Improper disposal of hazardous waste (chemicals) is a well-known cause of both point source and non point source water pollution. Over the past years New York State has helped localities provide special collection of these products with a 50% grant to help defray costs. This grant program has been offered on a continuing basis and is awarded first come - first served; no point system that prioritizes projects is factored in. Not all communities take advantage of it, but those that have applied are almost assured that they will receive this financial help. The program covers almost all household hazardous wastes and in most cases also helps what is termed Conditionally Exempt Small Quantity Generators. A CESQG is someone who generates no more than 220 lbs. (27 gal.) of hazardous waste per month, or generates no more that 2.2 lbs of acute hazardous waste monthly. To qualify as a CESQG they must store less than 2,200 lbs of hazardous waste and less than 2.2 lbs of acute hazardous waste at any time.

Unfortunately, many farms in New York State do not qualify for these funds since they are considered Large Quantity Generators. It is felt that there remains quantities of this material still stored on numerous farms throughout the State. To date there seems to have been little concerted effort to solve this problem. Over the past few years the NYRWA Solid Waste Management Technical Assistance Program and the Northeast Rural Communities Assistance Program have been concerned with the issue and have tried to take a closer look at it.

We have made some very general observations. There seems to be little data available to determine where and how much of this stuff is out there. Although the Federal Superfund Amendments and Reauthorization Act of 1986 (SARA) require reporting of these hazardous chemicals, for obvious reasons few farms have complied. Most people we talk with (including farmers) seem to feel that outdated and banned chemicals are still lying around.

Proper collection and disposal of these substances is extremely costly. Hazardous waste haulers and hazardous waste disposal sites operate under such stringent regulations that their operating costs are very high. Most farms would suffer tremendous economic hardship if they were forced to cover the entire costs of collection. I doubt that many of us would like to see a reduction of regulations on material that could literally kill us, so it appears that we must try to find a way to help individual farms meet the huge costs of hazardous waste disposal.

There have been some local and regional farm pesticide collection projects made possible by grants from the United States Environmental Protection Agency. County Soil and Water Conservation Districts, Solid Waste Departments, and other local agencies have held these Clean Sweep "amnesty day events". The problem seems to be that many were one-time events and were not held on a continuing basis like the household hazardous waste annual collection days. While participation was decent in some parts of the State, they were disappointing in other sections. We've concluded that there are a variety of reasons for low participation.

We must recognize that we are dealing with products that are currently illegal and folks that store them are technically breaking laws. Therefore, there is a reluctance to admit possession and mistrust that the amnesty events are a way to report violators to authorities. Some feel that they are "taking a chance" rather than understanding that these days offer a very low cost method of proper disposal. Perhaps a strong public relations campaign that explains that the only reason for the events is collection, not retribution would help participation rates.

Farmers are extremely busy, many could use a 30-hour day, and these programs do take time. To begin with, the New York State Department of Transportation requires special permits to transport hazardous waste. Few farm vehicles have it and most past programs have required a training session (either half day or full day) in order for a farmer to receive a NYS DOT Waiver for transporting this hazardous waste to a collection site. Many feel that since they already have Application Certifications, this is an unnecessary time consuming step. It also takes time to handle this dangerous product. It must be properly loaded with extra safety precautions (even respirators in some cases) and inventoried. Most collection sites require delivery by appointment only and if they fall behind there is additional waiting.

We have also made some other general observations. We've estimated that most of the problem areas are with smaller farm operations and on non-working "gentleman farms". Our conclusion is based on an understanding that larger working farms have already utilized most all of the chemicals they had in stock. In fact, many of the larger farms no longer handle chemicals themselves but contract out full time applicators so they are no longer required to work with or store these products. On the other hand, some smaller operations could have a stockpile of this waste, as they might have bought additional supplies to earn price breaks and then didn't use all of their purchase. And then there are the city folks who purchased farm property only to walk out into the barn and discover a 55-gallon drum of "something". Most often they don't know what it is or how to get rid of it.

So how do we proceed to help solve this problem? We will continue to encourage localities to apply for EPA Clean Sweep Grants when available and to run amnesty chemical collection events. New York State recently announced a mini-grant program for County Water Quality Coordinating Committees through the New York State Soil and Water Conservation Committee. It will award $15,000 toward a countywide collection program and up to $25,000 for a regional collection. They anticipate that they will have between $200,000 and $300,000 in Section 319 Clean Water Act funds for this program and we will help spread the word on this program and promote its use. NYRWA and RCAP have held meetings with the New York Center for Agricultural Medicine and Health on this issue and will continue to work with them to find solutions. We continue to plan some method of tabulating a statewide inventory of old farm chemicals so that we can use this data to demonstrate to State and Federal authorities the need for an ongoing grant program to help remove this danger to our environment. As was briefly discussed at a focus group of farmers from Columbia County, this might prove difficult and will take an enormous public relations effort in conjunction with farmer friendly organizations in order to complete. We continue to evaluate a workable method for this study.

It 's been generally agreed that there is some degree of problems with old farm chemicals. The problem will be costly to fix, it won't be an easy process, and it will take time to resolve. We'll keep working to find some reasonable solutions and inform you of our progress. If you would like more information on the NYS Soil and Water Conservation Committee's mini-grant offer, please call their office at (518) 457-3738 or call Libby Smith at NYSDEC (518) 485-8772. You may also call Bob Messinger at the NYRWA office for help applying for these funds.