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              The Law
•  The repackaging facility must keep all records
  required by federal pesticide law, and must report
  the amount of repackaging to EPA each year.

Under the EPA bulk policy, if any of the above
conditions is not met, the repackaged pesticide is
considered to be unregistered.   The dealer
responsible could be subject to enforcement action
under federal or state law, which could include the
assessment of fines.

For information on registering your establishment
with EPA, or record-keeping and reporting
requirements, please call (206) 553-1970. For all
other information concerning the bulk policy, please
call (206) 553-5032.
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                            -August 1994
                                                                                         EPA910/F-94-002
                   SEPA
United States           Region 10
Environmental Protection    1200 Sixth Avenue
Agency               Seattle WA 98101-9797

Repackaging
Bulk Pesticides
Information Bulletin

Important Information for
Dealers/Repackagers of
Bulk Agricultural Pesticides

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This bulletin provides information on the EPA bulk policy and is intended for dealers who repackage bulk pesticide products for sale to the agricultural community. Please
read this carefully. There have been recent changes in the policy and, as a result, new requirements for dealers.

A"bulk dealer" is anyone who repackages bulk pesticides for sale to end-users (growers/applicators). EPA's bulk policy allows the repackaging of any quantity of a registered
pesticide into a refiliable container if the following conditions are met:
             The Container
               The Site
           The Bulk Tank
  The containers must hold more than 55 gallons of
  liquid pesticide or more than 100 pounds of dry
  pesticide.

  The containers must be dedicated to and refilled
  with one specific pesticide product, or they must
  be cleaned according to instructions from the
  pesticide registrant before being filled with another
  pesticide.

  The containers of  all  repackaged pesticides
  distributed by the repackaging facility must be
  labeled with the EPA-approved,  end-use label.
  The label must include the establishment number
  of the repackaging  facility, and  the correct net
  contents of the container.
Each site (physical location) where repackaging
takes place must be registered as a producing
establishment with EPA.
     . site (physical location) where repackaging
takes place must have a written agreement with
the pesticide registrant which  allows them to
repackage the product and to use the registrant's
label. A copy of the agreement, dated and signed
by the dealer and the registrant must be kept at
each site.
The bulk storage tanks must be correctly labeled
with the registrant's EPA-approved label.

The  label  must include the number of the
establishment  where the pesticide was last
produced.  (This requirement is  a change from
previous policy. In the past, many bulk dealers
have  been  instructed to  put  their  own
establishment number on the bulk tank labels.
This  is no longer the correct procedure.)

The net contents of the bulk tank must be marked
on the label when it is filled. (It is not necessary
for the dealer to change the net contents on the
bulk tank each time he withdraws product.)
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