In 2010, when I stepped into RIGK Romania office as an Executive Manager I asked my new colleagues how do they organised the sampling procedure for analysing in 2008 and 2009.
One of the SCAPA inspectors, a RIGK srl employee, was very proud to tell me he washed every container into his home’s bathtub before bring them to the office. We are speaking about pesticide’s containers. The others were more precautions in expressing their actions but in the end came that they just selected the best clean whole packages from the cleanest bag they inspect at one generator. They all send a number of 10-20 packages, different sizes from 0,5l to 5 l, by post , two times per year, to RIGK office. The sample was send together with a minute singed by one of the representatives of the collection site.
AIPROM required to RIGK srl this analysis by contract to keep a non-hazardous classification for the pesticides packages and to use this analysis in the communication with authorities. The European Crop Protection Association agreed & certified laboratory was Institute Kuhlmann from Germany. I worked for AIPROM and I knew that was a very sensible subject.
Still considering this an important subject, I opened this discussion with my colleagues from RIKG Germany and with my direct boss. I found a smart answer: a blink of an eye. Thing has to go forward. He took the best decision between any legal obligation (there is no legal obligation per se to do the analyses) and to respect the contract with AIPROM and ECPA guidelines. Things were going forward in his way.
In march 2012, the waste management legislation changed in Romania making mandatory for a generator to classify a waste based on an analyse bulletin done by and authorised laboratory. I asked my German colleagues if might be possible to have at RIGK Romania a small shredding machinery for SCAPA packages to prevent any delays in case of a Environmental Guard control at farms or SCAPA generators. I received a negative answer from RIGK Germany. Last try for me to do make things clear until now.
Between 2008 and 2012, 2008 and 2009 under direct supervision of RIGK Germany manager and between 2010 and 2012 under his supervision and with my acceptance, RIGK’s inspectors send samples of pesticides packages carefully selected from SCAPA stream to RIGK srl office, then RIGK srl office send all the quantities by post, to Institute Kuhlmann. We had to have beautiful analyses for SCAPA waste in front of our national authorities and at European level.
In case a hazardous classification is mandatory for pesticide collected packages, the collections systems are facing 2-3 times more transportation costs and a more slow collection pace because of the complicate procedure to authorise an ADR transport. Every cost has to be paid by the industry.
What says the European Crop Protection Association guideline for sampling?
Source: “Sample collection of plastic material out of shredded plastic containers (Post Consumer Resins, PCR’s) for later analysis of pesticide residues – Erika Seidel, Bayer CropScience AG on behalf of Packaging and Transport Expert Group of European Crop Protection Association- 2006”:
4.1. Primary Sample The primary sample is the amount of a shredded material taken at one time in one sampling step at one and only place (sampling location / sampling point) of a means of transport or directly out of the shredder process (8 portions each 30 t out of 10 t). The amounts of a number of primary samples should be in the same size. Primary samples are taken at randomly selected shredding sites in a certain interval defined by the manager of the collection scheme.
4.2. Cumulative Sample (Optional) The cumulative sample is a summarized sample based on a number of primary samples. A cumulative sample is prepared by combining and mixing of primary samples.
4.3. Final Sample The final sample is prepared out of several cumulative or primary samples by combining and mixing. A final sample might be a representativeA subset of the whole amount of all primary or cumulative samples after efficient combining and well mixing. The final sample should be almost 5-times as large as for the later analytical procedure needed.
4.4. Laboratory Sample
The laboratory sample is a subset of the final sample (where appropriate primary sample) intended to be used for analysis in the analytical laboratory after appropriate grinding according to method description [references , ].
Each analysis includes two replicates.”
End of the quote
When between 2008 to 2012 had SCAPA in Romania 30 tons, or 10 tons of shredded materials? Maybe in RIGK warehouse in Resita. Any sample taken from there?
Considering all these, please let me have doubts too about the sampling procedure in Germany and in their results widely promoted by ECPA, and to ask my self if is any double or single standard in the way RIGK is sampling the waste in their collection systems.
Update: the Spanish case