FERTILIZER PRODUCT STEWARDSHIP RE-USE, RECYCLING AND/OR DISPOSAL OF PACKAGING MATERIALS AND LEFT-OVERS

INTRODUCTION

One of the objectives of the Product Stewardship Program of Fertilizers  is to minimize safety issues and environmental impacts from wastes and non-conforming materials. This involves the re-use, recycling and proper disposal of solid and liquid waste and packaging material, and the correct treatment of off-spec and refused products. The first step is to establish the fate of all impurities and of waste products.

LEGAL REQUIREMENTS

There are no legal requirements to establish the fate of waste products, though the consideration of the environmental fate is a good practice for Responsible Care companies.

FERTILIZERS EUROPE REQUIREMENTS

The following aspects have to be taken into account:

1) Risk for the environment (Responsible Care: no risks for man and the environment; part of the risk management process)

2) Risk to the customers (risk to the users of the product involved in any possible exposure).

3) Risk to the business 

For defining the risk to the environment and user.

• How many products are manufactured?
• What is the use/misuse of the product and how is it applied?
• What are the exposure and disposal data?
• What are the disposal patterns for product/ impurities/wastes at each stage of the lifecycle?
• What are the user competence, facilities and know-how?
• What are the toxicity and eco-toxicity hazards?
• Is the product handled is a safe way?
• Compliance with regulatory requirements on use and disposal?
• Knowledge on previous incidents and accidents?
• Information on and training in safe disposal?
• Are impurities/by-products present?

How to achieve:

• Auditable system for environmental fate in place?
• Market use, exposure and disposal data; monitoring changes in use/disposal
• Written procedures on roles and responsibilities.
• Periodically audit against the defined systems and procedures.
• Corrective and protective actions.
• Partnership with distributors, users and waste disposers is useful.
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  CUSTOMER WASTE

  Advice to customers and product users on the disposal of packaging, waste product and end-of-life product. It excludes the specific obligations on producers for packaging waste.

  LEGAL REQUIREMENTS

  For products which are hazardous, advice for customers on product disposal must be provided through section 13 of the Safety Data Sheet: Disposal Considerations.

  FERTILIZERS EUROPE REQUIREMENTS

  Suppliers should look for opportunities to work actively with their customers and to help the latter dispose of any product-related waste safely. (It is important not to take on liability - advice should be offered in a way that customers retain responsibility for their risk prevention and management measures.) For products not requiring a Safety Data Sheet, suppliers should still provide appropriate disposal advice by the most effective means, taking into account the capabilities of the customer.
  How to achieve
• Identify significant wastes (unused products ; packaging waste)
• Assemble information on the health, safety and environmental fate (re-use, reprocessing, recycling, incineration, landfill or release to the environment) and hazards of such waste. Check the relevance of the company's own practices and procedures to waste disposal by customers.
• Access commercial and environmental benefits : give advice to customers on :
  • Regulations
  • In-house procedures
  • Skilled help and assistance from supplier
  • Choice of contractors for disposal
  • Initiate waste management studies, resolve problems
  • Set up processes
• Identify recycling possibilities
• Implement