Waste legislation is changing at a rapid pace. Aimed at improving standards and reducing environmental harm, stricter laws affect some sectors much more than others. That’s certainly true of the pest control industry. Here, Lee Petts, managing director of specialist waste and environmental management firm Remsol, offers his views on the waste challenges facing the pest control sector and explains the importance of some of the new rules.
Putting waste controls into context
The UK generates more than its fair share of commercial and industrial waste. Despite moves to reduce waste at source and recycle more, the greater proportion of business waste is still disposed of – mostly to landfill.
Although often derided simply as ‘dumping’ of waste, modern-day and properly engineered landfill sites are anything but dumps, and there is a relatively low risk of environmental harm occurring where sites are well managed.
However, not all landfill sites have historically been that well managed. For instance, in the mid 1980’s, a large landfill operator in the North East of England was renowned for accepting all sorts of hazardous liquid concoctions even when they were not permitted to accept liquid wastes. Their justification? That the waste they accepted was solid. Well, the packaging it was contained in was at any rate!
Poor practices like this over the years are really where our current environmental protection laws originate.
There has long been a widely accepted understanding, particularly across Europe, that as soon as a material has no further value to its holder, and is therefore waste, they will take substantially less care of it than they would if it still had some use or value to them.
With this recognition in mind, lawmakers and those responsible for policy have progressively implemented a raft of increasingly restrictive laws that govern how we can deal with the wastes we generate across industry.
How increasing waste regulation affects the pest control sector
After poisoning, animal cadavers have generally been treated as being potentially contaminated and therefore typically discarded in sealed units for incineration and this hasn’t really changed as a result of more recent legislative controls.
Why is it important to treat carcasses in this way? Well, put simply, there is a risk that ingested poisonous substances could be transferred to other animals higher up the food chain, allowing potentially damaging and persistent chemicals to enter the environment.
The area in which new waste laws are probably set to have the most impact on the pest control sector concerns empty packaging.
In 2005, the Hazardous Waste Regulations (England and Wales) were introduced and replaced the earlier Special Waste Regulations 1996.
Under the former regulatory framework, it was permissible in many cases to claim that packaging that had previously contained dangerous substances was non-hazardous provided every effort had been made to remove all traces of the prior contents (such as pouring, scraping, aspirating etc). This was referred to as the ‘de minimis rule’, and could be applied when waste producers were able to demonstrate that former hazardous components were present at below certain threshold levels.
The new regime isn’t quite so clear, and so in the majority of cases, packaging that has previously contained hazardous chemicals will need to be treated as being a hazardous waste – even when empty and containing only residues. This is especially true in the case of containers that have previously held biocides, insecticides, pesticides etc.
Well, the simple fact is that many of the chemicals that are used to control pests such as insects and rodents are extremely harmful in the aquatic environment particularly. Take a look at the material safety datasheet for DRAT containing Chlorophacinone (http://www.pestcontrol-expert.com/BAYER/CropScience/BESpestcontrol.nsf/id/DA4F1AC18469D086C12572920045AB10/$file/Drat.pdf ) which shows that the lethal concentration of this substance at which 50% of exposed rainbow trout will die is just 0.35mg/l.
Nominally empty containers that have previously held chemicals with biocide properties could, if accidentally mismanaged or deliberately abandoned without due care, leach their residue contents into the natural environment to cause significant harm.
Such harm isn’t always immediately noticeable: some of the chemicals used to manufacture pest control products are incredibly persistent which means they won’t be broken-down in the environment. Instead, they have a tendency to concentrate in soils and sediment, where they can be taken-up by fish and mammals. Once ingested, they bioaccumulate in the fatty tissue of these living organisms and because of this there is a real risk that they could enter the human food chain, causing long-term and delayed harm.
If you’ve experienced difficulties discarding unwanted, nominally empty bottles, kegs, sacks and drums that have been used to store pest control products, this is why.
The problem is compounded by the requirement to pre-treat hazardous and non-hazardous waste if it is intended ultimately for landfill disposal, which is a requirement of the EC Landfill Directive 1999. These requirements, transposed into domestic law in the form of the Landfill (England and Wales) Regulations 2002, also prohibit certain forms of hazardous waste from landfill, including those that are flammable or toxic – which some pest control products are.
As an industry, it’s easy to see why you might feel beleaguered by all these new laws!
Overcoming the packaging waste problem
You’re almost certainly going to find that small packages in particular are difficult to dispose of, and may now require incineration as the only tried-and-tested, widely available option that will prevent the risk of earlier contents escaping into the environment.
Larger containers, however, such as 25 litre carboys, 205 litre drums and IBCs, may be suitable for reconditioning or other forms of recycling depending on the nature of former contents and the levels of contamination present.
Remsol already manages tens of thousands of containers like this for reconditioning at selected and vigorously vetted facilities across the UK. We can arrange for palletised collection from anywhere, and in the majority of cases the empty packagings will be subjected to a specialist and automated cleaning process to enable their subsequent reuse. Metal containers that cannot be reconditioned are put through a furnace for their steel value, and washed plastic containers are shredded and sent to landfill once decontaminated.
