PART 261 SUBPART A - GENERAL
DOC: 9441.18(84)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Container, Pesticides
40 CFR 261.7, 261.33
Response to Questions from State Pesticide Personnel:
Triple Rinsing
N/A
John H. Skinner, Director, and Amy E. Schaffer, Program Analyst,
Office of Solid Waste and Emergency Response
Source Doc: See Miscellaneous [9560.07(84) Question //3]
Date:
Summary:
8-8-84
If a disposed empty container contained hazardous waste as listed in
§261*33, the container is subject to the requirements of §261.7: residues of •
hazardous waste in empty containers. Residues of hazardous waste in "empty''
containers are not subject to regulation if that container's waste was removed
using the practices commonly employed to remove materials from that type of .
container (i.e., triple rinsing or another acceptable method). *
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Response to Questions frora state Pesticides Cont-rol Officers
John H. Skinner
Director
Office of Solid waste and toer^ency Response (*H-562)
Amy E. Schaffer
Proyra/n Analyst
Office of Solid Waste and Emergency Response (WH-527)
The following responses are presented for the questions and
issues -fcosed by the State Pesticides Control Officers concerning
RCRA. Some of tha questions were quite difficult to interpret
and were answered to the best of our ability. If additional
information or clarification is required, please contact
Francine Jacoff at 475-8551.
(1) NEW MIXING, LOADING AND TEMPORARY STORAGE STANDARDS -
Currently no standards exist which indicate acceptance
methods. Society must lay out its level of accepta-
bility if actions taken today are not to result in
similar concerns to the old sites issue.
RCRA does have existing standards that apply to
temporary storage, that is, for less than 90 days.
(.2) Are there reasons which would justify the "economically and
technically feasible" standards for some pesticide disposal?
The question is taken out of context and is difficult ,
to answer. None of the RCRA disposal standards are
based on economics but instead are based on a "protect
human health and the environment" study. They may be
referring to tailored standards for particular pesticides.
RCRA either requires compliance with Subtitle C standards
for listed hazardous wastes or excludes them- for specitied
reasons.
.
(3) Container disposal, particularly ULV products and in
impregnated fertilizer situations. What if triple rinsing
is impossible?
Section 261.7 is pertinent only if the product is
listed in 5261.33. Section 261.7, Residues of
hazardous waste in empty containers, is explicit.
(4*) Bulk pesticide storage standards - are they needed? ^ff'fl ,i.(jf
RCRA is concerned with waste storage, not product
storage. OPP should answer this question.
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