United States
Environmental Protection
Agency
Office of
Pesticide Programs
Washington, DC 20460
tudy
EPA 540/09-91-116
May 1992
PB-91-110411
Report to Congress
..* s
Printed on Recycled Paper •
-------
PI
A Report to Congress
United States Environmental Protection Agency
Office of Pesticide Programs
Pesticide Management and Disposal Staff
May, 1992
-------
Pesticide Containers A Report to Congress
References to any product or company in this report are used
solely for illustrative purposes and are not intended as an EPA
endorsement of any product or institution.
-------
Pesticide Containers - A Report to Congress
Table of Contents
EXECUTIVE SUMMARY ix
CHAPTER 1 - INTRODUCTION 1
CHAPTER 2 - THE PESTICIDE INDUSTRY
2.1 Introduction 3
2.2 Definition of "Pesticide" 3
2.3 Pesticide Markets 3
2.4 Agricultural Pesticides 4
2.5 Institutional and Industrial Pesticides 6
2.6 Household Pesticides 8
CHAPTER 3 - FORMULATIONS
3.1 Introduction 11
3.2 Liquid Formulation Types 12
3.3 Dry Formulation Types 13
3.4 Other Formulation Types 14
CHAPTER 4 - PESTICIDE CONTAINERS
4.1 Introduction 19
4.2 Nonrefillable Containers 20
4.3 Refillable Containers 29
4.4 Number of Containers 33
4.5 Trends in Pesticide Containers 37
-------
Table of Contents
CHAPTER 5 - REQUIREMENTS AFFECTING PESTICIDE CONTAINERS
5.1 Introduction
5.2 Department of Transportation (DOT)
5.3 United Nations
5.4 Environmental Protection Agency (EPA)
5.5 States
5.6 Municipalities - Landfilling
5.7 Industry Standards
CHAPTER 6 - NONREFILLABLE CONTAINERS: USE
6.1 Introduction
6.2 Rigid Nonrefillable Containers
6.3 Pour Testing
6.4 Bags
6.5 Other Containers
6.6 Mechanical Transfer Systems
41
41
43
44
52
55
55
59
60
66
73
76
81
CHAPTER 7 = NONREFILLABLE CONTAINERS: RESIDUE REMOVAL
7.1 Introduction
7.2 Current Residue Removal Techniques
7.3 Variables in Residue Removal
7.4 Studies of Residue Removal
7.5 Laboratory and Field Analytical Methods
7.6 Future Research Needs
CHAPTER 8 - NONREFILLABLE CONTAINERS: DISPOSAL
8.1 Introduction
8.2 Surveys on Container Disposal
8.3 Open Dumping
8.4 On-Site Burial
8.5 Landfilling
8.6 Open Burning
8.7 Other Disposal Options
8.8 Recycling
8.9 Collection Programs
89
89
102
104
119
121
127
127
131
133
133
134
134
134
136
-------
Pesticide Containers A Report to Congress
CHAPTER 9 - REFILLABLE CONTAINERS: USE
9.1 Introduction 145
9.2 Minibulk Containers 145
9.3 Small Volume Returnable Containers 156
9.4 Bulk Containers 158
9.5 Dry Refillable Containers 160
CHAPTER 10 - REFILLABLE CONTAINERS: RESIDUAL REMOVAL
10.1 Introduction 163
10.2 Cross-Contamination 163
10.3 Dedicated Containers/Allowable
Refilling Practices 164
10.4 Residue Removal Procedures 166
10.5 Management of Rinsate 168
CHAPTER 11 - REFILLABLE CONTAINERS: DISPOSAL
11.1 Introduction 171
11.2 Landfilling 172
11.3 Open Burning 172
11.4 Stockpiling 173
11.5 Energy Recovery 173
11.6 Recycling 173
11.7 Collection Programs 174
CHAPTER 12 - BULK STORAGE FACILITIES
12.1 Introduction 177
12.2 Description of Bulk Storage Facilities 177
12.3 Pesticide Releases at Bulk Storage Facilities 178
12.4 Containment Structures 178
12.5 State Regulations 179
12.6 Other Operational Issues 183
-------
Table of Contents
CHAPTER 13 - OPTIONS
13.1 Introduction 185
13.2 Options To Encourage Refillable Containers 186
13.3 Options To Facilitate Residue Removal 190
13.4 Options To Encourage the Use of Bulk
Storage Facilities To Reduce the Number
of Containers Requiring Disposal 195
13.5 Summary of 1985 University of Manitoba Report on
Disposal Options 198
CHAPTER 14 - CONCLUSION
14.1 Introduction 203
14.2 General Conclusions 203
14.3 Specific Options 204
14.4 Areas for Further Study 207
14.5 Conclusion 208
APPENDIX A 209
APPENDIX B 217
BIBLIOGRAPHY 219
-------
Pesticide Containers - A Report to Congress
Executive Summary
In its 1988 amendments to the Federal Insec-
ticide, Fungicide, and Rodenticide Act (FIFRA)
Congress in FIFRA Section 19(g) mandated a
report from EPA that would present options for
encouraging or requiring:
•The return, refill, and reuse of pesticide
containers;
•The development and use of pesticide for-
mulations that facilitate the removal of pes-
ticide residues from the containers; and
•The use of bulk storage facilities to reduce
the number of pesticide containers requir-
ing disposal.
To provide a basis for developing such op-
tions, the Agency conducted a comprehensive
study to collect a wide range of information
about current pesticide container technology
and practices. Therefore, this report presents
not only a variety of options for solving the
problems about which Congress was concerned,
but also includes the information gathered as a
result of the study.
Three key concepts that emerged during the
course of the study figure prominently in this
report and in the options that the report presents:
•Containers can be classified into two types
— refillable and nonrefillable — each of which
presents different issues and concerns.
•Each container/formulation combination
should be viewed as a single entity. Most
container-related problems cannot be solved
without considering the interactions between
containers and their contents.
•Many tradeoffs are involved in changing
current container designs and practices.
The Pesticide Industry
Any attempt to address concerns relating to
pesticide containers must recognize that the
term "pesticides" encompasses a broad range of
substances, including such widely differing
products as insecticides, disinfectants, and plant
growth regulators. And although the same
active ingredient may be used in similar prod-
ucts for the three major markets — agricultural,
institutional and industrial, and household -
those markets differ in their distribution chain,
end uses, and practices for container use, resi-
due removal, and disposal.
The agricultural market is extremely diverse,
while the other markets are more uniform. In
IX
-------
Executive Summary
the agricultural market, the types and amounts
of pesticides used vary widely according to
crop, region, and size of operation. The agricul-
tural distribution chain generally includes the
registrant, manufacturer, formulator, distribu-
tor, dealer, and user. Many agricultural pesti-
cides are packaged in containers that can be
passed back up the distribution chain for refill-
ing.
Many pesticides are used in institutional
and industrial settings. The distribution chain
for these markets is generally not as uniform as
the agricultural chain. It includes more compa-
nies that only formulate the pesticides, and it
lacks an entity equivalent to the agricultural
pesticide dealer. Most of the containers in this
market are not refillable, so the end users must
dispose of them.
Household pesticides generally are pack-
aged in smaller containers than those used in
the other markets. No household products are
sold in refillable containers. In this market,
unlike the others, users can buy the products at
a wide variety of common retail establishments.
Formulators may sell through a distributor/
warehouse or directly to retail stores.
Formulations
Pesticide active ingredients are marketed in
many formulations. Any effort to achieve
improvements in container design, use, and
disposal must consider the interactions between
containers and formulations.
Formulations may be either liquid or dry,
and they include a wide variety of solutions,
emulsions, powders, dusts, granules, pellets,
and aerosols. The level of concentration of
active ingredient in a formulation may be high
or low, depending on the level of inert ingredi-
ents it contains. Some formulations are ready to
use; others must be diluted before use.
Pesticide Containers
The diverse pesticide market has led to an
equally diverse array of pesticide containers.
This report classifies containers into two major
types ~ nonrefillable and refillable.
Nonrefillable containers are commonly re-
ferred to as one-way or "throwaway" packages.
Although nonrefillable containers can be any
size, most have a capacity of 5 gallons or less.
Examples are cans, bags, bag-in-a-box designs,
aerosol cans, and water-soluble bags. Larger
nonrefillables include 55- and 30-gallon drums.
Each of these types includes a wide variety of
containers that differ in their materials, open-
ings and closures, and design features.
Most nonrefillable pesticide containers were
not designed specifically for the pesticide in-
dustry. Except for aerosol cans, about 10 per-
cent of which are used for pesticides, the pesti-
cide industry does not buy a significant portion
of the containers produced in this country.
Therefore, the pesticide industry may have little
influence on container design and availability.
Refillable containers are designed and con-
structed to be refilled with pesticide for sale or
distribution. Examples are bulk storage tanks,
minibulks, refillable bags, and small volume
returnables (SVR's). Refillable containers, too,
vary widely in materials, openings and clo-
sures, and design features. For the purposes of
this report, minibulks are portable refillable
containers for liquid pesticides with capacities
greater than 55 gallons, while SVR containers
are portable refillable containers for liquid pes-
ticides with capacities of 55 gallons and less.
No definitive statement exists with respect
to the number of pesticide containers presently
in the marketplace or the number of empty pes-
ticide containers generated in the United States
each year. A-1986 EPA survey indicated that
there were 223 million empty containers that
-------
Pesticide Containers - A Report to Congress
year, a figure that subsequently has been shown
to be a considerable underestimate. A 1989
pesticide industry survey provided approxi-
mate figures on container numbers; more im-
portantly, it indicated the major types of con-
tainers used in each segment of the pesticide
industry.
The National Agricultural Chemicals Asso-
ciation (NACA) portion of that survey provides
a general idea of the percent of agricultural
pesticides which is sold in each type of con-
tainer. In 1989, for example:
•Liquids ~ 43 percent in 2.5-gallon plastic
jugs, 17 percent in minibulk containers, 17
percent in drums, 13 percent in 1-gallon or
smaller plastic containers, 5 percent in 5-
gallon cans, and 2 percent in returnable
drums.
•Dry formulations — 96 percent in paper
bags; 4 percent in plastic bags.
The most common containers for institu-
tional and industrial pesticides are small plastic
packages and aerosols. Formulators ranked the
most useful sizes as (1) 1-gallon, (2) 5-gallon,
and (3) 55-gallon. Small plastics and aerosols
also dominate the household pesticide field.
The survey ranked household pesticide con-
tainers, in order of usefulness, as (1) 16-ounce,
(2) 1-gallon, and (3) 8-ounce.
A 1988 industry survey report provides an
overview of aerosol container usage. The number
of aerosol pesticide containers generated that
year is estimated to be 233 million — more than
the previous EPA estimate for the total number
of pesticide containers in 1986.
A major change throughout the pesticide in-
dustry in the 1980's was the nearly universal
adoption of plastic as the major packaging type.
In the agricultural market, the major trends in-
clude:
•Increasing use of minibulk containers;
•Decreasing use of 2.5-gallon plastic jugs;
•Increasing interest in the use of smaller
refillable containers;
•Increasing use of water-soluble packaging;
and
•Increasing use of plastic containers for dry
formulations, particularly dry flowables.
One trend in the institutional market is the
increasing number of bag-in-a-box containers.
The industrial market is using more refillable
containers. The major change in household
pesticide containers has been the substitution
of plastic containers for glass bottles.
Requirements Affecting Pesticide Containers
To adequately assess the options available
for improvements in container design, use, and
disposal, it is important to understand the many
relevant standards already in effect, including
regulations, policies, and trade association guide-
lines. The report summarizes the major stan-
dards that affect pesticide containers.
The Department of Transportation (DOT)
has regulations that apply to the transportation
and packaging of hazardous materials, which
include some pesticides. These regulations in-
clude requirements for classification of materi-
als, packaging, hazard communication (i.e.,
package marking, labeling, placarding, and
shipping documentation), transportation, han-
dling, and incident reporting. An estimated 20
to 25 percent of all pesticides previously have
been classified as DOT hazardous materials.
However, this percent most likely will increase
when recent changes to the hazard class defini-
tions become effective. The comprehensive
changes in Docket Number HM-181, published
in December 1990, establish performance-ori-
XL
-------
Executive Summary
ented packaging standards and also contain
other provisions that will affect pesticide con-
tainers, such as modifying the hazard class defi-
nitions.
The United Nations (U.N.) has established
recommended standards for a wide range of
packaging. Several international systems of
regulations have been promulgated on the basis
of the U.N. recommendations, thereby making
the recommendations enforceable. All interna-
tional shipments of hazardous materials have
been required to meet U.N. packaging specifi-
cations since January 1,1991.
The Environmental Protection Agency has
many regulations and policies that affect pesti-
cide containers and bulk pesticide facilities ei-
ther directly or indirectly.
The Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) — Several sets of regu-
lations under the authority of FIFRA deal with
issues relating to pesticide containers:
•EPA will issue container design and residue
removal regulations, as mandated by Con-
gress in section 19 of FIFRA, as amended in
1988. The purpose of these regulations is to
promote the safe storage and disposal of pes-
ticides.
•EPA, through its pesticide labeling regula-
tions, requires that all pesticide labels contain
information about disposal of the pesticide
and the container. Agency notices issued in
1983 and 1984 provide specific information
about the content and format of the required
information.
• EPA, in cooperation with the Consumer Prod-
uct Safety Commission, has implemented
Child Resistant Packaging (CRP) regulations
for containers of residential use pesticides
that meet certain toxicity and size criteria.
•Two sets of regulations affect pesticide
producing establishments, which include
repackagers. These requirements include
the registration of producing establishments,
production reporting procedures, and
recordkeeping.
Also important is EPA's bulk pesticide en-
forcement policy, which sets conditions that
must be met in order to repackage and sell
pesticides in bulk without having to register the
repackaged product. This policy defines ship-
ping and transfer practices for individual con-
tainers of pesticides that hold more than 55
gallons of liquid or 100 pounds of dry product.
