[CED/CD/EAT] Ag Container Recycling Acceptance Standards - ACRC's URGENT SPRING REMINDER

Wed Apr 5 08:44:55 MST 2023

Have you ever tried to recycle triple-rinsed pesticide containers only to be turned away because they were still not considered clean enough to recycle? If so, I think you'll appreciate the following letter from Mark Hudson, Executive Director of the Ag Container Recycling Council (ACRC) and the attachments describing what is and isn't considered clean enough for recycling. I found the photos in the attached "ACRC - Not Acceptable Examples" to be especially helpful.

Thank you, Cheryl Koury, Executive Director of the Arizona Nursery Association, for sending me this information to distribute widely. We encourage everyone to do the same during upcoming presentations, expos, meetings or through listservs and newsletters. Please see the ACRC letter below and the attached documents.

Hello State Agribusiness Associations and Stakeholders!

We appreciate the partnership your states have with the ACRC and would ask that you share this email with your members and growers in your states!  With spring upon us, we would value your help in getting this important word out NOW, before container plastic starts to pile up as the products they contain are used.

The Ag Container Recycling Council (ACRC)<https://www.agrecycling.org/> is the trade association of the ag chemicals industry, responsible for supporting the collection and proper recycling of ag containers nationwide.  The program currently operates in 46 states and collects ALL types of ag chemical containers including pesticides, animal health, specialty pest control, micronutrient, biologicals, fertilizer, and/or adjuvant product containers.  Over the past 30 years, the ACRC program has collected and recycled over 240,000,000 pounds of container plastic!  The program is fully funded by its member companies<https://www.agrecycling.org/our-members/> who are the manufacturers of these products.  Collection of containers takes place through ACRCs network of contractors<https://www.agrecycling.org/recycling/collection-sites/>.

ACRC has recently seen concerns in various states with our container acceptance requirements.  ACRC would like to stress that the container inspection and cleaning criteria used by ACRC contractors, is not the contractors standard, but is the ACRC standard which is ultimately the EPA standard.  This standard was established in the EPA 2006 Container and Containment Rule, requiring 99.99% removal of each active ingredient.  A simple way to articulate this standard is "CLEAN means CLEAN, with NO residue seen."  Staining is fine, but residue is not.  We acknowledge that enforcement of this standard by our contractors requires ongoing training and communication due to staff turnover.  Ongoing training and communication is also required at the end user level (farmers and professional applicators).

ACRCs goal is and will continue to be, to enforce the above inspection standards, not lower them.  As soon as we lower the standard, we jeopardize the program and the health and safety of all involved.  Specific environmental, health and safety (EHS) risks include EHS hazards at collection areas (trailers, staff, soil, groundwater), EHS hazards to downstream parties (contractors, plastic processors, and plastic end users), EHS risks to non-grower collection site owners (retailers, landfills, recycling centers), EHS risks in transportation, and financial impact through inability to recycle and sell the plastic.  Regarding caps and labels, removal and disposal of these has been the responsibility of the end user, not the contractor, throughout the life of the ACRC program.  This requirement is critical to the efficiency of our collection and inspection process.  Booklet labels and caps should be discarded but base labels may remain.  Because ACRC contractors cannot be sure what type of product was in each container, ALL containers must be properly triple or pressure rinsed prior to collection.  This includes non-pesticide products.

While the above may seem like difficult requirements to meet, we know from experience in states all across the country, that these standards are reasonable and readily achievable.  ACRC has many collection sites that continually demonstrate the ability to meet these standards with minimal (0 - 10%) rejects.  You will help foster the long term success of the ACRC program, by reinforcing our education and training efforts to achieve these same results at ALL collection sites in the coming season.  We encourage you to check out the ACRC website<https://www.agrecycling.org/>, and the attachments to this email, for educational details about rinsing.  Several best practices include 1) rinsing at the time of use 2) triple or pressure rinsing until rinsate is water clear and 3) field applying the rinsate.  Remember, CLEAN means CLEAN, with NO residue seen!

Lastly, ACRC would like to recognize and thank all those who are already participating in the ACRC program.  We hope that continues for many years to come.  If you are not currently participating, we hope you will decide to join us<https://www.agrecycling.org/contact/> as we seek to help take care of your land, family, and community, by giving new life to used plastic!

Best regards -

Mark

[cid:image001.png at 01D9679A.B8777000]
J. Mark Hudson
Executive Director
Ag Container Recycling Council
    [Receiver outline]  919-624-8013
     [World outline] <http://www.agrecycling.org/>  www.agrecycling.org<http://www.agrecycling.org/>
    [Envelope outline]  mhudson at agrecycling.org<mailto:mhudson at agrecycling.org>
Confidentiality Notice:  This e-mail message (including all attachments) from the Ag Container Recycling Council (ACRC) is for the sole use of the intended recipient(s) and may contain confidential and privileged information.  Any unauthorized review, use, disclosure or distribution is strictly prohibited.  If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message and any attachments.

Jennifer Weber
Pesticide Safety Education Program
Maricopa County Cooperative Extension
THE UNIVERSITY OF ARIZONA

MARICOPA COUNTY COOPERATIVE EXTENSION
4341 E. Broadway Road
Phoenix, AZ 85040-8807
Office: (602) 827-8222
jennyweber at arizona.edu<mailto:jennyweber at arizona.edu>

extension.arizona.edu/maricopa

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