Robert L. Denny has been honoured, on more than one occasion as the father of pesticide container stewardship. He is most frequently associated with pesticide stewardship efforts, yet his career is more varied than that. He began as an air pollution chemist, and from modelling pesticide spray drift he became a pesticides regulator in the US, then eventually a broad services, environmental project manager.
In 1981, as Director of the State of Maine’s pesticide regulatory agency, he was implementing a then novel use of helicopters for aerial enforcement of herbicide use and potential off-target drift. No violations of herbicide use were found, but he and his investigators noticed large scale violations of pesticide label-language container disposal instructions. He contacted Washington, DC immediately and received permission to redirect the remaining federal grant for additional enforcement work. His staff documented through first aerial and then ground research, hundreds of pesticide container disposal violations. In pursuit of these compliance actions he realized there were few legal and economic options in that State for pesticide container disposal. Robert and an attorney for a local NGO, began the process of writing a proposed container management statute, steering it through the Legislature, procuring funding and implementing the world’s first container collection and recycling programme. As early as the winter of 1981-82, several principles were expressed:
On this last point, the US pesticide industry fought efforts to create a monetary deposit, refundable upon returned properly rinsed. The industry was largely successful in blocking this measure, at least on general use pesticide products. Nevertheless, a deposit remains to this day in Maine on Class 1 toxics. In this instance, almost 100% of these containers are returned clean.
The Maine programme was and is an unqualified success and still operates today, both in conjunction with, and yet apart from, the nationwide industry Ag Container Recycling Council effort.
In that same year, 1981, Robert Denny conceived, found funding and initiated a state-wide, door-to-door obsolete pesticide stocks recovery programme that even today would meet the highest standards for environmental protection. He also did pioneering work in the field of off target residue analysis, especially soils and plant analysis relative to pesticide spray drift and began the policy changes that led to one of the earliest notification and drift laws in the US that were finalized after his departure. For his various pioneering projects, Rob Denny was named, in 1985, as one of Maine’s Conservationists of the Year, that state’s most prestigious environmental award.
In 1983-84, Robert Denny worked with then US Senator George Mitchell (currently the US Envoy to the Middle East Peace Process) to draft amendments to the Federal Pesticide Act. The Amendments failed passage in 1984, but were passed intact in 1988 as Section 19 to the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). By then Robert Denny was in Washington, working at EPA Headquarters and was put in charge of implementing these changes, as Chief Pesticide Management and Disposal. For these efforts Robert L. Denny was awarded the US EPA Gold Medal for Environmental Excellence.
One significant output from this US EPA Effort was initiated and supervised by Robert Denny:
Pesticide Containers, A Report to Congress: United States Environmental Protection Agency, OPP, Pesticide Management and Disposal Staff, Washington, DC: EPA 540/09-91-116, 235p.
This report, primarily written by his then most junior staffmember: Nancy Fitz, remains today, the most comprehensive assembly of issues and technical knowledge existent on pesticide containers: construction and design, sizes, openings, mixing-loading, rinsing and disposal. Within these pages are also two seminal studies on residues in containers and residues remaining after various rinses: The first is the “Peck Study” which Robert commissioned while serving in Maine and the “Formulogics Study,“ funded and directed under Rob’s direct management while at EPA. Both are considered definitive references in pesticide container management and their potential for safe recycling. He also funded a study on “glugging” or clean pours of product, minimizing opportunities for contamination of the user and the outside of the container.
Robert left EPA in 1992 for an opportunity as an environmental consultant. This included 13 years as a consultant manager of the American industry’s pesticide container recycling programme. In a relatively few years, he built that effort from a few thousand pounds to approximately 4 million pounds per annum. He designed and implemented virtually all of the training media for that effort and many items are used, in one form or another, today.
Robert provided counselling through these years to a number of now successful programmes in either obsolete stocks disposal or establishing national container collections. He assisted the Republic of Uzbekistan, through a World Bank Cotton IPM project, in drafting environmental legislation shortly after their independence. He also directed an overhaul of the Lithuanian non-farm pesticide registration and regulatory efforts as a condition of their joining the European Union. This massive project was completed on-time, within budget, with no non-compliances.
He also primarily designed and managed the combined obsolete stocks disposal and container collection programme for New York State. His efforts in New York City are still one of the most unique applications of pesticide stewardship collections in a large densely populated urban setting.
Robert Denny is a founder of The Pesticide Stewardship Alliance, an international organization initially focused on obsolete stocks and pesticide containers and now broadened into a spectrum of pesticide stewardship initiatives.
Robert’s current projects include:
Advisor to the Republic of Mozambique on several pesticide stewardship challenges.
Dissemination of a training programme to implement the FAO Guidance for rinsing pesticide containers. The complete training programme is available on this website.
As part of a team from the Natural Resources Institute of the United Kingdom, Rob is working on finding acceptable dispositions for spent insecticide mosquito netting. Pilot programmes are concluded in Kenya, Tanzania and Madagascar and he is preparing the final report.
Assisting the WHO and UNEP in designing the grant proposal for the next round of stewardship efforts for insecticide treated mosquito nets and their packaging.
Robert L. Denny was the senior technical advisor to the American Society of Agricultural and Biological Engineers standard making process on triple-rinsing pesticide containers. This is equivalent to an ISO standard in Europe.
ASABE, Recycling Plastic Containers from Pesticides and Pesticide Related Products. 2006: St. Joseph, Michigan, USA. p. 13.
Summary: Approximately 50 publications, mostly non-peer reviewed in the applied field of pesticide stewardship. Published peer-reviewed research on methodologies in Analytical Chemistry (ACS publication) and policy in ASTM book. Also keynote address at IUPAC (International Union of Pesticide Analytical Chemists) 1994 conference, Washington DC, and Keynote address at the American Chemical Society Conference, NYC, 1992. Rob Denny also wrote, narrated and produced three documentaries for the US National Public Radio.