A discussion paper prepared by a joint Steering Committee of ANZECC and ARMCANZ, June 1997

1. Setting the Scene

There are clear environmental, public and occupational health, and international trade reasons why Australia should safely manage and destroy its unwanted stocks of organochlorine pesticides (OCPs) and other unwanted farm and household chemicals. Some of these, particularly OCPs, are renowned for being long-lived, of high environmental and human hazard. Monitoring of land and aquatic environments, and of human tissue and breastmilk⁵ have, from time to time, revealed levels of OCPs above acceptable standards.

Previous use of OCPs on farms and subsequent uptake into primary produce has already resulted in multimillion dollar trade losses. To illustrate the significance of the primary produce trade market that could be affected, the Weekend Australian estimated that Australia's beef export market is worth between $2 and $3 billion⁶. Australia's beef trade with Japan alone is estimated to be worth $1.6 billion⁷ and the production of beef is just one primary produce sector that could, in the future, be affected by chemical residues.

As will be discussed later in this Paper, collection of OCPs and other pesticides have been undertaken before. The only national chemical collection scheme occurred in 1987⁸ and this removed some OCPs from farms. This occurred after the US Government detected OCP residues in Australian beef. Commonwealth, State and Territory governments were keen to retain the good image of Australia's agricultural industries and in addition to collecting unwanted OCPs, they have restricted or prohibited the use of most OCPs, particularly DDT. Accurate consolidated national figures are not available on the financial impact of the 1987 OCP contamination trade embargo, but it must be in the order of several hundred $million. In terms of the cost of collecting the OCPs, it is estimated⁹ that the OCP buy-back scheme and the chemical testing program cost approximately $50 million. Although the risk associated with any remaining stocks of OCPs finding their way into the food chain is less than it was 10 years ago, it is still possible. Should this occur, these figures are indicative of the magnitude of possible future losses should contamination occur.

The above illustrates how pesticide contamination of primary produce has and could still result in trade restrictions and that associated costs to Australia would be very high. Stocks of other unwanted farm and households chemicals are also a potential source of such contamination with the risks of contamination increasing over time through container deterioration or misadventure. On the other hand, risks and costs are also associated with the collection and transport of unwanted farm and household chemicals to new storage sites or destruction facilities. All risks and costs will need to be assessed and balanced in designing a scheme for the management of unwanted farm and household chemicals.

The development of an OCP management plan is part of a wider national effort to safely manage organochlorine wastes through ANZECC's National Strategy for the Management of Scheduled Wastes. In 1993, ANZECC agreed that the issue of persistent organochlorine wastes should be tackled through nationally-agreed management plans. Since Australia started to implement the National Strategyin April 1994, governments have endorsed two management plans, one for polychlorinated biphenyls and one for ICI Australia's hexachlorobenzene waste. A third plan for OCP waste is being prepared in parallel with the development of a proposal for the collection and destruction of unwanted farm and household chemicals.

Whereas the other two management plans deal with scheduled wastes that belong to holders who will need to take responsibility for destruction of their own waste, the OCP management plan deals with wastes held by a much more diverse group, including farmers and householders. Collection and destruction of OCP wastes therefore presents an added level of complexity if these wastes are to be safely destroyed; for example, who will pay for destruction. ANZECC has asked that advice be developed on the scope of the problem and possible solutions.

This discussion paper aims to generate discussion on both the scope of the problem and possible solutions. In doing this it suggests that a collection program could have several key building blocks which include safe on-site storage, the various options or models for collection, the infrastructure needed to collect and consolidate the waste, transport considerations, waste destruction or management (if some of the waste is to be recycled), and public accountability and reporting. As part of each key building block, there are many issues that will require discussion. Some of these are summarised in Figure 1 which also presents some idea of the chronology of a collection scheme and possible links between the various key building blocks.

Transparency and public reporting are two features of the National Strategy which have underpinned its success. To gain public confidence and support, transparency, public accountability and reporting are seen as important features of any collection scheme. Given their importance, this discussion paper treats them as being part of a separate building block. Likewise transport, while a feature of the whole process, is also treated as a separate building block.

2. Scope of the Unwanted Chemicals Issue

The National Strategy for the Management of Scheduled Wastes, endorsed by ANZECC in 1993 and reproduced subsequently in the management plan being developed for OCPs, provides a useful starting point for establishing the scope of a national collection, storage and destruction scheme for unwanted farm and household chemicals.

The relevant organochlorines listed on ANZECC's schedule X are:

Aldrin	Hexachlorophene
Isodrin	Lindane and its isomers
Dieldrin	Pentachloronitrobenzene
DDT	Pentachlorophenol
Endrin	Chlordane
2,4,5-T	Heptachlor

The schedule X organochlorines, DDD, DDE and Heptachlor epoxide may be found in collected unwanted chemicals as breakdown products.

While the emphasis in this discussion paper is still on the above Scheduled OCPs, its scope has been broadened so as to include 'unwanted farm and household chemicals' such as the non-scheduled OCPs mirex, toxaphene, methoxychlor, and isobenzan. In so broadening the scope, this paper recognises that all types of chemicals were surrendered through past chemicals collection programs. For the purpose of workshop discussions, this paper proposes that priorities be in the following order:

• Schedule X OCPs;
• other OCPs, including mirex (which remains registered for use in Western Australia and the Northern Territory), toxaphene, methoxychlor, and isobenzan;
• other unregistered pesticides, such as nicotine
• other unwanted pesticides; and
• other unwanted farm and household chemicals, especially those that are hazardous.