The 55-gallon limit established by the origi-
nal 1977 policy had two major implications.
First, containers with capacities 55 gallons or
less could not be refilled under the bulk enforce-
ment policy without obtaining a separate regis-
tration. Second, quantities of pesticide 55 gal-
lons and less could not be placed into containers
larger than 55 gallons under the bulk enforce-
ment policy without a separate registration.
The policy was amended in 1991 and currently
allows the second of these practices (without a
separate registration.)
The Resource Conservation and Recovery
Act (RCRA) — Some RCRA regulations apply to
pesticide containers, bulk pesticide facilities,
container recyclers, and open burning. RCRA
Subtitle C definitions of hazardous wastes en-
compass a number of types of pesticide wastes.
RCRA hazardous waste regulations do not apply
to empty containers, and they provide detailed
specifications for rendering a container "empty."
Rinsates and spill cleanup materials gener-
ated by bulk pesticide facilities, as well as rin-
sates generated by container recyclers, must be
disposed in accordance with applicable RCRA
regulations if the materials are classified as
hazardous wastes. RCRA Subtitle D regulations
prohibit the open burning of solid waste.
Xll
-------
Pesticide Containers A Report to Congress
The Comprehensive Environmental Re-
sponse, Compensation, and Liability Act (CER-
CLA) — CERCLA addresses the cleanup of ex-
isting environmental contamination. The threat
of CERCLA liability is one factor that has caused
many municipal landfills to refuse to accept
pesticide containers, even those that have been
triple-rinsed. Some companies have chosen the
more expensive option of sending empty, triple-
rinsed containers to hazardous waste landfills
instead.
State regulations also play an important role
in the management of pesticide containers and
bulk pesticide facilities. The Agency is prepar-
ing a separate detailed study of state regula-
tions on pesticide storage, transportation, and
disposal. FIFRA prohibits states from impos-
ing any requirement for packaging that differs
from or goes beyond the requirements of FIFRA.
Areas that many states address in their regu-
latory programs include:
•Residue removal procedures — These vary
greatly between states.
•Transfer of pesticides — California requires
the use of closed systems for liquid pesti-
cides in toxicity category I.
•Container collection and return — Many
states have container collection and return
programs. Many are voluntary, but in Maine,
Illinois, and Minnesota these programs are
mandated by state law.
•Open burning — Some states allow open
burning under certain conditions. Some
prohibit open burning in their pesticide
regulations or on the basis of state air pol-
lution laws.
•Bulk storage and handling — State regula-
tions ranging from minimal to comprehen-
sive are either proposed or are already in ef-
fect in about 20 states. The Association of
American Pesticide Control Officials
(AAPCO) has developed model regulations
regarding bulk pesticide facilities.
At the municipal level, pesticide container
disposal options may be limited due to hesi-
tancy on the part of many landfills to accept
rinsed pesticide containers for disposal.
Many industry trade groups have made sig-
nificant contributions to pesticide container man-
agement and container standards. Examples
are the Container Management Goals devel-
oped by NACA and the Voluntary Manufac-
turer Specifications and User Guidelines for
Portable Agri-Chemical Tanks developed by
the Midwest Agricultural Chemicals Associa-
tion (MACA).
Nonrefillable Containers: Use
All nonrefillable containers — whether they
are rigid containers, bags, or other types —
present a number of problems and issues relat-
ing to container integrity: handling, design, and
opening and closure performance among them.
Each variety of rigid nonrefillable container
presents different problems:
Drums — Difficult to manipulate; require a
mechanical transfer system, but openings usu-
ally are compatible with such equipment.
5-gallon cans ~ May be difficult to manipu-
late; usually have a recessed orifice that is sev-
eral inches from the edge, causing pesticide to
be trapped on the top after pouring; flexible
spout may be difficult to operate.
Xlll
-------
Executive Summary
2.5-gallon plastic jugs —-Handles may be
awkwardly placed, complicating rinsing; ori-
fices often drip or "glug"; foil seals are difficult
to remove.
1-gallon plastic jugs — Same issues as 2.5-
gallon jugs; some orifices are so small that they
hamper smooth pouring; built-in measuring
devices, while convenient, may be difficult to
rinse.
A study conducted by EPA in support of this
report included a series of pour tests on a vari-
ety of containers. The tests were designed to de-
termine the feasibility of establishing criteria on
which to judge whether a container can safely
dispense its contents without splashing or "glug-
ging." This approach appears to be technically
sound and may be able to contribute to the long-
term goal of improving container designs to
minimize this problem. The study also showed,
however, that the pouring techniques of users
greatly affect the amount of glugging. In the
short term, it will be important to provide users
with better education on the safe use of individ-
ual container types.
Pesticide bags also present certain problems,
some of which may lead to'unnecessary worker
exposure:
•Opening bags can be difficult. The study
showed that many users do not open bags
in the way that the manufacturer intended.
•Bags may leak pesticide through seams and
sewn edges.
•Bags may retain an unacceptable amount of
residue.
•Bags cannot be reclosed effectively after the
contents have been only partially used.
Other types of containers also have some
major use problems:
Bag-in-a-Box—Structural integrity is a prob-
lem, particularly puncture-resistance and the
ability to withstand a drop. If the outer package
is damaged, the inner bag is difficult to manipu-
late.
Water-soluble packaging — Because these
bags are very moisture-sensitive, they must be
packed in a moisture-proof outer container that
can be reclosed tightly if unused pouches re-
main.
Aerosol cans — Cannot be totally emptied
and cannot be rinsed; their great numbers may
cause them to be an environmental burden after
disposal.
Several types of mechanical transfer sys-
tems (closed systems) are available in both the
agricultural and institutional pesticide markets.
California requires closed systems to be used
for mixing and loading liquid agricultural pes-
ticides in toxicity category I. Users there have
adapted their practices to conform to this re-
quirement. Nationwide, however, a number of
problems have prevented widespread adop-
tion of closed systems. The major difficulty is
that closed systems must be equipped with a
large number of adapters to be compatible with
the variety of container closures currently on
the market. EPA believes that universal accep-
tance of standardized container closures is nec-
essary to increase the use of closed transfer
systems.
Nonrefillable Containers: Residue Removal
Proper residue removal allows the user to
utilize the full volume of pesticide in the con-
tainer and also reduces risks to health and the
environment when the container is disposed.
xiv
-------
Pesticide Containers A Report to Congress
Residue removal procedures currently per-
formed vary according to the type of container
and the market in which it is used. In the
agricultural market, rigid containers usually
are cleaned by triple rinsing, although the use of
pressure rinsing is increasing. In the industrial
and institutional sector, these containers usu-
ally are triple rinsed.
Triple Rinsing — Triple rinsing is used to
clean containers of products designed to be
diluted before application. The rinsate can be
added to the spray tank or other application
device and applied according to label instruc-
tions. EPA, various states, and agricultural
industry groups all specify slightly varying
procedures for accomplishing triple rinsing.
Although triple rinsing is generally recognized
as effective, studies have shown that many end
users do not triple rinse because the procedure
is awkward and time-consuming.
Pressure Rinsing — Rinsing containers with
pressurized water delivered through any of
several different methods is faster and less
awkward than triple rinsing. However, recent
data show that it may be less effective than
triple rinsing. Pressure rinsing generally leaves
a hole in the bottom or side of the container,
which prevents the container from being reused
and can serve as an indicator that the container
was rinsed.
Bags — The container disposal statement on
the pesticide label, which is the only current
EPA procedure for removing residue from bags,
simply directs the user to completely empty the
bag into the application equipment. Several
states have defined procedures for emptying
bags. Most direct the user to shake or tap the
bag; some also advise opening the bag in a
certain way.
Ready-To-Use Products — Rinsing of rigid
containers of ready-to-use pesticides is not rec-
ommended, because the rinsate may create
another disposal problem. There is no applica-
tion mixture to which it can be added. Aerosols,
another form of ready-to-use pesticides, cannot
be opened to remove residue.
The four main variables in residue removal
are:
•The procedure used ~ triple rinsing, pres-
sure rinsing, emptying of non-rinsable con-
tainers;
•The timing of the procedure — performing
the residue removal procedure immedi-
ately upon removal of the pesticide from
the container is important to prevent the
pesticide from drying or caking onto the
container;
•The formulation — the physical properties
of formulations, such as viscosity and solu-
bility, affect residue removal more than the
chemical properties; and
•The container — container material, shape,
and size all affect residue removal.
The Agency analyzed about 10 residue re-
moval studies done between 1972 and 1990.
While they provide a variety of data, each was
done for a different purpose and used different
procedures, so it is difficult to compare their
results or to draw any general conclusions from
them. Therefore, the Agency sponsored new
tests to determine how various container types
and formulations respond when subjected to
uniform triple rinsing and pressure rinsing
procedures. Among the findings were the fol-
lowing:
xv
-------
Executive Summary
•Regardless of the formulation used in the
test, triple rinsing generally removed 99.9999
percent of the residue from 1-, 2.5- and 5-
gallon plastic containers. Final rinses from
the 5-gallon flathead steel can were 10- to
100-fold more concentrated than those from
the other containers.
•In a limited number of tests, the levels of
rinsate retained in a 2.5-gallon plastic con-
tainer and a 5-gallon can after pressure
rinsing were generally 100- to 1,000-fold
greater than that left after triple rinsing.
Several safety concerns became apparent
during the testing:
-Filled 5-gallon containers are difficult to
shake;
•5-gallon metal containers are difficult to
open without splashing pesticide onto the
container surface, and the plastic pieces
that make up the spout are difficult to remove
while wearing gloves;
•Some containers are difficult to reseal suffi-
ciently to prevent leaking during triple rins-
ing; and
•Some container/formulation combinations
drip during the emptying cycle.
An important consideration is the need for a
screening method that can be used in the field to
determine the level of residue removal from
nonref illable containers. Some possible options
include visual inspection, measuring the clear-
ness (turbidity) of the rinsate, and use of immu-
noassay testing kits.
EPA has identified a need for further re-
search in four areas:
•The amount of pesticide adsorbed to and
absorbed into the container;
•The expansion of the data base on resi-
due removal;
•The amount of pesticide removed and re-
leased during recycling; and
•Analytical field testing techniques.
Nonrefillable Containers: Disposal
The options available for disposal of nonre-
fillable containers vary significantly among the
different segments of the pesticide industry.
Institutional/industrial and household nonre-
fillable containers generally are discarded and
enter the municipal solid waste stream. Several
disposal methods are used for agricultural
nonref illables. Some of these methods are envi-
ronmentally responsible; others are not.
Landfilling and open burning are the most
commonly used methods. Other methods in-
clude open dumping, burying at the use site,
and recycling.
Open dumping ~ Although it is illegal, open
dumping is a common practice. It poses public
health risks from pesticide residues in surface
water, ground water, and soils.
On-site burial ~ Farmers still use on-site
burial as a disposal method, and it is allowed by
some states, with some restrictions. In general,
however, concerns about soil and water con-
tamination make it a practice that is not encour-
aged.
Landfilling — Disposing of pesticide con-
tainers in a landfill is the primary disposal
method in most states. However, many landfills
refuse to accept even triple-rinsed pesticide
containers because the landfill operators are
concerned about space, ground water contami-
nation, and liability.
Open burning — Although it is banned under
RCRA Subtitle D, open burning is a widely used
disposal method. Burning bags and plastic con-
tainers in the field where the pesticide was used
xvi
-------
Pesticide Containers - A Report to Congress
is convenient, cheap, and quick. Two studies
are currently being done to characterize the
risks associated with burning pesticide contain-
ers.
Other options — The reuse of nonrefillable
pesticide containers to hold other substances is
not a good practice and is generally prohibited
by the label. Returning containers to dealers
simply shifts the disposal burden. Storing con-
tainers on site can create hazards.
Recycling — Recycling, which includes col-
lecting containers, processing the material for
the market, and reusing the material for new
products, is still in the developmental stage.
Recycling cannot occur unless a market exists
for the recyclable materials.
Steel containers can be reclaimed and used
in steel production; however, some facilities are
reluctant to accept pesticide containers.
Almost all plastic containers for pesticides
are made from high density polyethylene
(HDPE). Much research and attention is being
focused on the recycling of HDPE. Recycled
HDPE can be used to make other objects, in-
cluding pesticide containers, and it also has
potential as an energy source. Barriers to recy-
cling include the possible presence of pesticides
in the plastic, the possibility that recycling may
lower the quality of the plastic, and a lack of
economic incentive.
Collection programs — The number of pesti-
cide container collection and recycling programs
is growing rapidly. These programs differ
greatly. For example, some programs are
mandatory; others are voluntary. In some pro-
grams, containers must be taken to a central site;
in others, the program operators collect the
containers from the users. In every program,
containers must be rinsed and are inspected to
verify rinsing. Collection programs are gener-
ally attractive to end users, because they pro-
vide an inexpensive and fairly convenient solu-
tion to the leftover container problem. Some,
however, such as deposit and refund programs,
may seem bothersome or time-consuming.
Refillable Containers: Use
Refillable pesticide containers are used pri-
marily in the agricultural market. In addition to
reducing the number of containers requiring
disposal, a major advantage of refillable con-
tainers is that they greatly decrease worker
exposure to the pesticide. However, refillables
present a number of problems and issues not
present with nonrefillables.
The use of minibulk containers presents
several important issues:
•Ownership — Minibulks are owned by reg-
istrants, distributors, dealers, and farmers,
with dealers owning the most. Owning the
containers or leasing them from registrants
gives dealers a high degree of control over
container integrity and subsequent sale of
the pesticide. Most farmer-owned and some
dealer-owned minibulks are inexpensive,
poor-quality containers that are a cause for
concern.
