of Lists ( EPCRA EPCRA CERCLA TRI RMP TQ CAS TPQ RQ RQ Sec. RCRA Name Number Sec. 302 Sec. 304 Sec Code Sec. 112r Aldicarb /10, Y P070 - Aluminum phosphide Y P006 - Amitrole Y U011 - Cacodylic acid U136 - Calcium hypochlorite Carbaryl Y U279 - Carbophenothion Chlordane , Y U036 - Chlorothalonil Y - - Chlorpyrifos Demeton Diazinon Y - - Dicamba ,000 Y - - Dichlorvos , Y - - Dicofol Y - - Dimethoate /10, Y P044 - Dinoseb /10,000 1,000 1,000 Y P020 - Dioxathion Diphacinone /10, Diquat , Disulfoton P039 - Diuron Y - - Endosulfan /10, P050 - Ethion , Ethylene dibromide Y U067 - Fenamiphos /10, Fensulfothion Heptachlor Y P059 - Lindane ,000/10, Y U129 - Malathion Y - - Maneb Y - - Methidathion /10, Methomyl /10, P066 - Methoxychlor Y U247 - Methyl bromide ,000 1,000 1,000 Y U029 - Mevinphos Y - - Nicotine sulfate /10, Y - - (Continued on page 7) 6 Pesticides and the RCRA

7 (Continued from page 6) EPCRA EPCRA CERCLA TRI RMP TQ CAS TPQ RQ RQ Sec. RCRA Name Number Sec. 302 Sec. 304 Sec Code Sec. 112r Oxamyl /10, P194 - Paraquat dichloride /10, Y - - Parathion Y P089 - Phorate P094 - Phosphamidon Sodium cacodylate /10, Trifluralin Y - - Warfarin /10, Y P001 - Zinc phosphide Y P122 - References 1. U.S. Environmental Protection Agency s Label Review Manual, Chapter 13 Storage and Disposal (October 2008). (as viewed 12/5/11) 2. U.S. Environmental Protection Agency s web page Hazardous Waste Generators (as viewed 12/5/11) 3. Cornell University. Fact sheet Pesticide waste vs. hazardous waste facts/pesthazard.html (as viewed 9/18/05) December

8 Pesticide Risk Reduction Education is a program of the College of Tropical Agriculture and Human Resources of the University of Hawaii at Manoa. It receives funding from the U.S. Environmental Protection Agency via the U.S. Department of Agriculture s Pesticide Safety Education Program. Its staff provides study guides, short courses, and a newsletter for Hawaii s applicators of restricted use pesticides. These education and training activities support the State of Hawaii Department of Agriculture s program for certification of applicators of restricted use pesticides. Pesticide Risk Reduction Education Certification of Restricted Use Pesticide Applicators Pesticides RCRA