Figure 1: Considerations in the collection, storage and destruction of unwanted farm and household chemicals

KEY BUILDING BLOCKS	ISSUES REQUIRING DECISION
Safe on site storage	should guidelines/principles for interim on farm/household storage be provided
Models for collection	How many times is collection offered? Transport distance: Finite or indefinite? Repeated? Collection to holder or holder to collection point? Damaged containers Damage to containers	Bounty paid? Payment required? Amnesty given? Locations? Public reporting? Education/publicity
Collection Points and Consolidation stores 10	Identification of wastes To be part of an excisting facility? Functions of the consolidator? How many for Australia? Assistance to holders Emergency spillage procedures	Period of operation? Who to run? Public reporting? Transport? Liability? Licensing
Transport	Transport from holder to collection point or vice versa, and associated risks Need for tracking, for example, interstate and intrastate movements Role of Australian Dangerous Goods Code? Tracking between the collection point, consolidation store and the destruction facility.
Destruction	Availability of facilities Types of waste to be dealt with: OCPs Mixed OCP and arsenic wastes Mixed OCP and other pesticide wastes Other pesticide wastes Other hazardous chemical wastes Other unknown hazardous wastes Export of portion of waste stream collected? 11 Landfilling of encapsulated arsenic wastes?
Public accountability and reporting	How best to establish and keep public trust.

Given that schedule X OCPs will thus be a major focus of any national collection scheme, this discussion paper draws on issues raised by the OCP Management Plan.

3. Some Coordination Options for Making it Happen

The issues of designing and running a collection scheme and who should take responsibility for such, are complex. Resolution of these issues will require cooperation and coordination between various parties, including:

• those holding unwanted chemicals;
• different industry bodies;
• different spheres of government; and
• other interested parties.

Without prejudicing or pre-empting how this might be achieved, this paper considers three possible coordination options.

• First, the responsibility for developing a national collection program could be left to individual governments which would, in effect, continue the present arrangements. This may not meet the goal of achieving national action on this issue which would be needed if Australia is to demonstrate that it has a national approach to the management of these chemicals.
• Second, a national chemical collection program could be implemented at the State/Territory government level under an agreed national policy framework. Jurisdictional action could be co ordinated, for example, through ANZECC/ARMCANZ.
• Third, clear responsibility could be given to a coordinating body to plan and run a national collection program. This body would be required to achieve outcomes specified by government and a possible relational arrangement of the various parties under this option is indicated in Appendix B.

Under the third option, the coordinating body could be responsible for designing the detailed operational aspects of a collection scheme such as:

• co-ordinating the national scheme across different regions;
• designing collection programs suitable for the different regions;
• taking responsibility for and possibly sub-contracting out the tasks of collecting, storing, transporting and destroying the collected wastes;
• taking responsibility for reporting to government on outcomes achieved; and
• facilitating research and development of treatment technologies.

Likely community expectations for which the coordinating body could also be accountable are also listed in Appendix B.

In considering the possible role of a coordinating body, a range of issues would need to be resolved:

• how should a coordinating body be established and who will be part of the body?
• to what extent should the government be involved? and
• what mechanisms are required to ensure that performance indicators are met and outcomes achieved?

4. Operational Aspects of Managing Unwanted Farm and Household Chemicals

Operational issues that will need to be considered if Australia is to successfully address the issue of unwanted farm and household chemicals will now be outlined. Figure 2 is a diagrammatic representation of these operational issues. It is by no means an exhaustive examination and the contribution of new issues and possible solutions by workshop participants is encouraged by the Steering Committee. The section concludes with a discussion of the major impediments to the successful management of unwanted farm and household chemicals.

4.1 Safe On-Site Storage

Irrespective of whether a national collection scheme proceeds, and up to the time unwanted pesticides are collected, safe on-site storage of unwanted farm and household chemicals needs to be encouraged. This is important for environmental, health and international trade reasons. It would be helpful if the chemicals are readily identifiable and safe to handle at the time of collection. This should reduce the costs of consolidation and maximise the opportunities of destroying the wastes safely and effectively.

A guidance document on the safe on-site storage of unwanted farm and household chemicals is now being developed by the NCSDS Steering Committee, drawing on advice published by government and non-government organisations. The document is expected to draw on principles presented in the draft National Strategy for Agricultural and Veterinary Chemicals.

Figure 2: Operational aspects of a collection program

This guidance document will cover the following topics or principles for good management of chemicals:

• Safely storing the pesticides, for example, keeping the pesticides out of the reach of children, keeping them in a dry environment and away from watercourses or produce feedstock;
• Identifying the pesticide product or active ingredient from the label on the container;
• Maintaining, where possible, legible labels and information that will allow the pesticide to be identified (Chemicals with missing or illegible labels will not be excluded from collection);
• Providing information to holders about how the chemicals should be handled, for example, through material safety data sheets (MSDS);
• Ensuring that the pesticides are safely packaged including enclosing pesticides in unsafe containers in a larger, safer outer package;
• Keeping the containers of OCPs separated from other chemicals;
• Dealing with spills; and
• Dealing with emergencies.

4.2 Models for Collection

4.2.1 Issue 1: Ownership of Waste

The issue of ownership of the chemical waste is complex. At present, the holder is clearly the owner of the waste and has a duty of care to ensure that the waste is safely managed and handled. As the waste is collected, consolidated, transported and finally destroyed or treated, the ownership of the waste will be transferred. During each stage of a collection scheme, various participants will need to have a clear understanding of responsibilities and liabilities.

Ownership may be assigned to:

• the initial holder
• subsequent holders, like
  • collection point operator
  • the consolidator
  • transporter
  • owner of destruction facilities
  • landfill manager or exporter (if the waste is immobilised and landfilled or exported for destruction in an overseas facility)
• the coordinating body if different to the above holders.

In the case where a company storing, transporting or destroying chemical waste becomes insolvent, and this is a real possibility given previous experience, reassigning ownership will be necessary. Ownership could remain with the coordinating body from the point of collection through to destruction or disposal or be assigned to other individual participants in the collection program.

Several mechanisms exist for dealing with the liability issue, including:

• Participants in the collection program could pay a premium to an insurance firm.
• A fund could be created into which those handling the materials would pay a fee. If anything goes wrong, the fund could then be used to remediate any damage. In a sense this is similar to insurance as both would require up-front payment of a premium.
• Participants in the collection program entering into a bond agreement, which is similar to a bank guarantee.
• Third parties seeking legal redress through the courts, although this could be seen as time consuming, particularly in the case of an emergency.

Despite these potential sources of funds, liability for the waste is an issue that will need to be dealt with.

