2016 Rwanda Pesticide Container Feasibility Study

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Used high-quality plastic and metal Empty Pesticide Containers (EPCs) have considerable value to small-scale farmers in developing countries for use as storage vessels in the same way that new plastic bottles purchased from container stores in the USA have to their developed country counterparts. Risks to human health, safety and environment arise commonly at the smallholder or small-scale farmer sector, where un-rinsed EPCs may be discarded in the field or streams, burned, or worse, reused for storing water, milk, cooking oil, drinks or food.

This report discusses the background, objective, activity description and proposed activities for this study of the proper disposition of EPCs. It spends eight pages describing a brief history of EPC management, and all of the key players—in addition to CropLife International (CLI, an international trade association of pesticide and agribusiness companies founded in 2001)—that have been and are involved.

It is clear on pages 4 to 11 of this report that there have been over eight different groups or initiatives involved in the evolution of EPC management, including the United Nations, the UN Food and Agriculture Organization, the UN World Health Organization, World Bank, Global Environment Facility, Africa Stockpiles Program, Standards and Certification schemes like GlobalGAP, Non-Governmental Organizations (NGOs) as well as the roles of regional development banks.

Worldwide, CLI members are responsible for the presence of containers in which they sell pesticides, so they take responsibility for those. Over they years, as part of their Stewardship Program—a lifecycle approach to product management—they have taken a leadership role in EPC management. CLI has the most global experience helping promote, finance and operate such programs, and naturally takes or shares the lead wherever such initiatives are begun. But they involve as many players as possible, including those listed above as well as donors, due to the financial and logistical needs. Plastic #2 or high-density polyethylene (HDPE) is a commonly recycled plastic, and is the most common plastic used to make chemical and pesticide bottles. EPCs from HDPE plastic are the most common type found in East Africa.

The countries with the most successful EPC disposal and recycling schemes have developed local non-profits and NGOs that operate these programs by bringing together resources from numerous sources. Most tropical and subtropical EPC management programs require supplementary funding (subsidies, tax breaks, rebates, donations) from public resources as well as combined financial and coordination efforts of ‘partners’ from the private sector, governments, especially ministries of agriculture and health, non-governmental organizations, as well as multilateral and bilateral donors.

According to CLI, there are currently 36 established EPC plastics recycling schemes in North America, Europe, Australia, New Zealand and Latin America. Few African and Asian countries have in place comprehensive legislation relating to EPC management, particularly in regards to state of the art recycling techniques. However, some developing countries have acquired limited legislation regulating EPC management, predominately in regards to triple rinsing (to remove 99.9% of residues), puncturing (to keep EPCs from being reused for liquid storage), discarding waste, high temperature institutional incineration, on-farm burial of plastic and cardboard waste.

Notably, Brazil, Guatemala, Mexico, Ghana and South Africa have acquired more robust policies and dedicated resources (including incentives, subsidies, infrastructure, and enforcement) to ensure that the best EPC management practices are followed. CLI has coined the merged word “CleanFarm” (in Spanish, CampoLimpio) for these programs.
HDPE plastic is commonly recycled into agricultural plastic sheeting, lumber, pallets, irrigation tubes, refuse bags, trashcans, benches, and greenhouse seedling trays.

Many constraints hamstring EPC disposal and recycling programs. Lack of funding is the biggest hurdle and generally public/multilateral donor funding is sought to assist. Most jurisdictions consider unwashed EPCs (that still contain pesticide residues) to be Hazardous Materials (HazMats), and thus require a separate recycling stream, adding complexity and cost. Generally insufficiently cleaned EPCs can only be incinerated, and those that are properly cleaned are recycled into agricultural or industrial plastic items, not domestic ones.

Recyclers require a sufficient amount of raw material—EPCs—for separate recycling runs, which can be a challenge to accomplish in smaller countries with undeveloped agriculture systems that produce relatively small amounts of EPCs. Some countries, like Indonesia, require costly environmental assessments be produced before EPC collection and recycling can commence. Finally, in all but a very few countries, supportive EPC recycling or disposal policies and regulations are lacking.

Several international conventions and guidelines have been developed to deal with obsolete pesticides and EPCs. Rwanda is rapidly developing pesticide policies, but still lacks a strong policy on the disposition, especially by recycling, of EPCs.

The study found that the farming sector in the northern province of Rwanda has the country’s highest use of pesticides, followed by the western province. And, after commercial crops of coffee and tea, the following crops, potato, vegetables and rice receive the highest quantities of pesticides used in Rwanda. This province and these crops would provide a suitable environment to pilot test a collection, transport, cleaning and recycling initiative.

Finally, this study found through data provided by the Rwanda Revenue Authority (that tracks imports) that a sufficient quantity of pesticide containers are entering Rwanda to support a recycling initiative. The study found that what is lacking is farmer awareness to the severity of the health issues related to EPC reuse, and the need to clean and return these to pesticide retailers. All survey respondents felt confident that a rebate program would provide sufficient incentive for farmers to return EPCs to retailers.