•Refilling — EPA's bulk pesticide enforce-
ment policy allows only registrants to refill
containers that have a capacity of 55 gallons
or less. This requirement is a barrier to the
development of smaller minibulks, which
the industry believes to be essential to the
future of pesticide container management.
•Transportation — Minibulks are relatively
large and many end users do not have equip-
ment adequate for moving them. Also,
minibulks can present a safety hazard if
they are not tied down during transport.
XVil
-------
Executive Summary
•Container construction — Minibulks must
be durable and rugged enough to with-
stand repeated transportation, rinsing, and
refilling. To prevent spills in case of dam-
age to the container, vulnerable hardware
must be protected against breakage, or check
valves must be used. The design features of
some minibulks make them difficult to empty
completely and difficult to drain. Mini-
bulks require a large amount of storage
space; some are not designed to stack at all,
and others cannot be stacked more than two
high. Some minibulks can be adversely
affected by sunlight. Both MACA and the
U.N. recommendations suggest a 5-year
lifetime for plastic minibulks.
•Container return — Dealers use a variety of
incentives, monetary and otherwise, to en-
courage users to return minibulks for refill.
•Associated hardware — Because of their
large size, minibulk containers need addi-
tional equipment — such as pumps, meters,
and hoses — to transfer the pesticide from
the container to the application or mix tank.
Flowmeters cause the most concern; their
accuracy is distrusted, they need frequent
calibration, and they have technical limita-
tions.
•Standardization — Some standardization of
minibulk container connections could have
two major advantages: it could ease the
burden on dealers, and it could help end
users become familiar with the equipment.
However, standardization is a complex issue
involving many manufacturers whose pro-
prietary rights and other economic inter-
ests may cause them to resist such an effort.
Small volume returnable containers are
smaller than minibulks, are generally made of
different materials than minibulks, and are used
not only in the agricultural industry but also in
the pest control business.
•Ownership—SVR's are owned solely by the
registrants. Because their capacities are less
than 55 gallons, they can be refilled only by
the registrant. Dealers have a much smaller
role with SVR's than they do with mini-
bulks.
•Transportation — SVR's are not usually trans-
ported with any hardware attached other
than the original valve. Their smaller size
makes them easier to transport than mini-
bulks.
• Container construction ~ Because SVR's are
constructed of stainless steel, container life-
time and the effects of sunlight are not
pressing issues. Their size makes them
much easier to handle than minibulks. The
valve on the top of some containers pre-
sents a risk of leakage in case of damage.
•Container return ~ The return of SVR's is
more difficult and expensive than the re-
turn of minibulks because SVR's must be
passed all the way back to the registrant to
be refilled.
•Associated hardware ~ Most SVR's have a
dry break coupler built into the container,
and most also have a one-way valve.
•Standardization — General standardization
issues for SVR's are similar to those for
minibulks. For SVR containers, there is a
significant opportunity to standardize the
opening between the valve and the hose
that leads to the pump.
Bulk containers present different issues be-
cause they are generally much larger than mini-
bulks and are used for the stationary storage of
pesticides.
•Ownership — Most dealers own the bulk
containers themselves; others lease the con-
tainers from pesticide manufacturers.
•Container construction — Most bulk con-
tainers are strong and very durable. Cone-
xviu
-------
Pesticide Containers - A Report to Congress
bottomed bulk containers drain more eas-
ily than flat-bottomed tanks, but the latter
distribute the weight of the tank more evenly.
•Associated hardware — Bulk containers have
pumps, meters, valves, and hoses to trans-
fer and measure the pesticide. Because the
containers are stationary, the hardware can
be secured. Some dealers have experienced
problems with leaky fittings on bulk con-
tainers.
Dry refillable containers include refillable
bags and rigid refillable containers. The bags
are currently used mainly by dealers, who re-
turn them to registrants for refilling.
Refillable Containers: Residue Removal
Residue must be removed from refillable
containers at two different times in their life
cycle — before refilling, which may occur many
times, and before disposal. Removing residue
before refilling prevents cross-contamination,
removes dried material, and renders usable
those containers whose previous contents are
unknown. Removing residue before disposal
minimizes the impact on the environment and
reduces worker exposure during disposal.
The regulations in 40 CFR Part 158, Data Re-
quirements for Registration, define the limits
for cross-contamination in Subpart C, Product
Chemistry Data Requirements. Any cross-con-
tamination is a violation.
Proper rinsing and minibulk container de-
signs that provide adequate draining are essen-
tial to preventing cross-contamination.
• Under current debate is the idea of when
containers can be refilled. Most of the debate
focuses on minibulk containers and involves
discussion by the states, EPA, dealers, and reg-
istrants. With the narrow definition of dedi-
cated containers, a minibulk could only be re-
filled with the same pesticide. However, most
policies proposed by EPA and the states that
describe allowable refilling practices permit
minibulks to be refilled with the same pesticide
or with another pesticide after a thorough clean-
ing.
Residue removal procedures vary according
to the type of container.
Minibulk containers ~ Minibulk containers
that are owned by the registrant or dealer usu-
ally are rinsed only by the refillers. To mini-
mize the chance for cross-contamination, most
of these containers have one-way valves that
prevent the user from introducing anything
into the container. The residue removal proce-
dure recommended for minibulks is pressure
rinsing through the dispensing opening. Holes
are not put into these containers as in pressure
rinsing nonrefillable containers.
Small volume returnable containers — All
SVR's are returned to the registrant for residue
removal and refilling. SVR's can be rinsed in
several ways depending on the design of the
container. Some must be cleaned individually
by pressure rinsing; others are designed to be
rinsed and filled on an automatic line.
Bulk containers ~ When a bulk container is
to be refilled with a different pesticide than it
previously held, the dealer pressure rinses the
container.
Dry refillable containers — Because these
containers usually are dedicated to one prod-
uct, they normally are not cleaned before refill-
ing.
The management of rinsates from the clean-
ing of refillable containers is an important issue
for dealers, many of whom handle large vol-
xix
-------
Executive Summary
umes of rinsates. In some instances, the legal
management options are fairly limited.
Direct application or use as a diluent — Al-
though a rinsate may be applied directly or
used as a diluent in a pesticide application if
certain conditions are met, this option poses
difficult logistical problems for dealers and other
container rinsers, especially those who are not
in the business of applying pesticides.
Treatment system — The rinsate can be treated
with an individually designed or commercially
available treatment system. One such commer-
cial system includes filtration, oil removal,
ozonation, and activated carbon adsorption. In
most systems, the treated rinsate is stored and
reused as rinse water.
Other disposal — If the rinsate is considered
a waste under applicable law, it must be dis-
posed in accordance with applicable federal,
state, and local solid and hazardous waste and
water quality regulations.
Ref illable Containers: Disposal
Although refillable containers have a rela-
tively long lifetime, at some point they must be
disposed. Bulk containers, SVR's, and dry ref il-
lables currently pose a relatively small disposal
problem. The disposal issues primarily center
on minibulks.
Removing minibulk containers from service
when they are old or unsound is easier if they
are owned by a dealer, distributor, or registrant
than if they are owned by an end user. End
users also have fewer available disposal op-
tions.
Minibulk containers can be landfilled, but
they face the same liability, expense, and nonac-
ceptance problems as other types of pesticide
containers. To reduce the large volume of space
needed to landfill minibulks, they usually are
cut into smaller pieces with equipment such as
a chain saw. Shredding the pieces would re-
duce the volume even more.
Although some dealers have reported burn-
ing plastic minibulks, open burning is not a
common or recommended practice. Many
minibulk containers are simply stockpiled, of-
ten in unprotected outdoor locations, until dis-
posal options become available.
Burning for energy recovery is an increas-
ingly popular minibulk disposal method prac-
ticed by registrants. High-temperature com-
bustion achieves a high degree of destruction of
the plastic resin.
Recycling of plastic minibulk containers is
feasible, but more research is needed on the
amount of pesticide absorbed into the walls of
the containers and on demonstrating the feasi-
bility of recycling minibulk containers con-
structed of different kinds of plastic. Steel
minibulks can be recycled in the same way as
smaller steel containers.
Several registrants are developing collec-
tion programs for their old minibulk containers
with the intention of incinerating them for en-
ergy recovery or recycling them.
Bulk Storage Facilities
A bulk storage facility is a location where
there are one or more bulk storage tanks and
where the pesticide stored in the tanks is re-
packaged into smaller containers. Bulk storage
facilities are usually dealers, although they also
can be distributors. Because they do repackag-
ing, these facilities are pesticide-producing es-
tablishments as defined by FIFRA.
Issues that arise in connection with bulk
storage facilities are closely related to the issues
-------
Pesticide Containers A Report to Congress
and problems of ref illable containers, since one
of the primary functions of bulk storage facili-
ties is to repackage pesticides into refillable
containers.
Several kinds of pesticide releases may oc-
cur at bulk storage facilities: routine leaks and
drips from storage containers; spillage during
the transfer of pesticide; release of pesticide-
containing rinsates into a collection system; and
accidental, large spills from bulk containers.
The environmental effect of these releases
can be minimized by good management and
maintenance practices and by the use of con-
tainment structures. The two primary types of
containment structures are (1) secondary con-
tainment around bulk containers, which usu-
ally consists of a concrete floor and walls and (2)
concrete containment pads, used in areas where
operations such as refilling or rinsing rninibulks
take place.
Five states have comprehensive bulk stor-
age regulations in effect Three states have pro-
posed comprehensive bulk storage regulations,
seven have minimal bulk storage or handling
regulations in effect, and at least five others are
drafting bulk storage regulations.
Options To Encourage Refillable Containers
In order to allow for the safe transition toward
more refillable containers, the following best
management practices should be considered:
•Refillable containers to be properly secured
during transport;
•Refillable containers to meet minimum stan-
dards for container strength and durability;
•Protection of hardware attached to refil-
lable containers or the use of check valves;
•Regular, mandatory inspection of refillable
containers;
•One-way valves and tamper-evident de-
vices to reduce the dealer's uncertainty about
the container's contents;
•Containers to be refilled according to ac-
ceptable refilling practices;
•Secondary containment structures around
stationary bulk storage containers; and
•Containment pads at bulk storage facilities.
Bulk pesticide enforcement policy ~ The
bulk pesticide enforcement policy could be modi-
fied to allow refillable containers smaller than
55 gallons to be refilled at all pesticide produc-
ing establishments (without a separate registra-
tion).
This modification could lead to the develop-
ment of new types of refillable containers, i.e.
smaller refillables that could be managed like
rninibulks.
Other options — Other options that may be
useful but would require further study and/or
enactment of additional legislative authority
include:
•Fee system -- A fee could be placed on each
nonrefillable container, except for water-
soluble packaging, to make refillable con-
tainers more attractive economically and
to provide funds for collection and recy-
cling programs for the nonrefillable con-
tainers.
•Deposit and return programs — EPA could
establish a mandatory deposit and return
program applicable to all nonrefillable pes-
ticide containers except water-soluble pack-
aging. Users would pay a deposit at the
time of purchase and receive a refund when
the container was returned, properly rinsed,
to a central collection point.
•Require use of certain containers — The
Agency could require that a certain per-
xxi
-------
Executive Summary
cent of a registrant's product line be sole in
either refillable containers or water-soluble
packaging.
Options To Facilitate Residue Removal
One of the congressional mandates was to
develop options concerning pesticide formula-
tions that would facilitate the removal of pesti-
cide residues from containers. The study re-
vealed, however, that effective residue removal
depends not only on the formulation, but also
on other variables. These options address these
combinations of variables.
Encourage refillable containers ~ The in-
creased use of refillable containers would re-
duce the need for end users to perform residue
removal procedures.
Residue standards ~ EPA could set per-
formance standards for registrants concerning
the maximum amount of residue that can re-
main in a container after a registrant-prescribed
residue removal procedure has been performed
for each particular container/formulation com-
bination.
Timing of the procedure — Through regula-
tions or through label language, EPA could
require that the user perform the residue re-
moval procedure immediately upon emptying
the pesticide from the container.
Standard residue removal procedures—The
definitions of triple rinsing and pressure rins-
ing could be standardized throughout the user
community.
Educational programs — Users could be tar-
geted with a wide-ranging educational pro-
gram about the importance of and proper tech-
niques for residue removal.
Other options — Other possible options
include:
•Encouraging water-soluble packaging —
Because this option would involve a fee
system for nonref illable, non-water-soluble
containers, further legislative authority may
be needed.
•Formulation standards — EPA could pro-
hibit the marketing of formulations that
hinder residue removal. This option is
technically limiting, it ignores the other
variables involved, and it would require
data that do not currently exist.
•Container regulatory standards — EPA could
establish container specifications, prohibit
certain design features, or prohibit certain
container designs. Additional research
would be necessary, and this approach is
somewhat technically limiting.
Options To Reduce the Number of Containers
Requiring Disposal by Increasing Use of Bulk
Storage Facilities
The options outlined above for encouraging
the use of refillable containers also would serve
to increase the use of bulk storage facilities,
since the primary function of bulk facilities is to
repackage pesticides into refillable containers.
The modification of the bulk pesticide enforce-
ment policy is the one option that could be im-
plemented now.
Other ways to reduce the number of contain-
ers requiring disposal include encouraging the
use of water-soluble packaging and increasing
the number of containers that are recycled. One
option that could increase recycling is to require
containers to be made of recyclable materials.
xxii
-------
Pesticide Containers A Report to Congress
Conclusion
EPA's overall pesticide container manage-
ment strategy includes: (1) promulgating con-
tainer design and residue removal regulations,
and (2) implementing the options discussed
above. The strategy has three long-term goals:
•To have the pesticide industry consider the
pesticide formulation and its container as a
single entity;
•To provide leadership in the area of pesti-
cide containers, encourage further coopera-
tion and dialogue, and monitor pesticide
container trends; and
•To encourage the development and use of
pesticide containers in a way that reduces
risks to human health and the environment
with the least possible cost and burden on
the public.
