In late 2005 the TPSA focus group drafted a prospectus outlining pesticide stewardship problems and describing the PLCS initiative. In 2006 we began to broaden this conversation in several ways. We developed the vocabulary of pesticide life-cycle stewardship and EPR, to put these concepts on the radar screen of pesticide stakeholders. We developed a relationship with the Product Stewardship Institute, a group that has brought the framework of LCS ND EPR to other industries. We began a dialogue to involve key pesticide industry stakeholders including the TPSA membership, American Association of Pesticide Control Officials, CropLife America, the Agricultural Container Recycling Council, American Association of Pesticide Safety Educators, the North America Hazardous Waste Association, the EPA and others. There is considerably more work to do in building stakeholder involvement, but the initial impact is in opening a multi-stakeholder conversation and in documenting need to the regulatory, end-user and producer communities. \nThis initiative bridges several of my program areas including recycling agricultural plastics, pesticide risk reduction, sustainability and biosecurity (a program theme 2003-2004). PLCS is a biosecurity issue because pesticide overstocks and obsolete products are hazardous materials that should be removed from insecure locations in communities.
impact statement issue
Regulatory mandates dictate that training and stewardship protocols are in place at certain stages of the pesticide life cycle. For example usage rates and permitted uses and are strictly regulated by the pesticide label. However, stewardship at the end of a pesticide's life cycle (i.e., at the point of disposal for obsolete pesticides and overstocks and their containers) has been at the pleasure of the pesticides industry and related trade groups (such as the Agricultural Container Recycling Council), and of state and local Clean Sweep programs for collection of hazardous materials. The early 1990s saw the proliferation of such efforts and programs but, with budget shortfalls of the past several years, many of these voluntary and local programs have retrenched. Pesticide end users in many areas of the United States have thus been left with accumulations of hazardous products and containers. Without proper disposal, materials are often stored in places where they could contaminate water and soil, or be consumed by livestock, wildlife, or children. Containers, some with residual products, are sometimes burned in open fires on the farm. This exposes farm families and other rural residents, livestock and wildlife, as well as the plants near the base of the human food chain, to dioxins and other toxic emissions. For the very most part, the economic, social and environmental costs of proper disposal have not been factored into the costs of doing business.
impact statement response
Working as a member of The Pesticide Stewardship Alliance (TPSA) Product Life-Cycle Stewarship (PLCS) Focus Group, I am promoting a dialog with a diverse array of pesticide stakeholders (manufactures, distributors, regulators, end-users, and educators) to envision and then implement a sustainable infrastructure for end-of-life pesticide stewardship. In July 2005 I represented TPSA at the US EPA Pesticide Environmental Stewardship Program (PESP) Conference, introducing the PLCS initiative at an early stage of its development. EPA's PESP has focused almost entirely on integrated pest management (IPM) and selection of least toxic products as its approach to reducing pesticide risk. Without diminishing the value of IPM, the PLCS initiative advocates for a broader framework for pesticide stewardship. In February 2006 I co-authored a presentation on PLCS at the TPSA 2006 Conference, and facilitated a session discussing strategy and implementation steps. We continued this dialogue with US EPA following the TPSA Conference, meeting with the Director and Staff of the US EPA OPP Field and External Affairs Division, developing a position paper, and carrying the conversation to the March 2006 biannual meeting of the Association of American Pest Control Officials (AAPCO). As Program Chair of the 2007 TPSA Conference, I integrated PLCS into the conference theme (Enhancing Pesticide Life Cycle Stewardship) and into sessions about disposal, drift, pesticide poisoning, pesticide packaging, container recycling, etc.
impact statement summary
This initiative applies the conceptual framework of Life Cycle Stewardship (LCS) and Extended Product Responsibility (EPR) to the stewardship of pesticide products. Its premise is that sustainable, transparent stewardship protocols must be in place at all stages of the pesticide life cycle, from product development and manufacture, through distribution and use, to the collection and disposal of unused products and containers. We advocate full stakeholder involvement in developing a stewardship strategy and implementation plan for the United States, particularly for the oft-ignored stages of pesticide storage and disposal. The LCS concept hinges on a full life-cycle assessment of inputs, outputs and impacts, moving beyond recycling as the sole means for resource reduction. LCS focuses instead on product design and use, with the objective of reducing throughput. E.g., if end-users purchase only the quantity of pesticide they need, less unused product remains and the potential for improper storage and unintended exposure is reduced. End-users have incentive to reduce the amount they purchase if pricing of smaller packages is cost effective, if return policies are attractive, if advertising encourages this behavior, and so forth. The acronym EPR can refer to either of two variations on the theme: 'Producer Responsibility' implies that the locus of responsibility lies with the produce. 'Product' responsibility does not assign responsibility a priori.\n