4.2.2 Issue 2: Previous Experience

A number of case studies of well established chemicals collection programs (presented in more detail at Appendix C) are summarised in Figure 3. They are presented to highlight some of the ways in which collection programs have been conducted. The national 1987 OCP recall, conducted in a number of States/Territories, is not summarised, but is described in detail in Appendix C.

Figure 3: Summary of selected chemical collection programs

COMPONENT	CASE STUDY 1 Queensland	CASE STUDY 2 Western Australia	CASE STUDY 3 - Victoria 1	CASE STUDY 4 - Victoria 2	CASE STUDY 5 - Hunter Water Corporation	CASE STUDY 6 - Sydney Water Board	CASE STUDY 7 - South Australia
No. of collection programs	Demand driven - continuous	2 finite programs	Regular	3 finite programs	Demand driven - continuous	Annual - continuously	2 finite and 1 regular programs
Material targeted	Household chemicals	Household chemicals	Household chemicals	Farm chemicals including OCPs	Household chemicals	Household chemicals	Farm and household chemicals
Collection program period	At least since 1992	1990 and 1991	Two periods 1987-94 and 1995-	1989-1992	1989 to present (on-going)	1989 to present	Finite rural programs in 1992 and 1995 Regular metro program 1990-
Period of individual collections	Demand driven	1 day	1 day	1-3 day stays	Demand driven	Weekend	1 week but dependent on size of region
Quantity collected	Not indicated	1990 - 2.5 tonnes	498 tonnes	455 tonnes	123 tonnes	257 tonnes - incl. 15 tonnes of OCPs	50 tonnes
Type of collection	House to house	Point	Point	Point	House to house	Suburb to suburb	Point and regional
Collection area	Metropolitan	Metropolitan	Metropolitan	Rural at N-central, NE, Gippsland and SW Vic	Hunter water catchment	Sydney suburbs	Rural at Lower SE and Riverland Metropolitan
Towns visited	Brisbane region	Not indicated	47	47	Newcastle region	Sydney suburbs	Two regions of SA with at least 5 major centres.
Cost per tonne of waste collected	Not indicated	Not indicated	$4,210.00	$3,250.00	Not determined	Not determined	Not determined
Advertising	Not indicated	Through local councils	Through local councils	Local paper, regional ABC radio, letterbox drops, posters	Consumer driven	Not indicated	Local paper, regional ABC radio, letterbox drops, posters

4.2.3 Issue 3: Possible Options for a Scheme

Based on these case studies, a series of possible options for unwanted farm and household chemical collections are canvassed below. Apart from Option 1, which addresses not having a NCSDS, Options 2 to 4 focus on a range of capacities for ongoing collections; that is, Option 2 is a one-off collection and Option 4 looks at indefinite ongoing chemical collections.

In considering any of the options, a range of questions need to be asked including:

• for the target region, what would be the most cost-effective type of collection program, for example, should it be run over a finite, semi-continuous or continuous period?
• how many collections are required during those periods?
• over what period of time should any collection program last?
• what criteria should be used to decide the collection regions or collection point locations?
• should the criteria for location include excisting collection sites, agricultural and veterinary chemical use patterns, and high population centres?
• how to best integrate the roles of industry, governments and other stakeholders in developing a scheme to return chemicals appropriately?
• will the timing of chemical collections, consider farming and householder practices, ie. what time of year (harvest season), what days of the week (market day) and what hours of operation?

Also, consideration needs to be given to collections from other holders of unwanted chemicals such as pest control operators, government agencies (such as primary industry, defence and transport), pesticide manufacturers, suppliers and retailers, water authorities and research organisations such as CSIRO.

Option 1: Do not conduct a NCSDS.

Governments, industry and chemical holders may consider that action over unwanted farm and household chemicals should be restricted to safe on-site storage of the chemicals. This would require a judgment that leaving the chemicals in their current location poses little threat to international trade, the environment or public health and would avoid the potential multi-million dollar cost of conducting a NCSDS.

The current holder of the chemicals would still have the option of paying for off-site storage and disposal. The costs of storage and disposal have tended to discourage this practice.

Advantages

• There would be no need to take co ordinated action or for government or industry funding.
• This approach supports the implementation of the 'polluter pays' principle and may encourage the holder to adopt a more responsible approach to future chemicals purchasing.

Disadvantages

• There would be on-going repackaging costs to farmers and householders and some holders may decide not to bear these costs and even dispose of the wastes illegally.
• Waste holders not removing unwanted organochlorine pesticides from farms could threaten the trade of those that do remove and destroy organochlorine pesticides. Without concerted national action, the Australian community cannot be assured that potential risks to human health, the environment and trade, has been minimised.
• There would be a need to regularly assess potential threats of not conducting a collection program.

Option 2: A one-off nationally co ordinated collection program

A one-off collection program could involve visiting regional locations once to collect surrendered unwanted farm and household chemicals and transporting those wastes to a designated storage area. No infrastructure, brought in for collections, would remain for ongoing receipt of unwanted chemicals.

A one-off collection would not necessarily involve simultaneous collections across the country, but more likely at different times across the country targeted to regional preferences.

Success will depend on promotion and education and, given previous State/Territory experiences, a failure to collect all or at least the majority of unwanted farm and household chemicals could place additional costs on the program and undermine the objective of removing most, if not all, unwanted farm and household chemicals by a certain date.

Advantages

• A one-off collection program may not require extensive coordination and infrastructure.
• This option is probably the easiest to cost because of its 'once only' nature.
• A 'one-off' program may send a clear message to the community and to industry that ongoing chemical use needs careful management because there will be no future collections.
• Depending on the type and proportion of unwanted chemicals collected, this option will assist in reducing the risk to public health, the environment and trade.

Disadvantages

• There is a strong likelihood, based on State experiences, that a one-off program will not collect all the chemical waste.
• Such an option may give the community no future outlet for chemical wastes produced in future and may result in improper disposal.
• There are likely to be long term storage costs and risks.

Option 3: A one-off nationally co ordinated collection program with limited opportunity for follow-up collections.

This third option would build on option 2 and could involve a one-off collection program featuring one collection for a region, augmented by a follow-up collection during the next 18 months or so.