XXlll
-------
Pesticide Containers A Report to Congress
Chapter 1
Introduction
Congress reauthorized the Federal Insecti-
cide, Fungicide, and Rodenticide Act (FIFRA)
in 1988. Section 19 of FIFRA requires EPA to ad-
dress the pesticide container issue in three ways:
to promulgate container design regulations, to
promulgate residue removal regulations, and
to conduct a study and report the results to Con-
gress. Specifically, the study under section
19(g) is required to address options to encour-
age or require:
•The return, refill, and reuse of pesticide
containers;
•The development and use of pesticide for-
mulations that facilitate the removal of pes-
ticide residues from the containers; and
•The use of bulk storage facilities to reduce
the number of pesticide containers requir-
ing disposal.
In conducting the study, EPA was directed
to:
•Consult with the heads of other interested
federal agencies, state agencies, industry
groups, and environmental organizations;
and
•Assess the feasibility, costs, and environ-
mental benefits of encouraging or requir-
ing various measures or actions.
Upon initiating the study, EPA realized that
little formal investigation has been done on the
topic of pesticide containers and very little
published material exists. Therefore, EPA's
study and this report have been forced to rely
heavily on informal communications and corre-
spondences. Four open meetings were held
with representatives from federal agencies, state
agencies, industry groups, environmental or-
ganizations, and other interested parties. Most
of the information in this report has been gath-
ered through these meetings as well as addi-
tional meetings, personal communications, and
trips. While the informal collection of informa-
tion and data may not be the preferred ap-
proach, EPA believes that considerable effort
was made to contact the people who are most
knowledgeable on the subject of pesticide con-
tainers.
EPA has interpreted the directive for this
study broadly, as evidenced by the wide range
of topics covered in this report. At the begin-
-------
Chapter 1 Introduction
ning of the study, EPA distinguished two major
types of pesticide containers - nonrefillable and
ref illable - with substantially different concerns
and issues for each type. Further investigation
revealed that the topics addressed in the FIFRA
directives, including residue removal and dis-
posal, are closely related to factors such as con-
tainer use and handling practices. Because of
this interrelationship, EPA determined that a
comprehensive study incorporating all of the
stages in the life cycle of pesticide containers
would be the best and most useful approach.
The goals of both the study and the report
are to:
•Satisfy the requirements of Congress in
section 19 of FIFRA;
•Summarize and consolidate the existing
knowledge and data on pesticide con-
tainers and current practices into one docu-
ment;
•Develop and present new data on residue
removal and container dispensing per-
formance;
•Provide background information and data
for EPA in the development of the con-
tainer design and residue removal regu-
lations also mandated in section 19 of
FIFRA;
•Discuss EPA's long-range container man-
agement goals;
•Stimulate discussion of pesticide container
issues between industry groups, federal
and state agencies, and environmental
organizations;
•Recommend solutions to existing or po-
tential problems; and
•Point out topics that require further study
or research.
An important concept that emerged from
the study was that of considering a pesticide
formulation and its container together as a single
entity, which is not a common practice today.
Generally, formulating and packaging a pesti-
cide are separate projects done by different
groups within a company or by different com-
panies altogether. In practice, the interaction
between a pesticide and its container affects
many situations, including emptying, remov-
ing residue, and disposing of the container. The
philosophy of viewing the pesticide formula-
tion and container as a single entity will be
stressed throughout this report.
Another important theme throughout the
report is the many trade-offs involved with
revising the current pesticide container prac-
tices. For example, the use of refillable contain-
ers and bulk storage facilities reduces the number
of containers requiring disposal, but increases
the risks associated with large volume storage
and handling. EPA wants to avoid simply
replacing one problem (i.e., container disposal)
with another one (i.e., larger spills or accidents).
Therefore, certain recommendations, such as
minimum standards for the strength of refil-
lable containers, are necessary as a part of the
options to encourage the use of refillable con-
tainers and bulk facilities.
The first several chapters of this report pro-
vide background information on the pesticide
industry and a general discussion of pesticide
formulations and containers. Chapter 5 - Re-
quirements Affecting Pesticide Containers —
addresses the various "forces" on pesticide
containers^ including federal and state regula-
tions, applicable policies, and trade group or
industry standards. The next six chapters dis-
cuss pesticide container issues and current
practices regarding use, residue removal, and
disposal. Specifically, Chapters 6 through 8
address these topics for nonrefillable contain-
ers and Chapters 9 through 11 address refil-
lable containers. Chapter 12 describes bulk
storage facilities. Chapter 13 presents the op-
tions required by FIFRA section 19(g) includ-
ing recommended requirements necessary to
safely implement these options. The final
chapter discusses long-range pesticide con-
tainer management goals, summarizes the
conclusions of the study, and suggests areas
for further study.
-------
Pesticide Containers A Report to Congress
Chapter 2
The Pesticide Industry
2.1 Introduction
The initial step in studying pesticide con-
tainers is to understand the pesticide industry.
This chapter addresses several aspects of the
pesticide industry essential to understanding
the detailed discussion of containers, including:
•The definition of the term pesticide;
•The different pesticide markets; and
•The pesticide distribution chain within each
of the major markets.
2.2 Definition of "Pesticide"
The term "pesticide", as defined by the Fed-
eral Insecticide, Fungicide, and Rodenticide Act
(FIFRA), includes a broad range of substances.
Specifically, section 2(u) of FIFRA in part de-
fines a pesticide as "(1) any substance or mix-
ture of substances intended for preventing,
destroying, repelling, or mitigating any pest,
and (2) any substance or mixture of substances
intended for use as a plant regulator, defoliant,
or desiccant." Section 2(t) of FIFRA defines a
pest as "(1) any insect, rodent, nematode, fun-
gus, weed, or (2) any other form of terrestrial or
aquatic plant or animal life or virus, bacteria, or
other microorganism (except viruses, bacteria,
or other microorganisms on or in living man or
other living animals) which the Administrator
declares to be a pest under section 25(c)(l)."
In other words, the term "pesticide" covers
more than the common perception of insecti-
cides and herbicides. Other substances incor-
porated in the definition of pesticide are antimi-
crobials, including disinfectants, sanitizers, and
anti-fouling agents. A list of representative
classes of pesticides is given in Table 2-1.
2.3 Pesticide Markets
Because of the broad scope of the term pes-
ticide, it is useful to classify pesticides accord-
ing to their markets. This report distinguishes
between the following three major markets:
-Agricultural;
•Institutional and industrial; and
•Household.
There are no clear-cut, distinct divisions be-
tween these markets based on the chemicals
used. A single active ingredient may serve
several different markets. Therefore, it is easier
and more useful to define the industry by the
-------
Chapter 2 The Pesticide Industry
Table 2-1
Representative Classes of Pesticides
Class
Target Pest
Acaricide
Algicide
Attractant
Aviclde
Bactericide
Defoliant
Desiccant
Fungicide
Growth regulator
Herbicide
Insecticide
Miticide
Molluscicide
Nematicide
Piscicide
Predacide
Repellents
Rodenticide
Silvicide
Sllmicide
Sterilants
Mites, ticks
Algae
Insects, birds, other animals
Birds
Bacteria
Unwanted plant leaves
Unwanted plant tops
Fungi
Insect and plant growth
Weeds
Insects
Mites
Snails, slugs
Nematodes
fish
Carnivorous mammals
Insects, birds, other animals
Rodents
Trees and woody vegetation
Slime molds
Insects, other animals
SOURCE: Minnesota Department of Agriculture, Rinse and Win Brochure,
1989.
markets served rather than by the chemical
content of the pesticides. These markets have
significant differences in the pesticide distribu-
tion chain and the end uses, as well as varying
container use, residue removal, and disposal
practices.
The pesticide market in the United States,
broken down by product type and sector, is
summarized in Figure 2-1. The classification
into these three markets is made for the pur-
poses of this report only and is not intended to
alter or amend any existing definitions in EPA
guidance documents or regulations.
The three major markets: agricultural, insti-
tutional/industrial (I&I), and household will
be discussed individually. There are many
other specialty areas which will not be covered
in detail in this report. Examples of specialty
areas include: stored grain products such as
feed stored in grain elevators, seed treatment,
pest control operations, e.g., the use of termiti-
cides, cattle shed treatment, ornamental, for-
estry, parks, golf courses, and utility rights-of-
way.(l) A discussion of these specific areas is
beyond the scope of this report.
2.4 Agricultural Pesticides
The agricultural market dominates the pes-
ticide industry in terms of the pounds of pesti-
cide sold and with respect to the amount of
regulatory and public attention focused on the
industry. It is also an extremely diverse market.
Pesticide management practices vary substan-
tially between regions of the country and some-
times even between counties of the same state.
It is difficult to make broad generalizations
about this market. For example, there are vast
differences between the Midwest's large fields
of corn and soybeans and California's 1-acre
plots of specialty vegetables. This diversity is
an important distinction which separates agri-
culture from the other major markets, which
tend to be more homogenous nationwide.
Despite its diversity, a general description
of the largest part of the agricultural market can
be generated. First, the U.S. agricultural pesti-
cide industry is characterized by the predomi-
nance of a 'few very large companies: Mon-
santo, Ciba-Geigy, BASF, DuPont, Mobay,
DowElanco, American Cyanamid, and Stauffer
(now part of ICI). In 1988,130 companies pro-
duced pesticide active ingredients; 19 of these
held 85 percent of the U.S. pesticide market.
Second, 75 percent of U.S. annual agricultural
expenditures are for pesticide products for use
on corn, soybeans, cotton, deciduous fruits, and
nuts. (2)
A knowledge of the distribution chain in the
agricultural chemicals business is necessary to
understand the factors that influence the selec-
tion, use, and final disposition of pesticide
containers. The following list provides some of
the steps a registered pesticide must go through
-------
Pesticide Containers A Report to Congress
Figure 2-1
The Volume of Pesticide Active Ingredient Used in the U. S. by Class and Sector in 1988
Million Lbs. A.I.
800
700
600
500
400
300
200
100
Institutional/
Agriculture Industrial
Herbicides (HH Insecticides I I Fungicides
Home & Garden
Other
Total
SOURCE: U.S. EPA, Pesticide Industry Sales and Usage, 1988 Market Estimates, December 1989.
in order to reach the end user:
•Registrant (generally includes manufactur-
ers and formulators);
•Manufacturer;
-Formulator;
•Distributor;
•Dealer; and
•User (farmer, commercial ground applica-
tor, commercial aerial applicator).
A brief description ofthe purpose or process
involved with each step is given in Table 2-2.
Additionally, the distribution channels are
depicted in a flow diagram in Figure 2-2.
This is a general depiction of the distribution
chain, although in many cases several steps are
performed by one entity. Large companies
might register, manufacture, and formulate their
pesticides. Some distributors also formulate
several pesticides. Additionally, a single facil-
ity might function as a distributor, dealer, and
commercial applicator. (3)
Another important point is that the con-
tainer management issues faced by the user
depend on the type of user. For example, the
number of containers required, as well as the
size or type of containers used depends on the
size of the application area. The available dis-
-------
Chapter 2 The Pesticide Industry
Table 2-2
Steps in the Pesticide Distribution Chain
Chain
Purpose
Registrant
Manufacturer
Formulator
Distributor
Dealer
Registers the pesticide formulation with EPA; involves a long expensive
research and development process to develop the pesticide, produce the
data required for registration process. Manufacturers and formulators must
obtain a registration.
Synthesizes the active ingredient from raw materials.
Produces the pesticide formulation by combining the active ingredients)
with other substances, including surfactants, clays, powders, and solvents;
involves mixing or blending operations.
Acts as a "middle man"; buys pesticide from the registrant/manufacturer/
formulator and sells to dealer.
Sells the pesticide to the users.
posal options and applicable regulations are
different for farmers and commercial applica-
tors.
A crucial point regarding the distribution
chain is the difference between nonrefillable
and refillable containers. Nonrefillable con-
tainers are used only once. A nonrefillable con-
tainer proceeds through the distribution chan-
nels to the end user, who disposes of the con-
tainer. Containers intended to be refilled must
go back up the distribution chain to the party
(dealer, distributor, or registrant) who is au-
thorized to refill them.
2.5 Institutional and Industrial Pesticides
The institutional and industrial (I&I) mar-
ket, as defined for the purposes of this report, is
a smaller, more specific segment of the pesticide
industry. Many I&I products, such as antimi-
crobials, generally are not perceived as pesti-
cides by the general public. The I&I market is
estimated to exceed $200 million, with about 45
percent to health care institutions. (4)
The distinction between industrial and in-
stitutional pesticides is based on the setting in
which the pesticide is used. In many cases, the
same formulation is used in different types of
facilities. Typical institutional end users in-
clude personnel in hospitals, nursing homes,
schools, restaurants, hotels, and contract clean-
ing businesses which service stores, apartment
houses, office buildings, and garages. (5) Typi-
cal industrial end users include those personnel
in food processing plants and breweries. Other
industrial pesticides are fungicides used in metal
processing plants, paints, wood preservatives,
adhesives, and metalworking fluids as well as
slimicides used in cooling towers, paper mills,
and oil wells. (6,7)
The I&I market differs from the agricultural
market in several significant ways. First, the
application of I&I products is generally more
uniform across the country. For disinfectants,
hospitals in various parts of the United States
have the same concerns and needs. However,
the use of pesticides for wood preservation and
in cooling towers varies according to the cli-
-------
Pesticide Containers A Report to Congress
Figure 2-2
Distribution Channels for Pesticides
BASIC PESTICIDE MANUFACTURERS
IN-HOUSE FORMULATORS
IN DEPENDANT
FORMULATORS
CONSUMER
COMPANIES
DISTRIBUTORS
Y Y
DEALERS/CCOPS
FORMULATOR/
DISTRIBUTORS
>
DPS
f
>
f V
RETA
FOOD BROKERS, ETC.
y w> f
INDUSTRIAL &
INSTITUTIONAL SUPPLIERS
Y > f
AGRICULTURAL USERS
HOUSEHOLDS
INSTITUTIONAL
USERS
INDUSTRIAL
USERS
COMMERCIAL
USERS
GOVERNMENT
USERS
SOURCE: Based on a diagram in: B. Omilinsky, Formulogics, letter to N. Fitz, U.S. EPA, Office of Pesticide Programs,, July 26, 1990.
