UNL CropWatch March 4, 2011 The Rules for Refillable Pesticide Containers
March 4, 2011
This is the first segment of a three-part series on rules pertaining to refillable containers, non-refillable containers, and secondary containment. This article addresses refillable containers.
EPA pesticide container rules apply to refillable containers as well as the re-use of refillable containers (repackaging). The PCC Rule (see box) also addresses labeling on pesticide containers, including requirements for cleaning and disposing of empty containers.
Both the registrants and independent refillers (repackagers but not the product registrant) must comply with requirements for stationary tanks, repackaging, and portable refillable containers. EPA requirements for refillable containers are discussed below.
1) Stationary tanks are containers that are fixed in place for 30 or more days at the facilities of independent refillers. These containers hold 500 gallons (liquid) or 4000 pounds (dry) of pesticides. Each tank must have:
- a serial number or other identifying code,
- sufficient strength and durability,
- vents that limit evaporation,
- no external sight gauges,
- a lockable inlet/outlet valve,
- secondary containment if holding an agricultural pesticide, and
- anchorage or elevation to prevent flotation if holding an agricultural pesticide.
2) Registrants are responsible for making sure portable refillable containers (mini bulks, shuttles, totes, etc.) meet Department of Transportation (DOT) standards and bear a DOT transport marking and serial number. In addition, they must be tamper resistant or have one-way valves.
Since the requirements for these containers were changed in recent years, many older containers will be recycled. Many agro chemical manufacturers or distributors offer programs to properly collect and destroy old mini-bulk containers that can no longer be used under the PCC Rule. Many of these programs will continue for years as old containers are being taken out of circulation and being replaced by new, compliant containers. In Nebraska, Tri-Rinse, Inc. (314-647-8338) and Container Services Network (866-225-6629) will collect containers upon request.
Repackaging requirements for any refiller or registrant include:
- a written contract between the independent refiller and the registrant,
- responsibility for product integrity,
- no regulatory limits on size of refillable containers, although in their contract, registrants might establish a specific size limitation, and
- that the registrant provide
1) procedures to clean refillables and
2) descriptions of acceptable containers that meet stationary tank and portable refillable requirements.
Refillers must have these documents on file.
Refilling requirements that must be implemented during repackaging include:
- identification of the previous pesticide that was in the refillable container and visually inspecting the container to ensure it is safe and has the required marks and openings
- cleaning of the container unless the tamper-resistant or one-way valve is intact and the container is being refilled with the same product (or if a new product meets other limited circumstances)
- ensuring that the container is included in the registrant’s description of acceptable containers
- proper labeling of the product, including the EPA establishment number and net contents
- a record of appropriate information, such as date of repackaging and container serial number
Examples of label language for refillables include a “refillable container” statement and instructions for cleaning the container before recycling or disposal (not before being refilled).
The next article in this series, scheduled for the March 18 CropWatch, will discuss rules for non-refillable pesticide containers.
Erin Bauer, Extension Associate
Clyde Ogg, Extension Educator
Pierce Hansen, Extension Assistant
Jan Hygnstrom, Project Coordinator
UNL Pesticide Safety Education Program