Advantages

• This option should collect more unwanted farm and household chemical waste than Option 2.
• Like Option 2, a collection program with limited follow-up collections is still a finite process, thereby making cost estimation easier.
• A collection program with limited follow-up collections may not require continuing extensive coordination.
• This option has the potential to significantly reduce the risk to public health, the environment and trade.

Disadvantages

• Although, this option is likely to collect more unwanted chemicals than Option 2, it may not collect sufficient quantities of target wastes to reduce risks to health, environment and trade to acceptable levels.
• Like Option 2, this option does not recognise the need for ongoing collections as supported by those experiences detailed in Appendix B.
• This option may require more resources and funding to undertake and will be more difficult to cost because of the follow-up, though limited, collections.
• There are likely to be long term storage costs and risks.

Option 4: A one-off nationally co ordinated collection program followed by a mechanism for ongoing collection.

This option focuses on providing ongoing capacity for collections rather than the temporary nature of the previous options for a NCSDS. The scope of any on-going collection program would depend primarily on desired outcomes, available funding and the nature of the community being served. Ongoing collections of wastes could include a chemical drop-off point, staffed on an ongoing basis.

Establishing chemical collection points with the capacity for ongoing collections may require facilities staffed on a part or full-time basis to allow the community to surrender unwanted farm and household chemicals at their convenience. The advice of local communities on whether ongoing chemical collections were desirable would be an important consideration; ongoing collections for a limited period may be more suitable to some communities.

Of the three NCSDS options, this option is most likely to require the establishment of an ongoing coordinating body to develop the required infrastructure, coordinate ongoing collections and oversee the other operational aspects of a NCSDS which include, handling, storage, consolidation, transport and destruction.

Advantages

• This option would give greater assurance to government, industry and the community that unwanted chemicals and their potential risks are removed from farms and households.
• The community would have a facility at which it would be able to surrender unwanted chemicals of any kind on an on-going basis, thus greatly reducing any incentive for improper disposal and misuse.
• This option will assist in minimising the risk to public health, the environment and livestock health.

Disadvantages

• A chemical collection point with an ongoing capacity for collections would be resource intensive.
• There would be an ongoing need for appropriately trained personnel at each site to operate the chemical collection program.
• There is a potential for local community resistance to and concern over an on-going reception facility being located their neighbourhood.
• There does not appear to be an incentive to minimise future generation of unwanted chemicals.
• There are likely to be long term storage costs and risks.

4.2.4 Issue 4: Promotion Education

Experience shows that the success of any collection program is heavily dependent on its promotion in the wider community. In turn, effective promotion depends on potential hindrances being addressed early in the planning of any collection program like putting in place effective communication strategies.

The case studies illustrate some of the different ways in which messages can be conveyed and people motivated to participate. Strategies include promotional activities through:

• Farm chemical points of sale;
• Agricultural training courses;
• Pamphlets;
• Leaflets sent out with Council rates notices;
• Council bulletin boards;
• Landcare and other similar organisations;
• Newspapers;
• Radio, including through ABC and commercial station community service announcements;
• Electronic means such as the Internet;
• Posters at shopping centres and public bars; and
• Intergovernment and interagency cooperation and information sharing.

The merits and costs of these and other promotional strategies need to be considered. Workshop participants may wish to consider the need for tailoring promotional and educational activities to the target area or region to maximise participation rates.

4.3 Collection Points and Consolidation Stores

The draft final OCP management plan introduces the concept of consolidation stores to handle and consolidate OCP waste. The OCP waste would be brought to the consolidation stores from collection points, most of these being of a temporary nature. The functions of a consolidation store could include handling, identification, analysis if required, packaging and storage of unwanted farm and household chemicals once they have been handed in or collected.

The following questions and issues are among those that would need to be considered:

• the location of collection points and consolidation stores (for example as part of totally new or excisting facilities);
• how many collection points and consolidation stores would be required?
• what liability issues are associated with the handling of chemical wastes from point of collection to consolidation stores?
• would the consolidation stores be required for long or short term storage?
• how would collection points and consolidation stores be managed and resourced, particularly given that there will be collection peaks and troughs?
• hazardous material emergency spillage plans;
• possible community concern over the location of consolidation stores;
• what should the inventory of collected chemicals held by the consolidation store cover and how should this inventory be maintained?
• what issues are associated with chemical waste identification and segregation during consolidation?
• is the level and detail of public reporting outlined in Section 4.6 adequate? Note this is based on the present draft of the OCP management plan; and
• what consolidation infrastructure is required, for example, how many stores for a region (which may be a grouping of States or Territories) or for Australia? What storage capacity will be needed and what regulatory requirements should stores be subject to, for example, dangerous goods, environment protection and occupational health and safety controls.

4.3.1 Handling (including identification of chemical wastes)

The following questions and issues are among those that would need to be considered:

• identification of chemicals;
• chemical analysis requirements;
• requirements for handling broken or damaged chemical containers;
• who will train and/or provide trained personnel to identify, segregate and consolidate collected chemical wastes; and
• training needs to meet regulatory requirements for dangerous goods, environment protection and occupational health and safety.

One of the objectives of initial identification and segregation is to reduce the later need for chemical identification and analyses. Based on past experience, chemical identification and/or analysis of the material likely to be collected is a particularly expensive component of the process.

The cost of identification and analyses could be significantly reduced by ensuring, that during collection, unlabelled or poorly labelled containers are identified, where possible, by the person surrendering the chemicals and, during repackaging, only like farm and household chemicals are combined.

4.3.2 Storage

Previous experience shows that the cost of storage and redrumming of collected waste can be a major component of the overall cost of a collection scheme. Strong concerns have also been raised by State/Territory government agencies on the cost of handling and re-handling collected and stored unwanted chemicals that are awaiting destruction or treatment. Storage costs will depend on the availability of adequate destruction facilities. If none are available long-term chemical waste storage, and its associated high cost, may be required.

The following questions and issues are among those that would need to be considered:

• costs of storage in the short and long term, particularly if viable destruction technologies are unavailable;
• likely consolidation storage capacity required for a national collection program ;
• scope for using excisting commercial or government facilities; and
• providing for and dealing with the responsibilities associated with long-term storage of some chemical wastes where destruction facilities may not be available, for example, arsenicals.