7
-------
Chapter 2 The Pesticide Industry
mate. (8) Second, applications of I&I pesticides
generally involved smaller quantities of prod-
uct and smaller target sites than applications of
agricultural chemicals. Third, I&I products are
usually less expensive per unit volume than ag-
ricultural pesticides because they are more di-
luted.
There are also differences between the I&I
and agricultural distribution chains. A major
difference is that fewer I&I companies both
manufacture and formulate their pesticides. In
other words, companies who primarily formu-
late pesticides are more predominant in the I&I
market. Another substantial difference is the
complexity of the path between the formulator
and end user, as well as the lack of an entity in
the I&I market equivalent to an agricultural
dealer. This can be seen in Figure 2-2, where
there are many potential routes from the basic
manufacturer to the institutional and industrial
users. For example, institutional formulators
may sell directly to large end users such as hos-
pitals. On the other hand, institutional formula-
tors may use distributors or janitorial supply
houses to indirectly sell to smaller or out-of-
state users. Institutional distributors usually
sell general maintenance products such as clean-
ing supplies and non-pesticide cleaners as well
as the sanitizers and disinfectants. Similarly,
formulators of industrial pesticides may sell
directly to the end user or indirectly through a
warehouse. (9)
Most of the containers used in the I&I mar-
ket are nonrefillable and therefore are disposed
by the end users. However, there is a trend
toward the use of refillable containers for some
industrial pesticides. (10)
2.6 Household Pesticides
The household pesticide market is loosely
defined for the purposes of this report to in-
clude those pesticide products that are com-
monly used in or around the home. The follow-
ing are representative kinds of household pesti-
cides: rodenticides, insect repellents, lawn and
gar den pesticides, disinfectants and other pesti-
cidal cleaners, insecticides for pets and house-
hold pests, herbicides, fertilizers with herbi-
cides/insecticides, and insect baits and traps.
In general, household pesticides are packaged
in smaller containers than those used in the
other markets. Some household pesticides such
as lawn and garden products are seasonal, while
the demand for others remains fairly constant
throughout the year.
Three companies have a major presence in
the household pesticide market. These compa-
nies and the type of pesticide products they
make include Ortho/Chevron (lawn and gar-
den), S.C. Johnson (disinfectant/insecticide
aerosols and other insect repellents and traps),
and O.M. Scott (pesticide/fertilizer or "weed
and feed" lawn products).
The household pesticide distribution chain
is similar to the I&I chain and can be seen in
Figure 2-2. The main difference between the
household market and the others is that the end
user, the household consumer, can purchase
household pesticides at a wide variety of com-
mon retail establishments, including grocery
stores and stores such as K-Marts and Wai-
marts. The formulator can sell directly to the
retail stores or indirectly through a distributor
warehouse.
8
-------
Pesticide Containers - A Report to Congress
Endnotes
1. Omilinsky, B., Formulogics, letter to N. Fitz,
U.S. EPA, Office of Pesticide Programs, July
26,1990.
2. Calderoni, P., Pesticide Industry Overview,
Chemical Handbook - Marketing Research
Report, No. 573.1000A, June 1988.
3. U.S. EPA, 1989 Trip Report to California,
Oregon, Washington, September 16-22,
1990, U.S. EPA, Office of Pesticide Programs,
October 1990.
4. DiFazio, J., Chemical Specialties Manufac-
tuers Association, facsimile transmission to
U.S. EPA, Office of Pesticide Programs, No-
vember 30,1990.
5. International Sanitary Supply Association/
Research Triangle Institute/U.S. EPA, meet-
ing summary, Research Triangle Institute,
July 24,1989.
6. U.S. EPA, Trip Report to Chicago, July 18-
20,1990, U.S. EPA, Office of Pesticide Pro-
grams, July 1990.
7. Rohm and Haas/Nalco/U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide Pro-
grams, October 16,1990.
8. Krygsman, A., Troy Chemical Corporation,
personal communication to U.S. EPA, Office
of Pesticide Programs, November 17,1990.
9. U.S. EPA and MITRE Corporation, Metric
Division, The Supply and Use Patterns of
Disinfectants and Sanitizers at Selected Sites,
January, 1983.
10.Rohm and Haas/Nalco/U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide Pro-
grams, October 16,1990.
-------
Pesticide Containers A Report to Congress
Chapter 3
Formulations
3.1 Introduction
The f ollowing discussion will provide a brief
description of the formulations that are avail-
able to the various market segments described
in the previous chapter. The distinctions among
formulations are not intended to alter or amend
the definitions of formulation classes in EPA
guidelines or regulations. Rather, the discus-
sion is intended to help explain the interaction
between containers and formulations.
3.1.1 Definitions
The following definitions are included to
provide a basic understanding of pesticide for-
mulations^!)
•Adjuvant: An adjuvant is used in a formu-
lation to aid in the pesticide application or to
improve the effectiveness of the pesticide.
The term includes such materials as wetting
agents, spreaders, emulsifiers, dispersing
and foaming agents, foam suppressants, and
penetrants. A spray adjuvant may contain
one or more surfactants, solvents, solubiliz-
ers, buffering agents, and stickers needed to
formulate a specific type of adjuvant.
•Active Ingredient (a.L): Ingredient that
provides the pesticidal action in a formula-
tion, i.e., that prevents, destroys, repels, or
mitigates any pest, or functions as a plant
regulator, defoliant, or desiccant.
•Diluent: "An ingredient used to reduce the
concentration of an active material to achieve
a desirable and beneficial effect. "(2)
•Inert: An ingredient intentionally added to
a formulation other than the active
ingredient(s). Examples of inerts found in
pesticide formulations include: solvents,
emulsifiers, wetting agents, carriers, and
conditioning agents. Excipient is a term
also used by the industry for inert.
•Pesticide Formulation: Any substance or
mixture of one or more active ingredients
and inerts which is used to mitigate or
control pests.
•Solvent: "A substance capable of dissolv-
ing another substance (solute) to form a
uniformly dispersed mixture (solution) at
the molecular or ionic size level." (3)
•Surfactant (Surface Active Agent): A sub-
stance which allows two otherwise immis-
cible ingredients to mix with each other.
Surfactants adsorb onto the boundary be-
ll
-------
Chapters - Formulations
tween the liquid layers, thereby reducing
the surface tension and allowing the two in-
gredients to mix. These materials also re-
duce surface tension, allowing spreading of
the liquid over the surface.
•Technical Grade of Active Ingredient: A
material containing an active ingredient:
(1) which contains no inert ingredient, other
than one used for purification of the active
ingredient; and (2) which is produced on a
commercial or pilot-plant production sale
(whether or not it is ever held for sale).(4)
3.1.2 Formulations
Pesticide formulations are usually described
by their physical appearance: liquid and dry.
Within these classifications are various speci-
fied formulations. The rest of this chapter briefly
describes the existing kinds of formulations.
3.2 Liquid Formulation Types
3.2.1 Oil Concentrates
Oil concentrates are liquid formulations con-
taining a high concentration of active ingredient
which do not mix with water, but are diluted
with fuel oil or kerosene. It is necessary that the
concentrate be miscible, upon minimum agi-
tation, with the diluent to be used. Aromatic
hydrocarbons are generally used as solvents for
the active ingredients in oil concentrates.
There are some pesticide active ingredients
whose solubility in aromatic hydrocarbons is so
limited as to make the use of these solvents im-
practical. To overcome this limitation, it is
necessary to use a small amount of a more
powerful polar solvent. The necessary qualifi-
cation for use of any of these polar solvents is
that the concentrate obtained by diluting the oil
concentrate with the polar solvent be miscible
with the hydrocarbon solvent.
3.2.2 Emulsifiable Concentrates
Emulsifiable concentrates are liquid formu-
lations in which the active ingredient is dis-
solved in one or more water insoluble solvents.
Emulsifiers are added to allow the insoluble
solvents to mix with water. The most com-
monly used solvents are the aromatics or, when
the solubility of the pesticide allows, aliphatics
of the kerosene range.
Because of the convenience of measuring
and mixing emulsif iable concentrates, they may
be considered the most popular form of pesti-
cide formulations. They are expected to per-
form well under a wide variety of conditions
and to withstand a number of environmental
extremes during packaging and storage. In ad-
dition, emulsifiable concentrates must disperse
spontaneously in water of various quality and,
with the aid of gentle agitation, remain uni-
formly dispersed throughout the spraying pe-
riod.
3.2.3 Aqueous Concentrates
Aqueous concentrates, as the name implies,
are concentrates of pesticidal chemicals dissolved
in water. The most frequently encountered pes-
ticidal type found in this form is the herbicidal
acid salt. Since the active ingredients (in the case
of acid ingredients) are soluble in water, there is
generally no problem of miscibility, dispersibil-
ity, or suspendibility encountered in the use of
aqueous concentrates. The exception occurs
when the concentration of magnesium or iron
ions in natural waters used for dilution is suffi-
ciently high to cause an insoluble precipitate.
3.2.4 Oil Solutions
Oil solutions are ready-to-use formulations
that generally contain a low odor, colorless sol-
vent of the kerosene type, and a pesticidal chemi-
cal in low concentration. The concentration of
12
-------
Pesticide Containers - A Report to Congress
active ingredient is usually under five percent
by weight. Oil solutions of insecticides are gen-
erally used for household or institutional insect
control. They are preferably non-staining and
have a low odor.
3.2.5 Flowable Concentrates
Flowable concentrates consist of the active
ingredient suspended in oil or water. This type
of formulation contains little or no organic sol-
vent.
3.2.6 Invert Emulsifiable Concentrates
The dilution of invert emulsifiable concen-
trates with water results in an emulsion in which
the external or continuous phase of the emul-
sion is the oil portion and the internal or discon-
tinuous phase of the emulsion is water. They
are used principally in the formulation of oil
soluble herbicidal esters. The solvent is gener-
ally an oil having a relatively low vapor pres-
sure. The distinguishing feature of invert
emulsions is that they form significantly larger
droplets than conventional emulsifiable con-
centrates when emitted from special applica-
tion equipment. Because the external phase
contains an oil of relatively low vapor pressure,
evaporation of the continuous phase is mini-
mized. As a result, there is no reduction in the
size of the droplet from the time it emerges from
the application equipment until it impinges on
the target. Therefore, the drift of these particles
is greatly reduced.
3.3 Dry Formulation Types
The important dry formulation types are
dust bases or dust concentrates, wettable pow-
ders, water dispersible granules or dry flow-
ables, dusts, granules,-and pellets. All dry
formulations, with the exception of wettable
powders and water dispersible granules, are
applied in their dry form, either as dusts, gran-
ules, or pellets. The dust bases, water dispers-
ible granules, and wettable powders are in-
tended for further dilution to label use rate
before application. Dust bases such as clays and
talcs are usually mixed with the concentrate at a
regional formulation plant. Wettable powders
and water dispersible granules are generally
mixed with water before application and then
applied as a spray. The characteristic differ-
ences between the dry formulations are de-
scribed below.
3.3.1 Dust Bases or Concentrates
Dust bases or dust concentrates are dry,
free-flowing powders containing a high con-
centration of active ingredient which varies
from 25 percent to 75 percent. Such products
are seldom applied in this concentrated form.
They are usually diluted with suitable inerts by
formulators. Pesticide-fertilizer mixtures are
often made by mixing dust concentrates with
dry fertilizer.
3.3.2 Wettable Powders
Wettable powders are dry, free-flowing pow-
ders which are mixed with water prior to appli-
cation. Their quality is judged by the speed of
wetting when mixed with "water and by the
ability to suspend in water when mixed at prac-
tical dilutions for applications.
3.3.3 Water Dispersible Granules or Dry
Flowables
Water dispersible granules, or dry flow-
ables, differ in formulation from wettable
powders only in the size of the particle. The
wettable powder is processed into larger par-
ticles or granules. This reduces the tendency of
the formulation to create dust and therefore re-
duces exposure to workers, especially in the
mixer-loader application.
13
-------
Chapter 3 Formulations
3.3.4 Dusts
Dusts are very finely powdered dry pesti-
cides. They are formulated to label use rates
which may vary from as low as 1 percent to as
high as 10 percent active ingredient, depending
upon the potency of pesticide and the rate of ap-
plication. They must be free-flowing so that
they can be accurately metered in application
equipment. Particle size may vary, although it is
usually under 200 mesh (74 micrometers or
0.003 inches). For aerial application, the avoid-
ance of drift is important. Therefore, a moder-
ate particle size of uniform distribution is the
goal.
3.3.5 Granules
Granular pesticides, like dusts, are applied
dry; however, the particles are larger in size
than dust particles. According to a general
industry standard, granular pesticide is limited
to a range from 4 mesh (U.S. Standard Sieve
Series) to 80 mesh. For any given material (for
example, a product labeled 30/60) at least 90
percent of the finished product must be within
this specified mesh range, and the remaining 10
percent may be distributed on either side of the
specified mesh sizes. The U.S. Standard Sieve
Series defines 4 mesh as approximately 1/4
inch, 30 mesh as 600 micrometers (0.024 inches),
and 80 mesh as 180 micrometers (0.007 inches).
The presence of small particles which may be-
come airborne by a cross wind during applica-
tion is generally considered to be objectionable
in a granular product.
Granular pesticides must be non-caking
during storage and free-flowing to permit accu-
rate application in metered application equip-
ment. Depending upon the application re-
quirements, they may have either fast or slow
disintegration characteristics in the presence of
moisture. The disintegration characteristics of
granules, when in the soil, have a direct bearing
on the release rate of the pesticides.
