Safety issues
The plastic containers accepted by the ACRC for recycling, generally held commercial products that either control some pest, promote or control growth of a plant, or facilitate the action of any of the aforementioned products. Interestingly, the vast majority of high-density polyethylene HDPE containers subject to this program are filled with professional products that are essentially non-toxic or, of extremely low toxicity. For instance, most agricultural users are large consumers of a class of products known as adjuvants. Our collection sites are filled, at any given time, with about 35% or more containers that are better known as "stickers, spreaders (like detergent), vegetable oils" and other products that make the crop protection chemical work better. Of course, there are some pesticides that are toxic if humans are exposed at sufficient concentrations for biological effect, but surprisingly, the numbers where that concern is present is low, just a tiny fraction of the containers that are recycled through this program.
Still, the ACRC is concerned about any potential for harm to workers in a recycling facility, or to the consumer that may come into contact with the post-consumer product made from collected high-density polyethylene HDPE container. The ACRC has demonstrated to the entire industry that acceptable end-use products can be manufactured in a safe manner as long as certain safeguards and routinely recognized procedures are followed.
The procedures guaranteeing safe use start in the field, wherever the crop protection product container is emptied. Most crop protection products, even with standing liquid, will not trigger "hazardous waste" classification or regulation as defined by EPA. Despite this, the ACRC requires its granulation contractors to enforce a standard that is considerably more restrictive for cleanliness than either the regulations implementing the hazardous waste laws or those regulating pesticides. In fact, the ACRC publishes training videos and literature that prescribe a level of rinsing for containers as restrictive as the rinsing requirements proposed by the EPA office of pesticide programs on Feb.11, 1994, even though those standards have never been adopted. Eleven studies, summarized in an EPA Report to Congress indicate that over 99.99% of the pesticide residues are removed when our recommended practices, or even less stringent standards, are followed. Observers sometimes doubt this efficacy when stains or odors are detected in the granulate collected from the ACRC program. These false indications are often the result of plastic container exposure to certain intense coloring or odor producing agents, detectable by sight and smell at incredibly small fractions of a percentage point (part per hundred), actually at the part per billion level.
Ultimately, the ACRC has determined a high standard of assurance by utilizing the expertise of its own scientists and industrial hygienists who inspect potential manufacturing sites for safety and regulatory history prior to allowing this plastic to enter into the plant in question. The ACRC has monitored the extrusion process, sampled air from around the machinery, and analyzed the dermal absorption of workers who handle the chipped plastic or finished product. It has also taken these measurements made by a certified, independent laboratory and had these data reviewed by some of the foremost pesticide toxicologists in the US. The net result is that the ACRC has determined that it is unlikely that any harm could come to any worker or handler of plastic materials collected in this program, provided that each entity followed the contractual and specified procedures that the ACRC has promoted.
Through this entire process, neither the plastic containers, nor the plastic chips, nor the collection sites, nor the recyclers are owned, nor are they operated, by the ACRC. Each entity has a responsibility to assure that the conditions for safe handling are met at every level for final product safety to be assured. The ACRC has determined that if ACRC requirements are met, the risks are well within acceptable limits for workers exposed to the recovered plastic and for industrial consumers of the manufactured product. |
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