4.4 Transport

The issue of transport will be strongly influenced by how the collection, handling and storage components of a NCSDS are to be managed.

Farmers and householders may possess containers that are in a poor condition. For example, the containers may be rusting, they may have lost their lids or caps and their labels may have fallen off or become illegible. This all adds to the risk associated with transporting the waste from the farm or home to the collection point. Ways of minimising these risk need to be discussed and factored into any national chemical collection scheme.

A key issue for many regions of Australia, and one that could well have an adverse impact on the effectiveness of any collection program is the distance that waste holders would need to travel to a collection point. For some areas, this is likely to be considerable.

After being collected, the chemical waste will then need to be transported to the consolidation stores and then on to the destruction facility. Consequently, there are two components of transport which should be addressed. These are:

• the transport of chemical waste from its current holding place, whether that be a farm or household, to the designated collection point - this is likely to be undertaken by a diverse group of people who presently hold the waste; and
• the transport of collected chemical waste from the collection point to consolidation store and/or treatment/destruction - this is likely to be undertaken by specialist transport firms.

The following questions and issues are among those that would need to be considered:

• what transport guidance needs to be provided to farmers and householders before they transport their chemical wastes to collection points?
• the occupational health and safety risks to the farmer or householder during the transport of their chemical wastes to collection points;
• tracking requirements for interstate and intrastate transport of hazardous waste;
• requirements to be met under the Australian Dangerous Goods Code or enabling legislation; and
• public accessibility to information regarding the transport of the collected wastes.

The National Manifest System for the Transport of Hazardous Wastes could play an important regulatory role in tracking interstate movements of the collected waste and in providing to governments and the community with an assurance that the waste is moved from the consolidation facility to the destruction or treatment facility. This ability could be aided by a National Environment Protection Measure which is currently being developed for the transport of wastes across State/Territory borders.

4.5 Management of Consolidated Wastes

As discussed in Section 2 (Scope of the unwanted chemicals issue), even though targeting hazardous unwanted farm and household chemicals, a NCSDS is likely to result in the collection of a range of chemicals.

Given this scenario, it will be important that any national chemical collection program have available options for managing the range of wastes collected. These could include recycling, reuse, chemical and/or physical treatment, fixation in concrete and disposal to controlled landfill. Government agencies have indicated that, with the exception of some types of scheduled waste, there appear to be an adequate range of outlets for most categories of chemical wastes likely to be collected.

Scheduled wastes is one group for which particular attention has been given to establishment of appropriate and suitable means of destruction and this issue is discussed in more detail below.

Scheduled waste

There are currently three known commercial-scale scheduled waste treatment/destruction facilities in Australia.

These are:

• BCD Technologies in Brisbane, Queensland - this company uses the base-catalysed dechlorination technology;
• Ecologic in Kwinana, Western Australia - this company uses a hydrogenation-based technology; and
• HazWaste Services in Dandenong, Victoria, this company also uses the base-catalysed dechlorination technology.

Of the three operational facilities in Australia, the Ecologic plant in WA has demonstrated a capability for treating known OCP wastes, including those wastes collected in Western Australia through the 1987 OCP recall. In 1995/96, the facility treated 40 tonnes of organochlorine pesticides¹². The Brisbane BCD facility has received regulatory approval to treat a range of organochlorine pesticides but has treated only limited OCPs commercially. In addition, BCD is currently constructing a new facility which is to incorporate a Plascon plant, with initial use for concentrated PCBs and subsequently for OCPs.

Experience indicates that Australia may have the capability to treat the known non-organochlorine pesticide wastes such as organophosphate pesticides, and other hazardous chemicals and that it has limited capacity to treat the known organochlorine pesticides. However, it is clear that we would not have the capability, without further development, to treat arsenic and mixed pesticide/ arsenic wastes or the unknown wastes that may be collected.

Moreover, those responsible for implementing the National Strategy for the Management of Scheduled Wastes are now questioning if our current capacity to treat polychlorinated biphenyl (PCB) wastes within a reasonable time is adequate. Adding OCPs to the backlog of PCB wastes awaiting treatment, would extend the delay before those wastes are destroyed. Therefore, there are two destruction issues that need to be tackled in developing any national collection program: capability and capacity.

Research and Development

There needs to be a strong focus on research and development for the treatment of arsenicals and other difficult to treat waste. Experience demonstrates that the treatment/disposal of arsenic-based pesticides appears to be causing the most problems in finding a suitable treatment technology. Destruction costs will be an important component of overall cost of any collection program and these will be difficult to estimate where treatment technologies are currently unavailable for some chemical waste types. This uncertainty may delay the commencement of a NCSDS.

The storage cost estimates will need to take into account that companies, which might be interested in developing suitable technologies, may defer research and development until a sufficiently large market is guaranteed by having a "critical mass" of farm and household chemicals in storage and ready for destruction. Thus, delaying a collection program in the expectation that technologies would be developed may not reduce the storage costs involved.

Given concerns for the lack of appropriate treatment technologies for some chemical waste streams, government involvement in promoting research and development to establish new waste treatment technologies may be required.

Export

In 1993, the Commonwealth Environment Minister adopted a policy that permits for the export of scheduled waste would not be issued while technologies for its destruction in Australia were being developed. In 1996, amendments to the Hazardous Waste Act 1996, were passed under which exports of hazardous wastes for final disposal may only be permitted in exceptional circumstances. For example, export may be permitted when keeping the wastes in Australia presents an unacceptable risk to human health or the environment, and in addition, suitable and environmentally sound overseas destruction facilities must be willing to accept the waste for treatment.

Because of present and likely future limitations on the capability and capacity of Australia's treatment facilities, further consideration may need to be given to exporting part of the collected waste for treatment in overseas facilities. However for this to happen, significant socio-political difficulties would need to be addressed and any export would, of course, need to be done in accordance with the amended Hazardous Waste Act.