The concentration of the active ingredient in
granular pesticides may vary from as little as 1
percent to as high as 40 percent, depending
upon the properties of the active ingredient, the
characteristics of the carrier, or other factors
such as the potency of the pesticide and the
desired rate of application of the finished prod-
uct.
3.3.6 Pellets
Pesticide pellets are formulated with a par-
ticle size greater than 4 mesh. No maximum
sizes are established for pellets, but in practice
they may exist from 1/4 inch up to 1/2 inch in
diameter. They are generally formed by mixing
the active ingredient with a suitable inert, plus
a binder if necessary; followed, for example, by
pan granulating to the desired size or extruding
(and crushing, if necessary) to the desired size.
3.4 Other Formulation Types
There are a number of other possible formu-
lation types, many of which are used for special
purposes. In describing these formulations, both
liquid and dry types are presented.
3.4.1 Aerosols
Aerosol pesticide containers are pressurized
cans that contain a small amount of pesticide.
The pesticide is forced through a small opening
by a chemically inactive propellent. The type of
spray pattern and particle size of the spray are
controlled by the design of the nozzle and by the
pressure within the can which forces the concen-
trate through the nozzle. The pressure in the can
is determined by the properties of the propellent.
There are many different approaches to the for-
mulation and packaging of an aerosol pesticide
product, including both non-aqueous and aque-
ous solvent systems.
14
-------
Pesticide Containers - A Report to Congress
3.4.2 Seed Dressings
Seed dressings may be liquid or dry, and
there are variations within each type. Two of
the most important requirements of a seed dress-
ing are that:
•It must not interfere with the plantability of
the seed; and
•It must not diminish the viability of the
seed.
In addition, it is most desirable that the seed
dressing be non-toxic and not constitute an
adulteration if the seed is later fed to livestock.
Seed dressings must contain a dye to color the
seed and mark it as having been chemically
treated. (5) Certain seed dressings have been
developed in dry concentrate form for the addi-
tion to seed grains in a planter box for the
control of insects or disease from the time of
planting until after germination of the seed.
Wettable powder types of seed treating for-
mulations are used for the slurry treatment of
seed.
Liquid types such as certain emulsifiable
concentrates and water dispersible concentrates
also have been developed for the drench treat-
ment of seed. The concentration of the active
ingredient in seed dressing formulations fol-
lows the same rules and limitations as those
found in other liquid and dry formulations.
3.4.3 Poison Baits
Poison baits are special formulations de-
signed to attract and kill certain types of forag-
ing insects and rodents.
They are frequently used as a barrier to
intercept the migration of insects such as grass-
hoppers into grain fields. Another form of
poison bait is the bait trap for controlling Japa-
nese beetles in orchards or gardens and for con-
trolling the Mediterranean fruit fly in citrus
groves. Rodenticide baits, which may be in
pellet or meal form, are widely used for munici-
pal and residential rat control and for the con-
trol of mice and rats in farm buildings, or-
chards, and grain storage areas.
Poison baits have numerous physical forms
and composition. Their distinct advantage in
agricultural pest control is that they can effec-
tively reduce damage to agricultural crops by
insects and rodents without the potential haz-
ard of leaving a residue on the plant or crop.
3.4.4 Controlled Release Formulations
Controlled release formulations are designed
to release the pesticide under certain environ-
mental conditions. Environmental conditions
include time, humidity, temperature, soil mi-
croorganisms, and precipitation. For example,
an encapsulated pesticide is essentially a very
small mass of a pesticidal composition sur-
rounded by a continuous shell or envelope of
some coating material. The shell material must
be selected on the basis of its chemical inertness
toward the active ingredient and its ability to
dissolve or disintegrate at a controlled rate.
Particle size may vary from a few microns up to
1/8 inch in diameter or larger. Theoretically,
the concentration of active ingredient contained
within the shell wall may be from a fractional
percent up to and approaching 100 percent ac-
tive ingredient. Although the shell thickness
may be very low in comparison to the diameter,
the percent of the encapsulating shell material
increases as the particle size decreases.
Other methods of controlled release tech-
nology are also available including laminates,
matrices, coated granules, and the capillary
tube delivery system.
15
-------
Chapters - Formulations
3.4.5 Fertilizer Mixtures
The use of fertilizer mixtures containing in-
secticide and/or herbicide has become stan-
dard practice for agricultural as well as home
and garden products. Although the use of
pesticides with dry fertilizer mixes has become
generally accepted, the use of pesticides emulsi-
fied or dispersed in liquid fertilizers has not
attained general acceptance. The concentration
of the pesticide in dry fertilizer mixes is gener-
ally quite low and usually less than 1 percent.
To meet application requirements in agricul-
tural use, pesticide/fertilizer mixes are usually
prepared by local fertilizer suppliers on a cus-
tom basis.
Pesticides may be incorporated in dry fertil-
izers by spray impregnation or by blending of
dust bases and granules. Because of the low
concentration of pesticides in these products,
great care must be exercised through efficient
blending techniques to obtain a uniform prod-
uct. Also, because of the trend toward the use of
granular fertilizers, care must be taken in the
formulation of those mixtures to prevent the
possibility of segregation of the pesticide from
the bulk of the fertilizer mixture. Granular pes-
ticides should be approximately the same size
or mass as the fertilizer granules to avoid
separation.
16
-------
Pesticide Containers A Report to Congress
Endnotes
1. Unless otherwise noted, these definitions
have been taken in part from the 1991 Farm
Chemicals Handbook and the Maryland
Pesticide Applicator Training Series and
Core Manual (1990) and amended by the
U.S. EPA. These definitions are not in-
tended to alter the definitions found in F1FRA
or in EPA guidelines or regulations. Also,
much of the information in this chapter was
supplied by B. Omilinsky of Formulogics.
2. The Condensed Chemical Dictionary, Tenth
Edition, revised by G. Hawley.
3. Ibid.
4. 40 CFR 158.153, "Data Requirements for
Registration," May 4,1988.
5. 40 CFR 153.155, "Registration Policies and
Interpretations," May 4,1988.
17
-------
Pesticide Containers - A Report to Congress
Chapter 4
Pesticide Containers
4.1 Introduction
A pesticide container is defined in 40 CFR
Part 165 as "any package, can, bottle, bag, bar-
rel, drum, tank, or other containing device (ex-
cluding spray applicator tanks) used to enclose
a pesticide or pesticide-related waste." As de-
scribed in Chapter 2, the pesticide market is
very diverse; therefore, so are the types of con-
tainers used to package the various products.
The materials of construction, volume, and design
of the containers vary from product to product,
and from market to market.
To simplify the discussion, this report di-
vides containers into two distinct categories: re-
fillable and nonrefillable containers. Theoreti-
cally, all containers could be refilled. However,
many containers are not refilled due to eco-
nomic, legal, or technical barriers. Therefore,
these two categories are actually defined by the
current industry refilling practices.
For the purposes of this report, a nonrefil-
. lable container is one that is not currently re-
filled. Often, these containers are referred to as
one-way or throw away packages. Generally,
nonrefillable containers are relatively small, al-
though there is no maximum size limit. Nonre-
fillable containers include 1- and 2.5-gallon jugs,
5-gallon cans and pails, bags, bag-in-a-box de-
signs, aerosol cans, and water soluble bags.
Larger nonrefillable containers include 30- and
55-gallon drums.
For the purposes of this report, a refillable
container is one that is currently refilled with
pesticide for further sale or distribution. Al-
though presently there are no regulatory re-
quirements, construction materials and design
specifications generally are selected to ensure
the structural integrity of the container under
adverse storage, shipping, and use conditions
over the course of multiple fill and use cycles.
Some containers are designed so the parts that
are vulnerable to damage are protected to pre-
vent accidental release of the product. Some of
the containers that fall into this category are
bulk storage tanks, minibulks, small volume re-
turnable containers, and refillable bags.
According to this classification scheme, all
pesticide containers are considered either refil-
lable or nonrefillable. Most pesticide containers
fit cleanly into one of the two categories. The
major exception to this, however, is the group of
19
-------
Chapter 4 - Pesticide Containers
containers that can be reconditioned, specifi-
cally 55- and 30-gallon drums. Drums can be re-
conditioned and then refilled with pesticide,
provided this is not prohibited by the label. The
actual reconditioning process varies according
to the type of drum (e.g., steel or plastic, open-
head or closed-head). As an example, recondi-
tioning steel drums involves the following proc-
esses: residue removal, reshaping, pressure
testing, and repainting.(1) In general, however,
drum reconditioners do not handle pesticide
containers.(2) Usually, pesticide drums are not
sold with the intent that they will be refilled, al-
though some companies have established drum
return and reconditioning programs. (3) Recon-
ditioning is an extra step that is not commonly
part of the pesticide industry refilling practices.
Therefore, 55- and 30-gallon drums are classi-
fied as nonrefillable containers for the purpose
of this report.
In the sections that follow, various types of
containers will be discussed. This discussion is
not meant to be an in-depth review of all the
types of containers available in the market-
place. Rather, the discussion is designed to in-
troduce the basic types of containers and some
of the markets in which they are used. In the
course of the discussion, the term closure is
used. To avoid any confusion, the reader should
be aware that the term closure refers to the
device that is used to seal the opening in a con-
tainer, not the opening itself. For example, com-
mon closures are screw caps and bungs. Bungs
are plugs that are inserted into the openings of
barrels and drums and are held in place by
screw threads. (4) The industry standard method
of reporting the size of a closure is to specify the
outer diameter of the spout which it seals, where
appropriate, or the diameter of the hole (open-
ing) as on a drum.
4.2 Nonrefillable Containers
4.2.1 Drums
The drums used as pesticide containers are
similar to those commonly used for other chemi-
cals. Typical drums are depicted in Figure 4-1.
Figure 4-1
Drawing of 30- and 55-gallon drums
30 gallon
"0
55 gallon
20
-------
Pesticide Containers - A Report to Congress
I igure 4-2
An open-head pail and S-^allon can
Photo Credit: U.S. EPA.
The two most common sizes are 55 and 30
gallons. Drums are constructed from steel or
high density polyethylene (HDPE). The three
closures that are usually used in various combi-
nations on drums are a 2-inch bung with Na-
tional Pipe Thread (NPT), a 2-inch bung with
buttress thread, and a 3/4-inch bung with NPT.
In most cases, drums have just two closures, al-
though three are sometimes used. On steel
drums, one closure is often a 3/4-inch bung that
is used to provide pressure relief. In general,
the second closure is a 2-inch NPT bung, which
can be removed to attach transfer pumps, hoses,
or other valving. Plastic drums usually have
two 2-inch closures. These closures can be of the
same design or one 2-inch NPT and one 2-inch
buttress thread. One difference between the
two types of threading is that the NPT standard
has more threads per inch than the buttress fit-
ting. With plastic, the NPT threads tend to strip
during the use of the container, thereby pre-
venting the drum from being reconditioned.
For this reason, at least one registrant has cho-
sen to use the buttress threading for plastic
drums.(5) The bung on a plastic drum may also
be equipped with a "knock-out" that permits
the insertion of a fitting with a 3/4-inch NPT
thread.
4.2.2 Flat Top 5-Gallon Cans and Pails
Five-gallon cans are generally cylindrical
with flat heads and are constructed from steel.
Containers made from plastic in this size are
usually referred to as open head pails. Plastic 5-
gallon containers that are of one piece construc-
tion are called closed head pails. A can and
open head pail are shown in Figure 4-2.
Steel cans have several distinctive design
features. First, they have both a side seam and
a chime. In metal containers, the chime is the
outer edge or rim, which is usually formed by
21
-------
Chapter 4 - Pesticide Containers
I ij-ure 4-3
Flexible spout commonly used on agricultural
pesticide cans and pails
double seams and consists of a multiple thick-
ness of body and head steel. (6) Both the chime
and the side seam can be weak points in these
cans. Depending upon the chemical composi-
tion of the product placed in the container, leaks
may occur at the side seam or the chime. Often
the inside surface of the metal containers will be
treated with a baked-on phenolic resin coating.
This serves to prevent or forestall possible cor-
rosion of the container walls and also helps seal
the container.
The bottom portions of 5-gallon open head
pails are one-piece moldings, so there are no
seams to fail. The container tops are snapped
SOURCE: Rieke Corporation.
into place and form a leak-proof seal with the
appropriate gasket. While such containers do
not have seams and chimes, they can fail if the
product placed in such containers is incompat-
ible with the plastic.
The closure on the 5-gallon can depends pri-
marily on the segment of the pesticide industry
for which the container is targeted. Institutional
pesticides are often packaged in plastic pails
that usually have a 70 mm (2.75-inch) screw
cap.(7) On the other hand, nearly all cans in the
agricultural market have an opening called a
flexible spout. The two major producers of
these spouts are the Rieke Corporation and
22
-------
Pesticide Containers - A Report to Congress
American Flange. The closure on a flexible
spout is a 38 mm (1.5-inch) screw cap with but-
tress threading. Figure 4-3 shows a flexible
spout.
To empty the contents of the container, the
individual must first remove the seal on the clo-
sure. Removal of the seal provides the user with
access to the spout. For protection during ship-
ping, the spout is recessed into the container
and the seal sits flush with the top of the con-
tainer. To extend the spout, one must pull up on
the "handles" of the screw cap. Upon removal
of the screw cap, the user must then remove the
Figure 4-4
Representative designs for 2.5-gallon "F"-style plastic jugs
23
-------
Chapter 4 Pesticide Containers
inner seal within the spout. If only a portion of
the contents is used, the container may be closed
by replacing the screw cap and pushing the flex
spout back to its recessed position.
The location of the spout also poses a poten-
tial problem in these containers. The center of
the spout is located approximately 2-3 inches
from the edge of the container. Therefore, pour-
ing the pesticide can result in some of the prod-
uct being retained on the upper surface of the
container.
