University of Nebraska-Lincoln Extension, Institute of Agriculture and Natural Resources

October 27, 2006

EPA releases Pesticide Container and Containment Rule

For further information on pesticide research, use, safety and products, check UNL's Pest Education Resources Web site.
EPA has released the final rule on standards for pesticide containers and containment. The rule was first proposed in 1994. The rule will affect pesticide registrants, distributors and retailers. The only requirement for private applicators and commercial/noncommercial applicators is to follow instructions on the pesticide label regarding refilling, cleaning and recycling containers. EPA is considering the label requirement of recycling rinsed plastic pesticide containers and this rule serves as a standard in this process.

The document, ANSI/ASABE S596 FEB2006, Recycling Plastic Containers from Pesticides and Pesticide-Related Products, was developed in cooperation with CropLife America, a trade association whose members fund container recycling, and the Ag Container Recycling Council, ACRC. Other members of the standard development committee included representatives from the Association of American Pesticide Control Officials, American Association of Pesticide Safety Educators (Larry Schulze, University of Nebraska-Lincoln Extension), Chemical Producers and Distributors Association, The Pesticide Stewardship Alliance, The Environmental Protection Agency and experienced ASABE members from the PM Division technical committee PM-23/6, Application Systems.

The rule has extensive language regarding the containers, both refillable and nonrefillable and containers used for repackaging of pesticide products. Containment structures are required for agriculture retailers as well as agriculture commercial and custom applicators. These structures include secondary containment dikes around stationary tanks, containment pads for pesticide dispensing areas, recordkeeping and monthly inspections of tanks and structures. The final regulations include five sections, which are described below.

  1. Nonrefillable Containers: This section addresses "one-way" or disposable containers and applies to pesticide registrants. The purpose of these standards is to ensure that containers are strong and durable, minimize human exposure during container handling and facilitate container disposal and recycling.

  2. Refillable Containers: This section applies to containers that are intended to be refilled and reused more than once and applies to pesticide registrants. The purpose of these standards is to ensure that containers are strong and durable, minimize cross-contamination of pesticides distributed in refillable containers, and encourage the use of refillable containers to reduce container disposal problems.

  3. Repackaging: This section, which describes procedures and other safeguards for repackaging pesticide into refillable containers, applies to pesticide registrants and anyone who refills pesticide containers for sale (registrants, formulators, distributors and dealers). These regulations are intended to minimize cross-contamination of pesticides distributed in refillable containers, codify safe refilling management practices and encourage the use of refillable containers to reduce container disposal problems.

  4. Labeling: The labeling segment includes instructions for how to properly clean pesticide containers and a statement identifying the container as nonrefillable or refillable. Pesticide registrants are required to ensure that labels include the specified information. Pesticide users are required to comply with the instructions on the labels.

  5. Containment Structures: This section establishes standards for secondary containment structures at certain bulk storage sites and for containment pads at certain pesticide dispensing operations. Pesticide dealers who repackage pesticides, commercial applicators and custom blenders have to comply with the requirements. The purpose of these standards is to protect the environment from leaks and spills at bulk storage areas and from contamination due to pesticide dispensing operations. More information about the new regulation is available at: http://www.epa.gov/pesticides/regulating/containers.htm

(Sources: EPA Office of Pesticide Programs Update 8/16/06, ASABE News Release, 9/21/06)

Larry Schulze
Pesticide Education Specialist

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