Some Issues for Discussion

The following questions and issues would need to be considered:

• does Australia have adequate capacity and capability for managing the range of hazardous chemicals that may be collected?
• should priority be given to recycling and/or reuse options for certain collected chemical categories?
• how to increase Australia's capacity to treat wastes?
• how to improve Australia's capability to treat mixed OCP/arsenical and the unknown wastes that are likely to be collected?
• should Australia consider the use of a mobile waste destruction unit to treat collected wastes?
• should Australia consider exporting certain types of collected chemical wastes that cannot be treated/destroyed in Australia?
• is controlled landfill disposal of treated and fixed, arsenical components of the collected waste an acceptable solution?
• what treatment/destruction information should the public be given access to and in what form should this be?

4.6 Public Reporting and Accountability

ANZECC's scheduled waste strategy is founded on the principles of openness, fairness and equity and the safe management of OCPs is an integral part of that strategy. The development of trust between all interested parties during the process to develop scheduled waste management plans has been nurtured by openness and easily comprehensible information and processes. The Steering Committee believes these principles should be extended to any collection program that may be developed to remove unwanted farm and household chemicals.

In this discussion paper, the option of a coordinating body has been suggested to provide the focus for the operational aspects of any collection scheme. The accountability of such a Coordinating Body to governments and the community, and the public accessibility to information, are considered to be essential features of any collection and destruction program.

Public reporting

It is considered desirable that the community have full access to information to ensure that trust is developed and maintained. Among the parties involved, communities should have ready access to information on inventories of collected chemical, and on treated/ destroyed/ export/ recycled chemicals, to be confident that chemical wastes are being managed appropriately. The requirements for public reporting should be consistent with those specified in the draft OCP management plan.

The following components of a collection and destruction program would need to include clear public reporting of information related to:

• waste material received at and forwarded on from collection points
• waste material received at, stored in and forwarded on from consolidation stores
• waste transported between any of the following sectors:
  • collection points to consolidation points
  • consolidation points to destruction facilities
  • consolidation points to export facilities
  • consolidation points to any secure landfills, for example, for encapsulated arsenical waste.
• Waste received and destroyed at destruction facilities
• Environmental and health performance of destruction facilities.

Public accountability

Any coordinating body would need to be accountable to governments through a number of processes which may include contractual requirements to develop corporate, strategic plans and annual reports. They would also need to comply with regulatory requirement in terms of relevant occupational health and safety, dangerous goods, environment protection, public health, and export control legislation.

5. Future Management of Agricultural and Veterinary Chemicals

In considering the future management of agricultural and veterinary chemicals, and consistent with the objectives of the National Strategy for Agricultural and Veterinary Chemicals, the following questions would need to be asked:

• What strategies are needed to prevent or minimise the generation of future unwanted chemicals?
• What strategies are needed to manage future unwanted pesticide holdings that may be generated, for example, as a result of deregistration, date-expired products or severe restrictions on use?
• The effect of providing ongoing facilities for unwanted chemical disposal on the incentives for general waste minimisation; and
• What strategies for the management of future unwanted chemicals should be put in place?

6. Conclusions

This discussion paper attempts to convey the nature of issues that need to be resolved in developing a national scheme for managing unwanted farm and household chemicals.

The national workshops being run by the National Advisory Body on scheduled wastes in July and August of 1997 provide an ideal opportunity to bring forward new and creative ways for addressing these issues.

The options in this Discussion Paper provided, while based on previous experience, may or may not be appropriate to the vastly different regions across Australia. The workshops will provide an opportunity to help identify the best options to put to governments, so that the most cost-effective options are implemented for Australia, taking into account regional differences.

Appendix A: National Collection Storage And Destruction Scheme Steering Committee Membership

Jurisdiction	Nominee	Agency type
ACT	Peter McDowall	Environment/ Agriculture
Commonwealth	Ray Jeffery	agriculture
New South Wales	Mark Gorta	Environment
Northern Territory	Brett Struck	Environment
Queensland	Gary O'Connor	Environment
South Australia	Geoff Sclare	Environment
Tasmania	Patrick Deprez	Environment
Victoria	John Hogan	Environment
Western Australia	Peter Rutherford	Agriculture

Appendix B: Possible Institutional Relationship between a Coordinating Body and other National Chemicals Collection Scheme Players

Figure 4 illustrates a possible relationship between a coordinating body, governments and each part of the collection process. It is envisaged that a coordinating body would be responsible for administering a collection scheme and ensuring that the collection, storage and destruction actually occurs, but it would not necessarily perform all of the tasks.

A coordinating body could sub-contract components, components or parts of the components in a competitive manner and thereby avoid a private monopoly. If there is no effective commercial option for a coordinating body to utilise, eg. destruction, then a coordinating body could look at performing this role. It is important that a coordinating body, whilst operating in a commercial field, does not have an unfair advantage arising from its being the result of a government-created monopoly (refer to the Hilmer Committee Report on National Competition Policy).

Figure 4: Possible relationship between governments, a coordinating body and a national chemicals collection scheme.

Community expectations for a NCSDS

In setting performance goals for a NCSDS body, a range of issues will need to be considered, including:

1. the quantity of chemical waste required to be collected and destroyed, for the NCSDS to be considered a success;
2. the time with which the destruction of collected wastes or components of the collected waste should occur;
3. how to judge if Australia is maximising the opportunities to destroy all collected wastes
4. within its own borders, including the difficult-to-treat mixed OCP/arsenic wastes.
5. the use of performance measures such as "no detection of organochlorine residues in Australian primary produce exports within X years of the start of the collection program"?
6. similarly, should performance goals include the criteria relating to chemical residues in humans, animals, plants, water and soil?
7. the mechanisms required to ensure that governments can audit and monitor the operations of a coordinating body through contractual arrangements and State/Territory statutes?

Appendix C: Chemical Collection Program Case Studies

Case Study 1: 1987 OCP Recall

The last national chemical collection scheme was the Commonwealth-funded collection of organochlorine pesticides (OCPs). This took place in 1987 in response to the detection by USA of contamination of exported beef and gave expression to the desire to retain the good image of Australia's agricultural industries.

All States/Territories of Australia restricted or prohibited the use of most organochlorine pesticides particularly DDT.