Five-gallon closed head containers are avail-
able. These one-piece units usually have been
designed so that the opening for the spout does
not have any surrounding surfaces that could
collect fluid. They utilize the same closures as
mentioned above. There are also 5-gallon con-
tainers that are one-piece molded plastic and
are equipped with an opening designed to ac-
cept a screw cap.
Most 5-gallon containers when filled weigh
40 to 50 pounds. This makes pouring quite dif-
ficult, especially if the user must lift and hold
the container for a sustained pour. This is one of
the reasons that the market has shifted to smaller
containers.
4.2.3 Two-and-One-Half-Gallon Jugs
Nearly all 2.5-gallon jugs are made of high-
density polyethylene (HOPE). These jugs are
usually "F"-style containers, i.e., the handle is
located on the top of the container. Examples of
2.5-gallon jugs are shown in Figure 4-4.
The 63 mm (2.5-inch) screw cap with but-
tress threading is used on almost all 2.5-gallon
jugs. These caps are commonly made of poly-
propylene.
Sometimes the inside surfaces of plastic jugs
are treated with fluorine to reduce the permea-
bility of the plastic to the pesticide formulation.
The characteristics of the pesticide formulations
determine whether the plastic container needs
to be fluorinated.
The mouth of the container may be sealed
with a mylar/foil barrier, which serves two key
purposes. The foil barrier acts as a seal to indi-
cate whether the container has been opened,
and it keeps the contents of the container from
contacting the surface of the cap, preventing
leakage. However, this seal is difficult to re-
move with gloved hands.
The use of 2.5-gallon jugs became popular in
the 1980's. Their size made them convenient.
The jugs were not as heavy as 5-gallon cans. Ad-
ditionally, the thicker, molded handles were
easier to grip and the wide, molded spout made
it easier for the user to pour and drain the con-
tainer. Some industry representatives have in-
dicated that these containers also gained popu-
larity in the major agricultural markets because
they could be burned. Steel containers had to be
rinsed, crushed, and then either recycled or bur-
ied. The plastic containers significantly reduced
the number of container failures and, as pre-
sented in Chapter 7, plastic containers drain
more completely than metal containers.
4.2.4 One-Gallon Jugs
One-gallon jugs are similar to 2.5-gallon
jugs in many respects: they are predominantly
constructed of HDPE, the caps are made of
polypropylene, "F"-style containers predomi-
nate, and foil/mylar seals are often used. One
major difference is that a variety of closures is
used for 1-gallon containers. The most com-
mon closure is the 38-mm (1.5-inch) screw cap
with 400 finish thread. (8) Some packagers have
expressed concern that a 38-mm orifice on the
container is too small and therefore use a larger
opening. Some of the larger closures are a 45-
mm (1.75-inch) screw cap and a 63-mm screw
cap.(9)
24
-------
Pesticide Containers - A Report to Congress
4.2.5 Small Rigid Containers
The pesticide industry uses a variety of rigid
containers that are smaller than 1 gallon. These
small rigid containers come in a variety of sizes
and with a number of different closures. The
containers used vary according to the specific
pesticide market. Examples of these containers
are shown in Figures 4-5 and 4-6.
Small rigid containers are used in the agri-
cultural pesticide market for highly concen-
trated emulsifiable concentrates and dry flow-
able formulations. These containers are gener-
ally made of HDPE. Similarly, institutional and
industrial pesticides are packaged in HDPE
containers in the pint, quart, or half-gallon
sizes. (10)
Household pesticides are predominantly sold
in containers smaller than 1 gallon. The materi-
als used for packaging vary tremendously, al-
though bottles are usually constructed at least
partially of HDPE. For example, a major manu-
facturer of household pesticides uses multi-
walled plastics and a barrier treatment. Multi-
walled plastic containers may have 3 layers of
plastic: HDPE, nylon or mylar, and then HDPE
again. These layers are co-extruded, not lami-
nated, which provides strength and chemical
resistance to the pesticide. The most common
process used as a barrier treatment is fluorina-
tion of the innermost layer of plastic.(ll)
4.2.6 Bags
Bags are used to contain most dry formula-
tions. While most bags are made of paper or a
paper/foil/plastic composite, there has been a
recent move toward the use of plastic. In the
pesticide industry the most commonly used
bags can be grouped into two major size classes:
25-50 pounds (11.36 - 22.73 kilograms) and 1-10
pounds (0.45 - 4.55 kilograms).
Figure 4-S
A small rigid plastic agricultural
pesticide container used for tablets
Photo Credit: Minnesota Department of Agriculture.
The paper bags are usually multiwall paper
shipping sacks and are classified as flexible con-
tainers. In general, these bags are made of three
to six plies (walls) of kraft paper. (12) Most bags
used in the pesticide industry also have a bar-
rier ply as part of the bag structure. The barrier
helps provide the necessary strength for the
bag. In addition, the barrier prevents product
components or odors from escaping from the
bag. Typical materials used for the barrier ply
include:
•LDPE Film (low density polyethylene);
•HDPE Film (high density polyethylene);
-Saranex Film (LDPE/Saran/LDPE lami-
nate);
-------
Chapter 4 - Pesticide Containers
Figure 4-6
A small metal container for fly bait
•Saran coated polypropylene;
•Metallized polyester;
•PE foil (PE/foil/PE/natural Kraft laminate);
and
•PE coated paper.(13)
The PE foil is considered to be the best odor
barrier. (14) Most bags are made with three or
four plies of paper and one barrier.(15)
The three most common bag types used for
pesticides in the larger size category are pinch-
bottom open-mouth, sewn open-mouth, and
pasted valve bags. (16) These three types of
bags are very common in all industries; they
comprise over 93 percent of the total number of
multiwall bags produced by the paper ship-
ping sack industry. These bag types are used
for the smaller size class in addition to the
"automatic" pasted open-mouth style. This
kind of bag is not used to contain large quanti
ties of material because of strength con-
Photo Credit: Minnesota Department of Agriculture.
straints.(lT) Drawings of these four bag types
are shown in Figure 4-7.
4.2.7 Bag-in-a-Box
The bag-in-a-box container consists of a plastic
bag or bladder restrained by the confines of
thick-walled corrugated cardboard. The struc-
tural integrity of the cardboard gives the blad-
der the needed rigidity for transit and storage.
Bag-in-a-box systems were designed to:
•Reduce the amount of storage space re-
quired for container inventory prior to fill-
ing;
•Replace difficult-to-dispose steel contain-
ers, since the bag and paper were assumed
to be readily disposable materials; and
•Reduce the amount of plastic used for the
container compared to a rigid plastic con-
tainer, which is intended to reduce the envi-
ronmental burden.
26
-------
Pesticide Containers A Report to Congress
The bag-in-a-box container was not designed
specifically for the pesticide industry. The con-
cepts listed above with respect to disposal and
storage were meant for other industries that
could use this container to replace items such as
glass bottles. For example, a bag-in-a-box could
be used as a large-volume milk container for use
in milk dispensers.
The institutional pesticide market uses many
of these containers and the 5-gallon size pre-
dominates. Recently some companies in the ag-
ricultural sector have begun using the 2.5- and
5-gallon bag-in-a-box containers. Industry rep-
resentatives have indicated that one of the at-
tractive features about bag-in-a-box containers
in the agricultural industry is that these pack-
Figure 4-7
Common types of bags used for pesticide
containers
Pinch Bottom Open Mouth
(Stepped End-Gusseted)
"Automatic"
Pasted Open Mouth
(Gusseted)
Sewn Open Mouth
(Gusseted)
Pasted Valve
(Flat Tube)
SOURCE: Stone Container Corporation, The Bag Packaging Wnrkshnp. 1990.
27
-------
Chapter 4 - Pesticide Containers
ages facilitate disposal by burning.(18) A new
development in the agricultural segment of the
pesticide industry is experimentation with larger
bag-in-a-box packages. The capacities being
used in test markets include 30,55,110, and 330
gallons.
The cardboard for the outer package is de-
signed to be stronger than the standard card-
board used in shipping containers. The type of
plastic used to make the bag varies according to
the size of the container. For example, some of
the 5-gallon bags are made of HOPE with a
nylon laminate.(19) The bag used for the larger
containers is composed of vinyl.(20)
The openings and closures used on bag-in-
a-box containers vary according to the specific
package. For example, some 5-gallon systems
have an opening with a screw cap. The product
can either be poured from the container or a
spigot can be attached to dispense the liquid. In
the institutional market, an automatic dispensing
system that adapts to the spigot may be mar-
keted with the bag-in-a-box. (21) The larger
bag-in-a-box systems utilize a valve that is at-
tached to the container once the package has
been delivered to the site of intended use. Dur-
ing shipment, the container has no exposed
openings, which minimizes the chances of spills
caused by loose caps or damaged valves. Once
the container has been delivered, the user at-
taches a fitting to dispense the product. (22)
4.2.8 Water-Soluble Packaging
Water-soluble packaging, made of polyvi-
nyl alcohol film, is a concept that is being re-
vived. Popular in the early 1970's, this packag-
ing fell into disfavor after numerous customer
complaints were received. The concept of wa-
ter-soluble packaging is not unique to pesti-
cides; soaps and other dry products intended
for use in water were originally packaged in this
material.
Currently, only dry formulations are pack-
aged in this film. The film is usually formed
into small bags or pouches, i.e., 1 to 2 pounds or
less, because of strength limitations. The bags
work because polyvinyl alcohol, while being an
extremely resistant polymer to most solvents,
readily dissolves in water. However, because
the bag is readily soluble in water, it must be
protected from the moisture present in the air.
This means that water soluble bags must be
packaged in foil, plastic, glass, or some other
container that provides the necessary protec-
tion. Also, the film becomes quite brittle when
stored at freezing temperatures. If care is not
taken to warm the samples, the bags can rupture
when handled.
The dissolution time of the polyvinyl alco-
hol film is predominantly a function of the
water temperature and film thickness. This has
proven to be a drawback of the product in some
of the pesticide markets where water tempera-
ture cannot be controlled and time is a valuable
resource. Film thickness is an item of concern
because as packagers strive for safety by in-
creasing the strength of the film, they increase
the dissolution time.
Polyvinyl alcohol packaging is seeing new
growth as producers learn how to educate the
consumer to use the product correctly. Also, as
more companies use the film, the user's famili-
arity "with the material increases.
Water-soluble containers for solvent-based
liquid products are being developed. A resin
called Vinex, which is a thermoplastic polyvi-
nyl alcohol, can be blow molded into bottles.
These bottles are being produced and field tested
by several pesticide manufacturers. (23)
4.2.9 Aerosol Containers
Aerosol containers are probably the most
prevalent pesticide container. These containers
28
-------
Pesticide Containers - A Report to Congress
are made of steel or aluminum and range in size
from 6 to 28 ounces. Most aerosol containers fall
in the 10- to 16-ounce range. (24)
Aerosol cans function by maintaining the
contents of the can under pressure. When the
valve is depressed, the contents are propelled
out of the container and into the atmosphere.
The size of the spray droplets and the shape of
the stream are a function of the design of the
nozzle and the formulation. These products are
commonly used in the household and institu-
tional markets as well as in pest control opera-
tions.
4.2.10 Other Containers
This chapter has described the major kinds
of nonrefillable containers currently used in the
pesticide industry. Other container designs are
used; however, a detailed discussion of them is
beyond the scope of this report. These other
containers include a variety of steel containers
(such as 2.5-gallon cylindrical cans and 1-gallon
rectangular cans), foil-lined cardboard boxes,
compressed gas cylinders, glass/plastic am-
poules, and bait stations.
4.2.11 General Comments
As stated previously in this section, most of
the nonrefillable containers mentioned were
not designed specifically for the pesticide in-
dustry. While there are specific instances where
companies have made molds for their contain-
ers, most of the pesticide companies purchase
their containers from general suppliers. The
pesticide industry does not buy a significant
portion of the total number of containers pro-
duced in the United States, with the exception
of aerosol cans. The number of pesticide aero-
sol cans is approximately 10 percent of the total
number of aerosol containers produced each
year. (25)
In the past, the pesticide industry selected
containers on the basis of chemical compatibil-
ity, cost, availability, user preference, and the
image desired for marketing. This will proba-
bly change as worker exposure, glugging, drip-
ping, container draining, container rinsing, and
container disposal become major issues. Dis-
cussions with the manufacturers of paper sacks
and plastic bottles have indicated that other
container designs or construction materials may
offer possible solutions to the problems. How-
ever, the pesticide industry has had little influ-
ence on container design and availability, be-
cause it is a relatively small buyer of containers.
Therefore, the pesticide industry may have
problems getting container manufacturers to
develop or produce containers that meet their
specific needs.
4.3 Refillable Containers
4.3.1 Bulk Containers
For the purposes of this report, a bulk con-
tainer is considered to be a container perma-
nently attached to one location and used exclu-
sively to store pesticide before sale, distribu-
tion, or use. In other words, they are stationary
storage tanks. There are actually several defini-
tions for bulk containers based on the capacity
of the container. These definitions will be dis-
cussed in more detail in Chapter 5.
Several factors contribute to bulk tanks having
a high level of structural integrity. These fac-
tors include: (1) substantial dollar investment
in the stored pesticide; (2) the potential for high
costs of cleaning up spills; (3) potential difficul-
ties in finding disposal methods for spill cleanup
residue; and (4) concerns about liability. Bulk
containers are generally large and range in size
from 500 to 10,000 gallons. The bulk storage
containers are either cylindrical or cone-bot-
tomed and are constructed of steel or HDPE.
29
-------
Chapter 4 - Pesticide Containers
I -it>u ix* 4-8
A bulk storage tank wilh a
flotation device
Photo Credit U.S. EPA.
These containers usually have an outlet valve
near the base, an orifice for cleaning, and a vent
on top of the container. Additionally, bulk
storage tanks usually have some method for
determining the level of pesticide within the
container, such as an external sight gauge or a
flotation device. A bulk storage tank with a
flotation device is shown in Figure 4-8.
