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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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