Victoria

In Victoria all uses of DDT were prohibited in June 1987 and to avoid farmers using up their excisting stocks of DDT, a buy-back program was instigated by the Department of Agriculture and Rural Affairs. This buy-back period lasted three months from June to September 1987. During this period 85 kilolitres of liquid and approximately 5 tonnes of powdered DDT was brought in for disposal. A further 20 tonnes of DDT was handed in over the next year.

In May 1988, the Melbourne and Metropolitan Board of Works, as the Victoria's Industrial Waste Disposal Authority, arranged for the collection and disposal of this DDT, via export to Rechem International Pontypool South Wales, by high temperature incineration. At the completion of export process, approximately 115 tonnes of DDT had been collected.

Queensland

The Queensland Government enacted legislation prohibiting the use of certain organochlorine pesticides in agriculture in mid 1987. The Queensland Rural Pesticide Recall Program commenced on 8 October 1987 with a Ministerial direction to all local Authorities, Government members and Department of Primary Industry officers setting out the details of the program and advertisements placed in the rural media. During the following six months to April 1998, 180 tonnes of OCPs were collected.

The OCP waste was disposed of by high temperature incineration at Rechem International.

During this recall, 16 tonnes of arsenic waste was collected, of which 11 tonnes was sent to May and Baker, United Kingdom and 5 tonnes to Rhone Poulenc. The latter was returned and remains stored in Queensland.

Western Australia

The Western Australian Government enacted legislation in mid 1987 to prohibit the agricultural use of organochlorine pesticides. Subsequent to this, the Department of Agriculture conducted two pesticide recall programs where 180 tonnes of OCPs and 20 tonnes of arsenic waste were collected. To date a further 20-30 tonnes of OCPs and arsenicals have been surrendered.

Unlike the eastern states who exported their OCP waste for high temperature incineration, Western Australia placed their material into storage awaiting the establishment of a suitable local treatment facility. EcoLogic have been contracted to treat this stored OCP waste at their Kwinana site. The arsenic waste has been encapsulated in concrete and placed in the secure landfill site at Mt Walton.

The Department of Agriculture has provided the following approximate costs to collect and store the above material: administration ($137,000), transport ($28,500), buy-back of chemicals ($342,000), consolidation storage ($37,500), initial waste handling and maintenance ($110,000), redrumming and further handling ($165,000), totalling $820,000.

Case Study 2: Queensland

Household Chemicals Collection Programs

The Brisbane City Council (BCC) have been collecting small quantities of unwanted household chemicals at their transfer stations for some years, most of which is taken by local waste disposal contractors or deposited in their landfill sites. Currently, BCC collects waste from residents on request, although this has an expensive exercise. BCC are now considering running collections on a suburb by suburb basis at some stage in the future.

The Department of Environment and Heritage indicated that several municipalities have also run household chemical collections, usually as an annual event, and include Maroochy Shire , Beaudesert Shire and Gold Coast City. The quantities collected were not provided but are known to be relatively small.

Case Study 3: Metropolitan Western Australia

Two Household Hazardous Waste collection days were held in 1990 and 1991 in Western Australia, organised by the Western Australian Municipal Association.

The 1990 collection, which involved opening 25 collection sites for one day, resulted in 2.5 tonnes of chemical waste being collected.

In the absence of further organised Household Hazardous Waste Collection days, several Councils established collection services, which include a 'drop-off' point and storage shed at their respective transfer stations or landfill sites.

Western Suburbs (Perth) Environmental Health Officers Group held a Chemical Collection Day in 1996 where they collected approximately 40 kilograms of pesticides from 104 vehicles. A similar collection was held in 1995 where 35 people attended. This collection was advertised in the local paper and staffed by a chemist from the Waste Management Division of the Department of Environmental Protection and the Environmental Health Officers from the participating councils.

Cockburn City Council collects household chemical wastes at a storage shed at their landfill site. This initiative is promoted in the council's newsletter, through a pamphlet entitled "Removing Risky Rubbish" available in council offices and via council noticeboards. As a result of this collection program, 360 kg of pesticides have been collected.

Case Study 4. Metropolitan Victoria

After the 1987 OCP collection, two pilot chemical collections were conducted in 1987/88, followed by a series of regular collections that continued until the end of 1994 and resulted in 299 tonnes of material being handed in for disposal.

Concern over the cessation of these collections resulted in the formation of a Household Chemicals Working Group (HCWG), comprising representatives from the Environment Protection Authority, regional waste management groups, waste management associations, the Plastics and Chemicals Industry Association, the Australian Conservation Foundation and Melbourne Water. The HCWG commissioned a survey of 400 households throughout the metropolitan area, to explore the demand for a Household Chemicals Management Program. The survey found significant use of household chemicals with about 30 percent of households requiring a disposal service for at least one chemical product category out of 41 categories surveyed.

As a result of this report, the Waste Management Council, now EcoRecycle Victoria, conducts chemical collection days once a month. On average 250 people hand in chemicals, which total nearly 8 tonnes of material, on each collection day. A total of 189 tonnes of chemical wastes have been collected since 1995.

Case Study 5. Rural Victoria

As a result of the 1987 OCP collection, it was found that farmers had other unwanted chemicals they wished to dispose of. To address this problem, a pilot rural collection program was developed for the northern part of central Victoria. It involved visiting 9 towns to collect unwanted chemicals, resulted in the collection of over 55 tonnes of material, handed in by a total of 923 farmers.

The response in this pilot program resulted in a second collection program involving 25 towns in north-eastern Victoria where over 163 tonnes of material was handed in by 1798 farmers. A third rural collection covered 7 towns in the Gippsland area, and 6 towns in the South West portion of the state resulting in 824 farmers handing in 120 tonnes of chemicals for disposal.

The rural chemical collection program consisted of 1-3 day stays at the various towns. The collection team would set up and await delivery of unwanted chemicals by farmers and town residents. The community had been informed by way of advertising in various media before the collection team arrived at a particular town.

The EPA advertised the collections through postal dumps of brochures or flyers a few weeks before the collection day, advertisements in local papers running over three consecutive issues, utilising free time on ABC regional radio, placing posters around shopping areas and pubs, using the Department of Agriculture to provide lead articles to the local papers, and having the collections mentioned in the CFA fire reports. The Environment Protection Authority (EPA) found the most effective media for advertising the rural collection were the local paper and regional radio such as the ABC.

