On July 19, 2004, the Working Committee for Water Quality and Pesticide Disposal (WQ&PD) of the State FIFRA Issues Research and Evaluation Group (SFIREG) submitted a report on pesticide disposal label language to the U.S. Environmental Protection Agency (EPA). The report, entitled EPA Label Review Manual Revision: Pesticide Disposal Language Updates and Other Challenges, includes specific recommendations for pesticide label language relating to:
- On-site disposal and dumping;
- Toxicity category hazard statements;
- Storage and security directions;
- Open burning of containers; and
- Product and container disposal or recycling instructions.
In the report’s cover letter, SFIREG and the WQ&PD Working Committee request that the follow topics be designated as priorities for revising EPA’s labeling policies and making the appropriate modifications to Chapter 13 of EPA’s Label Review Manual:
- Rewording the instructions and/or limitations for on-site disposal;
- Prohibition of open dumping; and
- Consistency between active ingredient toxicity and toxicity hazard statements.
The Working Committee also identified two other important issues requiring prompt review and evaluation by the US EPA, SFIREG and the NPSA:
- An examination and resolution of the apparent jurisdictional and regulatory conflicts between provisions of the Clean Air Act, FIFRA and RCRA related to the open burning of pesticide containers;
- The need for improved storage and security instructions for pesticides.
SFIREG’s letter also stated that:
“We reference the NPSA as a necessary participant in future discussions on these topics because the work of the WQ&PD has greatly benefited from a new and effective working relationship between SFIREG and the NPSA. We believe the NPSA brings significant experience, knowledge and resources to discussions on these particular topics and can be a primary contributor to drafting revisions to product label language and the guidance in the LRM. Future work on these topics will also require the participation of the SFIREG Pesticide Operations and Management Committee (POM).”
On July 23, 2004, NPSA sent the following letter to the EPA supporting SFIREG’s report on pesticide disposal language and urging EPA to give this topic a high priority for action.
Mr. William Diamond, Director
Field and External Affairs Division
EPA – Ariel Rios Building
1200 Pennsylvania Avenue N.W.
Washington, D.C. 20460
Dear Mr. Diamond:
The purpose of this letter is to offer the National Pesticide Stewardship Alliance’s (NPSA) support to the report EPA Label Review Manual Revision: Pesticide Disposal Language Updates and New Challenges recently completed the SFIREG Working Committee for Water Quality and Pesticide Disposal (WQ&PD) and provided to EPA.
NPSA, founded in 2000, is an organization of federal, state and local governmental agencies, educational and research institutions, public organizations, private corporations and individuals that are actively involved in different aspects of pesticide stewardship. We serve as a forum to facilitate cooperation among these entities. Our goals are to increase the effectiveness, efficiency and longevity of pesticide stewardship efforts.
Our alliance was actively involved in the discussions and deliberations in developing the aforementioned report and fully supports its recommendations. Not only did we have a member on the review team, but our membership had the opportunity to provide additional comments and guidance at our 2003 annual meeting in Tucson, Arizona through roundtable discussions led by Mr. Gary Bahr, review team leader. We cannot stress strongly enough the importance of the recommendations for changes to Chapter 13 of the EPA Pesticide Label Manual. The recommendations, particularly the removal of the dispose on site statement, bring pesticide disposal label statements into the 21st century and acknowledge that the protection of our environment is paramount.
On the issue of the open burning of pesticide containers, NPSA suggests that the EPA Pesticide Label Manual require labels take a proactive approach and direct end users to recycling programs and away from open burning. NPSA is piloting a cooperative project with Earth911 to place agricultural/commercial pesticide disposal information for all states on their web site as is currently done for household hazardous waste. In addition to any container disposal statements, directing end users to the Earth911 web site would provide them with current information on their states’ disposal and recycling programs and state contacts for each.
In conclusion, we support the recommendations in the report and urge EPA to give this a high priority for action.
Respectfully submitted,
Mary Grodner, Chairman, Board of Directors
National Pesticide Stewardship Alliance
Gail Amos, President
National Pesticide Stewardship Alliance
