Disposal of Empty Pesticide Containers: A Shared Industry Responsibility
Forestry South Africa’s Timber Industry Pesticide Working Group
In South Africa, pesticide stewardship does not end once the product has been applied. The responsible disposal of empty pesticide containers, used for both agriculture and forestry, forms a critical part of legal compliance, environmental protection, worker safety, and certification requirements.
Despite clear legislation, established recycling collection systems, and readily available guidance, reports of non-compliance relating to pesticide container disposal continue to emerge. This is concerning because container management is one of the areas where compliance is both achievable and relatively straightforward when the correct systems are implemented.
This is why, as TIPWG (Timber Industry Pesticide Working Group) we would like to remind all pesticide users that proper disposal is not optional. It is a legal and environmental responsibility shared by every pesticide user, i.e., applicator, distributor, and manufacturer.
Why Proper Disposal Matters
Empty pesticide containers that are improperly handled can create significant environmental and human health risks. Residues left in containers may contaminate soil and water resources, expose workers and communities to hazardous chemical substances, and contribute to illegal re-use of containers for food, water, or household storage.
In addition to the environmental implications, poor container management can result in:
- Non-compliance with legislation
- Certification risks (including negative audit findings and non-compliance to FSC and PEFC/SAFAS requirements)
- Reputational damage
- Unsafe working conditions
South Africa’s Extended Producer Responsibility (EPR) regulations have further strengthened the importance of proper container management and recycling within the agricultural and forestry sectors. These regulations support structured recovery and recycling programmes for eligible pesticide containers.
It Is the User’s Responsibility, Not the Distributor’s
One of the most important misconceptions to address is the belief that pesticide distributors or suppliers are automatically responsible for collecting or disposing of empty pesticide containers. They are not. While some companies may have voluntary agreements or collection arrangements in place with suppliers or service providers, these are additional support mechanisms and not legal obligations placed on distributors.
The responsibility for the correct management, storage, preparation, and disposal of empty pesticide containers remains with the pesticide user or holder of the waste until it has been handed over to an approved collector or recycler. This means the forester, nursery manager, and/ or contractor responsible for pesticide usage must ensure that:
- Containers are correctly rinsed
- Containers are rendered unusable, i.e., punctured
- Containers are safely stored
- Containers are sent to approved recyclers or collection depots
- Appropriate records are maintained
Triple Rinsing Is Non-Negotiable
Before disposal or recycling, pesticide containers must be properly triple-rinsed immediately after emptying. Triple rinsing is essential because it:
- Removes residual pesticide from the container
- Reduces environmental contamination risks
- Allows the rinse water to be used as part of the spray mixture
- Ensures the container is deemed clean and safe for recycling
A correctly triple-rinsed container should contain negligible chemical residue. The general process includes:
- Empty the container completely into the spray tank.
- Fill the container approximately one-quarter full with clean water.
- Replace the lid and shake thoroughly.
- Pour the rinse water into the spray tank.
- Repeat this process three times.
Once triple rinsed, containers must be punctured or crushed to prevent re-use. Importantly, containers that have not been triple rinsed will not be accepted by certified recyclers.
Storage and Timely Recycling
After triple rinsing and puncturing, containers should be:
- Stored in a secure designated area
- Protected from rain and environmental exposure
- Kept away from incompatible materials
- Prevented from becoming a secondary contamination source
Containers should not accumulate on site. Recycling or collection should occur within a reasonable and timely period as part of an active waste management programme. Industry members must work with approved collection and recycling companies, including certified recyclers registered through CropLife South Africa container management programmes.
Useful resources include:
Record Keeping Is Essential
Container disposal records form an important part of both legal compliance and certification auditing requirements. Operations should maintain:
- Waste disposal registers
- Records of quantities disposed of
- Dates of collection or recycling
- Copies of recycler certificates, receipts, or collection confirmations
- Details of the approved recycler or collector used
These records help demonstrate due diligence and provide traceability during audits or inspections.
Fertiliser Bags and Containers: Current Position
It is important to note that, at present, fertiliser bags and containers are not included under the current pesticide EPR regulations. However, this does not remove the responsibility to manage fertiliser-related waste responsibly in accordance with broader waste management and environmental obligations.
TIPWG urges industry members to closely monitor regulatory developments, as this area may evolve in the future.
Stewardship Is Everyone’s Responsibility
The forestry and agricultural sectors have made significant progress in improving pesticide stewardship, environmental monitoring, and certification alignment. Proper container management forms a simple but essential part of that broader stewardship responsibility. The systems, guidance documents, recyclers, and industry support structures already exist. Compliance in this area is achievable. What is needed now is consistent implementation.
Additional guidance on developing and supporting container management programmes can also be found in the TIPWG Pesticide Monitoring and Management Guideline.
Ultimately, responsible container disposal is not simply about compliance; it reflects an industry’s commitment to environmental protection, worker safety, responsible pesticide use, and sustainable forestry practices.
“IT’S THE RIGHT THING TO DO!”
Source: Forestry in Focus
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