Case Study 6. NSW - Hunter Water Corporation

In 1989, and due to concern with the disposal of pesticides and other chemicals to its sewers, the Hunter Water Corporation (HWC) commenced a free chemical collection service. This service continues to collect from small industrial premises on a fee for service basis.

HWC has opted for a pick-up service of chemicals from the householder, in preference to holding chemical collection days or providing a drop off point. Householders with unwanted chemicals contact HWC and request the chemical pick-up service. Householders are required to provide information on the type and quantities of chemicals and their contact details. HWC schedules a chemical collection for a particular area when there are sufficient householders requiring the pick-up service to ensure that the program remains cost effective. HWC has found that the householders are prepared to wait until the collection service is undertaken in their area.

Once collected, the chemicals are transported to a licensed HWC storage facility located at Shortland Wastewater Treatment Plant. The storage facility has an EPA licence. The storage facility acts as a temporary transfer depot where, after a period of six months, a contractor is employed by HWC to transfer the chemical waste to appropriate treatment/disposal facilities.

HWC can refuse to collect some chemicals in certain circumstances, if this material causes a breach of its EPA licence, or if it is hazardous to transport. The decision as to whether to accept or refuse chemicals is solely at the discretion of HWC. Some of the chemicals that may be refused include leaking chlorine containers, diesel fuel with fertiliser, and mixed chemicals.

The program has been running since 1989 and has resulted in the collection of 123 tonnes of unwanted chemicals. Of this total, approximately 20.5 tonnes were herbicides and pesticides.

Hunter Water Corporation has indicated that it will continue to undertake the chemical collection program as a service to its customers.

Case Study 7. Sydney Water Board

Sydney Water Board commenced conducting Household Chemical Collections in 1989, as part of their campaign to improve the quality of their sewer discharge.

Collections are conducted continuously, usually on weekends, and operate out of transfer stations and landfill sites. The collection team has a caravan, other vehicles and equipment that are moved from site to site.

The total quantity of household chemicals collected over the period from July 1990 to December 1996 was 257 tonnes and comprises 15 tonnes of organochlorine pesticides, 1.2 tonnes of chlorinated Solvents, 10 tonnes of heavy metal pesticides, 11 tonnes of other pesticides and 219 tonnes of other material.

Sydney Water dispose of most of the material, that cannot be recycled or accepted at local landfill sites, through a local specialist disposal company, who have arranged the storage of OCPs and arsenicals at the Commonwealth Storage site, Oaklands NSW.

Case Study 8. South Australia

The Environment Protection Authority in South Australia (SAEPA) has undertaken the responsibility of managing the chemical collections program. The program was commenced due to public requests and the need to minimise chemical discharges to sewer and the environment. In 1992, a major collection was held in the Lower South East followed in 1995 with a similar collection in the Riverland.

In 1990 the SAEPA opened a chemical collection facility at Dry Creek , near Adelaide. The facility opens the first Tuesday of every month and enables householders and farmers to bring along their unwanted chemicals and leave them at the depot. This is a free service to the householder and farmers. No chemicals are accepted from industry or government agencies.

Between 1990 and 1995 five suburban collections were held around Adelaide. Apart from these collections, no other programs have been conducted. At present the Dry Creek drop off point is the only chemical collection program being undertaken by the SAEPA.

The collection day at Dry Creek has been advertised so people are aware of the day on which they are able to drop off their chemicals.

Some special arrangements are made for rural residents that are some distance away from the depot. These arrangements include opening up the depot on other occasions to receive the load, or actually arranging to have the chemicals collected.

There has been a total of approximately 50 tonnes of chemicals collected. Of these approximately 15 tonne represent pesticides. The SAEPA have not scheduled any further collections for South Australia. It will however continue to operate the Dry Creek facility for households and farmers.

Case Study 9. Tasmania

The Northern Midlands Council, which comprises mainly farming communities, undertook a survey of all residents in their region to assess the extent of unwanted chemicals in the community.

Although the community response was poor, the Council believed that there were sufficient unwanted chemicals to warrant collection. Chemsal Pty Ltd was engaged to collect the 182kg of chemicals, comprising organochlorine, organophosphate, arsenical and other pesticides, from the 14 properties where farmers had indicated having unwanted chemicals.

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¹ Australian and New Zealand Environment and Conservation Council (ANZECC) consists of Commonwealth, State and Territory Environment Ministers.
² Agricultural and Resource Management Council of Australia and New Zealand (ARMCANZ) consists of Commonwealth, State and Territory Agriculture and Resource Ministers
³ Established by the Australian and New Zealand Environment and Conservation Council (ANZECC) in 1994.
⁴ Standing Committee for Agriculture and Resource Management (SCARM) consists of senior officials from Commonwealth, State and Territory agriculture departments.
⁵ Quinsey, P., Donohue, D., and Ahokas, J. (1995), Persistence of organochlorines in breast milk of women in Victoria, Australia, Fd. Chem. Toxic., v33, no1, pp49-56. & Thompson, G., Chapman, J. and Richardson, B. (1992), Disposal of Hazardous Wastes in Australia: Implications for Marine Pollution, Marine Pollution Bulletin, v25, 5-8, pp155-162.
⁶ A Special Report - The Australian Beef Industry, Weekend Australian, January 18-19, 1997, p 29.
⁷ The Australian, 21 November 1994.
⁸ This scheme was funded by the Commonwealth Government.
⁹ Agriculture Department representatives on the NCSDS Steering Committee.
¹⁰ Consolidation store is defined as a location to where materials are moved for medium-term storage prior to destruction. This definition is derived from the draft OCP Management Plan.
¹¹ Export of scheduled wastes is technically possible for those wastes that cannot be treated in Australia but significant socio-political difficulties would need to be overcome to make this happen. For example, in the past Australia exported PCBs to the UK for high temperature incineration but the UK has recently banned the import of wastes for incineration.
¹² Appropriate technologies for treatment of scheduled wastes (Environment Australia), Review Report Number 3, August 1996.