Our advice would be to speak to your suppliers, and wherever possible and feasible for you, have them send you your pest control chemicals in larger packages to make it easier to facilitate onwards recovery.
For our part, we’re considering the possibility of establishing specialist container collection routes for the pest control sector. The core principal will be for end-users to return empty contaminated packaging to their suppliers, and Remsol will arrange for collection from there. It’s likely that our service will encompass on-site, mobile volume reduction of smaller waste containers to facilitate their subsequent disposal at one of several waste-to-energy incineration plants around the UK – priced to compete with current landfill costs but at rates that are far less expensive than conventional high-temperature incineration routes.
If you can develop a validated method for washing empty containers to remove any residues, which you can demonstrate does clean the internals of the packaging effectively, then you may be able to discard your packaging as pre-treated, non-hazardous waste. But (there’s always a but!) remember: you’ll need to be confident that you can prove your method works; in solving one waste problem, you’ll potentially create another (what to do with the contaminated rinsewaters); and if the individual packages are small and there are many of them, it could be an incredibly time-consuming, labour-intensive and inefficient task.
Other, wider environmental implications to consider
If you’ve watched the TV news in the last couple of months, you might have noticed an increase in the number of reports telling us about the decline in the UK bee population, disappearing flora, and the dramatic reduction in the numbers of the common British sparrow.
So far, researchers have been unable to conclude the precise causes of these worrying trends.
Could they be linked? And could pest control activities be contributing to them?
The short answer to both questions is ‘yes’.
A fall in the number of bees and other insects could be expected to trigger a reduction in pollination levels of flowers and other plants, which could explain why some species of native plants seem to be disappearing from the wild.
Fewer bees and other flying insects could, in turn, lead to our diminishing sparrow population given that these insects are typically a food-source for birds like this.
It is possible that pest control products, such as insecticides, are contributing to a break-down in the delicate natural balance of the Earth’s ecosystem. [Although without data, this is firmly in therealms of speculation - EDITOR]
End-users of products like this need to develop a better understanding of the need for greater environmental control as well as the wide-ranging safety controls that already exist to protect human health (particularly those applying such substances in the field).
Environmental awareness training for those specifying, purchasing and using pest control products may be the answer, and Remsol can help with this too. But this is only part of the solution: manufacturers of biocides will find they have to take a stronger lead in product stewardship, designing products that have fewer harmful consequences and making sure that customers have all the help and support they need to minimise the environmental effects during use.
A good understanding of the ‘Source-Pathway-Receptor’ concept of environmental risk assessment across the pest control sector would also be of benefit.
The impacts of new, emerging and tighter legislative controls on waste management will undoubtedly continue to have far-reaching effects for the pest control sector.
Whether you’re a Local Authority end-user, a private pest control contractor or manufacturer and distributor of pest control chemicals, you’re almost certain to experience increasing difficulties when it comes to disposing of your empty chemical containers.
These problems are not insurmountable: some clever planning, a full understanding of the disposal and recovery options that exist, coupled with sound contacts within the waste management industry will all help to keep costs under control whilst ensuring your waste is dealt with compliantly.
Additional partnering between end-users and suppliers will also prove invaluable.
Businesses seeking specific guidance can contact Remsol for help, by visiting the website www.remsol.co.uk
Good practice guide (simple steps to compliant and cost effective pest control container disposal)
- reduce packaging materials
Consider returnable packaging, and discuss with your supplier if they can accept these back either for direct reuse or to arrange reconditioning / safe disposal. Opt for larger pack sizes as these will mean less packaging overall.
- clean the packaging
If you produce relatively small amounts of contaminated packaging, washing it so that it can be regarded as non-hazardous will help to substantially reduce your disposal costs – it can cost many times more to disposal of hazardous packaging. But, be sure to protect against releases of rinsewaters to the environment and avoid contaminating any clean materials. Also, make sure you remove any prior warning labels or deface these after cleaning.
- sort the packaging
You might find that your appointed disposal contractor needs you to segregate your packaging (contaminated or otherwise) into different types, usually based on material of construction. For example, metal containers may need to be kept separate from plastic ones. Contaminated paper sacks and plastic bags are best placed into sealable plastic sacks and then into large boxes or clip-top drums for intermediate storage pending removal and disposal.
- store it safely
If you’re going to store empty pesticide containers etc., make sure you do so in a way that means the waste cannot escape (i.e., cannot get into surface water drains to cause pollution of a watercourse, and that it cannot be blown off-site to be deposited elsewhere where its contents could get into the environment). Both of these circumstances could result in severe punishment under Section 85 of the Water Resources Act 1991 or Section 33 of the Environmental Protection Act 1990 respectively.
About the author
Lee Petts is the founder and current managing director of Remsol, a business he launched in 2002.
He has been providing specialist waste and environmental management services in the UK for over 11 years.
In his spare time, Lee likes to encourage his two children to take an avid interest in the environment around them. After all, we only have one!