A considerable amount of equipment is nec-
essary to dispense pesticide from bulk contain-
ers. Most systems include a pump, meter, and
a series of hoses and valves. Because the tank is
permanent, the hoses and valves can be sup-
ported and braced for protection and strength.
4.3.2 Minibulk Containers
For the discussion in this report, a minibulk
container is considered a ref illable portable con-
tainer with a capacity greater than 55 gallons
from which a user dispenses liquid pesticide. In
other words, a minibulk is a portable container
that travels from some point in the distribution
chain, such as the registrant or dealer, to the end
user. Nearly all minibulks are used in the
agricultural market, although some are used for
industrial pesticides. Currently, minibulks are
greater than 55 gallons in capacity. Most agri-
cultural pesticide minibulks are between 110
Minibulk containers
Photo Credit: U.S. EPA.
30
-------
Pesticide Containers - A Report to Congress
1 igure 4-10
Minibulk container
and 220 gallons; other existing sizes include
250, 275, and 500 gallons. Additionally, 200-
and 400-gallon minibulks are used in the indus-
trial pesticide market. Several minibulk con-
tainers are shown in Figures 4-9 and 4-10.
Minibulk containers have a variety of de-
signs, as seen in the above figures. The contain-
ers are generally cylindrical or rectangular. A
desire to make minibulks easier to stack pushes
the design towards rectangular, although rec-
tangular containers are sometimes considered
weaker because the corners may be vulnerable
damage points. (26)
Minibulk containers are constructed from
one of three materials. First, a very small number
(about 5 percent) of minibulks are composed of
stainless steel. Most pesticides, however, are
sold in plastic minibulks made from either lin-
ear HDPE or cross-linked polyethylene. An
estimated 60 percent of the plastic containers
are made from cross-linked polyethylene, which
is more resistant to impact than linear HDPE.
Therefore, containers made from the cross-linked
polyethylene are considered to be more du-
rable. Another difference between the two types
of plastic is that the HDPE can be melted and
reprocessed with no significant change in the
properties of the resin. On the other hand, the
three-dimensional molecular structure of cross-
linked polyethylene gives the resin its addi-
tional strength, but prevents the plastic from
being melted and reprocessed.(27)
Nearly all minibulk containers require addi-
tional equipment to remove the pesticide from
the tank. A rare exception to this is a design
with a spigot at the base of the container.(28) In
most cases, minibulks have a relatively large
opening, usually 4 or 6 inches, where a pump is
attached. There is often another large opening
to allow easy access to the tank for inspection
and cleaning.
The equipment used to transfer pesticide
from a minibulk includes pumps, meters, hoses,
and quick couplers. Pumps usually operate by
vacuum to remove the pesticide from the con-
tainer and recirculate it if necessary. Row meters
31
-------
Chapter 4 - Pesticide Containers
I ii^ure 4-11
A small volume relurnable container
Photo Credit: Research Triangle Institute.
are used to measure the quantity of pesticide
being used. Hoses transport the pesticide from
the minibulk to the application equipment. Quick
couplers have valves on either side of the con-
nection to minimize potential leaks during the
connecting and disconnecting procedures. Dry
breaks, which eliminate or have negligible leak-
age, are available but expensive. The spillage of
pesticide from these connections is currently
addressed only in California. Therefore, the use
of dry breaks is not common because of the high
cost.
Additionally, many minibulk containers have
tamper-evident devices. An example of a tam-
per-evident device is a wire that is sealed to the
minibulk closure. The closure cannot be re-
moved without breaking the wire seal.
4.3.3 Small Volume Returnable Containers
Small volume returnable (SVR) containers
currently are classified as those refillable con-
tainers whose capacities are 55 gallons or less.
Presently, most of these containers are small,
heavy-duty stainless steel containers that are
very similar to beer kegs. The most common
sizes are 15 and 30 gallons. An example of a SVR
container is shown in Figure 4-11. This type of
container is used in the agricultural sector by
FMC, DuPont, ICI, and DowElanco. Addition-
ally, several companies market pesticide for
pest control operations in small-volume re-
turnables.(29)
Additional equipment is needed to dispense
the pesticide. Most containers come with a pro-
tected or shielded valve on the top of the con-
tainer. It is necessary to use a specifically
designed device to gain access to the tank. The
contents can then be drawn from the tank with
a pump.
4.3.4 Refillable Bags
Refillable bags are used by dealers or farm-
ers who require large volumes of product to
treat their acreage. These bags are also called
flexible intermediate bulk containers (FIBC's).
The product carried in such containers may be
directly loaded into the application equipment,
including aircraft. This type of container has
been used with bulk fertilizer for years. Figure
4-12 is a picture of a refillable bag.
One example of a refillable container is a
"Super Sack" used by Monsanto to distribute a
granular Lasso formulation. A Super Sack is a
polypropylene container that can be mounted,
if desired, on a cardboard or wooden pallet.
DuPont is using a similar refillable bag. (30)
32
-------
Pesticide Containers - A Report to Congress
4.3.5 Rigid Dry Refillable Containers
A recent development in the agricultural
pesticide market is the introduction of a rigid
refillable container for the packaging of a granu-
lar soil insecticide. This system was developed
jointly by American Cyanamid and John Deere
& Company and introduced to the public in
1989. John Deere developed a hopper lid that is
compatible with the 40-pound refillable con-
tainer. The container is shown in Figure 4-13.
The easy-to-use system is based on a set of
quick-coupling valves that allows the farmer to
fill the application equipment without physi-
cally contacting the product. (31,32)
4.3.6 General Comments
The development of refillable pesticide con-
tainers is a relatively new field. The rapidly
changing technology is constantly leading to
improved container designs. This report de-
scribes the refillable containers that are pres-
ently available as well as some potential devel-
Figure 4-12
A refillable bag
Figure 4-13
Rigid dry refillable container
Photo Credit: American Cyainiiiii,!.
opments. However, it is probable that the number
and kinds of refillable containers will change in
the future.
4.4 Number of Containers
4.4.1 Introduction
No definitive statement exists with respect
to the total number of pesticide containers pres-
ently in the marketplace. However, the compa-
nies or trade organizations that represent the
industry have provided surveys that allow the
market to be estimated. In addition, EPA con-
ducted a study in 1986 and estimated that 223
million empty pesticide containers were gener-
ated that year according to the following divi-
sions:
•124 million containers from home and
garden products;
•90 million agricultural product contain-
ers; and
•19 million containers from industrial, com-
mercial, and government operations. (33)
Photo Credit: U.S.EPA.
33
-------
Chapter 4 - Pesticide Containers
In 1989, the pesticide industry conducted a
joint survey to study the types and numbers of
containers being used. The groups that partici-
pated included the National Agricultural Chemi-
cals Association (NACA), the Chemical Pro-
ducers and Distributors Association (CPDA),
the Midwest Agricultural Chemicals Associa-
tion (MACA), the International Sanitary Supply
Association (ISSA), and the Chemical Special-
ties Manufacturers Association (CSMA). Par-
ticipation in the survey was voluntary. The
participating groups felt that the survey re-
flected the majority of their users. The survey is
extremely useful in determining the major types
of containers used in each segment of the pesti-
cide industry as well as the approximate num-
bers of containers.
This section discusses the main kinds of con-
tainers used in each of the major segments of the
pesticide industry.
Table 4-1
Number of Pesticide Containers in the Agricultural Market from 1989 NACA Survey
DRUMS
30-55 gallon plastic
30-55 gallon steel
PAILS
5 gallon plastic
5 gallon steel
JUGS
2-1/2 gallon plastic
1 gallon or less plastic
BAGS
20-50 pound all plastic
25-50 pound paper
1-10 pound paper
MINIBULK
Plastic
Metal
RETURNABLE DRUMS
Plastic
Metal
1988
193,000
579,000
387,000
1,022,000
27,700,000
19,500,000
1,560,000
15,500,000
16,500,000
20,800,000 eq. gal.
643,000 eq. gal.
1,420,000 eq. gal.
866,000 eq. gal.
1989
200,000
565,000
453,000
1,178,000
26,600,000
20,100,000
1,440,000
15,600,000
16,000,000
26,400,000 eq. gal.
643,000 eq. gal.
1,420,000 eq. gal.
1,070,000 eq. gal.
1990
(projected)
256,000
563,000
419,000
1,632,000
25,500,000
18,800,000
1,720,000
14,800,000
16,600,000
31,100,000 eq. gal.
762,000 eq. gal.
1,430,000 eq. gal.
1,300,000 eq. gal.
SOURCE: T. Gilding, National Agricultural Chemicals Association, letter to R. Denny, U.S. EPA, Office of Pesticide Programs, October 12,1989.
34
-------
Pesticide Containers - A Report to Congress
4.4.2 Agricultural Pesticide Containers
The NACA survey included responses from
38 individual companies, and the results are es-
timated to represent 80 to 85 percent of the
annual usage of agricultural pesticide contain-
ers. These data, however, do not include any
containers filled by NACA members for the
household market. (34) The tabulation of the
responses is given in Table 4-1.
The following observations can be made on
the basis of the information in Table 4-1. (35)
•2.5-gallon plastic jugs represent the largest
percentage of liquid capacity, although it is
decreasing: 46 percent in 1988,43 percent
in 1989, and a projected 40 percent in 1990.
•The use of minibulk containers is increasing
and represents 14 percent of liquid capacity
in 1988,17 percent in 1989, and a projected
20 percent in 1990.
• Drums represent 17 percent of liquid capac-
ity in 1988 and 1989, with the same figure
projected for 1990. The breakdown of drums
by material is 69 percent steel and 31 per-
cent plastic.
•Plastic containers that are 1 gallon or smaller
represented 13 percent of liquid capacity in
1988 and 1989. This is projected to drop to
12 percent in 1990.
•5-gallon cans consist of 72 percent steel and
28 percent plastic and represent 5 percent of
liquid capacity in 1988 and 1989 with a pro-
jected increase to 6 percent in 1990.
•Returnable drums represent 2 percent of
liquid capacity in 1988 and 1989 with the
same projected for 1990.
•Approximately 33 million bags were used
in 1988 and 1989 with a similar quantity
projected for 1990. Ninety-six percent of
the bags are paper and 4 percent are plastic.
•The effectiveness of minibulk containers in
reducing the use of nonrefillable containers
is evident if one compares the data for 2.5-
gallon jugs and minibulks. Between 1988
and 1990 (projected), the number of 2.5-
gallon containers dropped while the amount
of pesticide sold in minibulks increased.
While the decrease in jugs may be due to a
number of factors such as more concen-
trated formulations, it is reasonable to as-
sume that minibulks replaced a large number
of 2.5-gallon jugs.
Additionally, the number of minibulk contain-
ers in the field is estimated to be 100,000.(36)
4.4.3 Institutional and Industrial Pesticide Con-
tainers
ISSA conducted a container-usage survey of
its 2,242 members who formulate or distribute
pesticides and had an 11-percent response
rate. (37) The data are best used to distinguish
the most common containers rather than the
total number of containers in this market seg-
ment. It is difficult to extrapolate the data to
determine the total number of containers be-
cause of the small percent of respondents, the
uncertainty about the size of the businesses that
responded (i.e., was the size distribution of the
respondents representative of the industry?),
and the potential for double counting (i.e., some
of the containers counted by the formulators
may also have been counted by the distribu-
tors).
Table 4-2 summarizes the most common
containers from the distributor responses. The
most common containers by far are small plastic
packages and aerosol cans. Additionally, the
distributor ranked the following container sizes
the most useful (in this order): (1) 1-gallon;
(2) 5-gallon, and (3) 55-gallon.(38)
35
-------
Chapter 4 - Pesticide Containers
Table 4-2
The Most Common Pesticide Containers
in the Institutional Market from 1989
ISSA Survey
TYPE OF
CONTAINER
Plastic, 1-5 gal
Plastic, 16-32oz
Aerosol, > 16oz
Aerosol, > 16 02
Plastic, < 16oz
TYPE OF
PESTICIDE
Disinfectant
Disinfectant
Insecticide
Disinfectant
Disinfectant
ESTIMATED
NUMBER OF
CONTAINERS1
3,368,250
1,858,625
1 ,086,625
1,085,875
164.625
1. The estimated number of containers was calculated in the following way.
The number of containers was given in ranges, i.e., 501-1000. These
ranges were totalled, giving a wide range, i.e., 701,750-1,470,000. The
estimate is the average of the total lower and upper limits, i.e., 1,085,875.
SOURCE: W. Balek, International Sanitary Supply Association, letter to
C.O'Connor, Chemical Producers and Distributors Association, August 25,
19S9.
4.4.4 Household Pesticide Containers
CSMA received surveys from 24 companies,
including 13 formulators, 9 manufacturers, 2
distributors, and one packager.(39) Again, the
data are difficult to analyze in terms of total
numbers of containers, partly because the re-
sults from the different types of companies are
summarized together. Therefore, there may be
some double counting. Additionally, a small
percentage of these containers may have been
sold to the I&I market.
The CSMA membership ranked the contain-
ers in terms of the most useful size in the follow-
ing order: (1) 16 ounces; (2) 1 gallon; and
(3) 8 ounces. (40) Table 4-3 summarizes the re-
sults for the most common kinds of containers.
Again, the small plastic and aerosol containers
dominate.
4.4.5 Aerosol Pesticide Containers
The Aerosol Pressurized Products Survey of
the United States in 1988 provides an overview
of aerosol containers usage.(41) This survey in-
cludes all fillers of aerosol containers. The
aerosol cans were divided into major product
groups and further subdivided into product
segments. Table 4-4 summarizes the major
product groups and product segments that in-
clude pesticide containers.
An attempt was made to use these data to
generate the number of aerosol containers used
in the United States for pesticide products. The
following assumptions were made:
Table 4-3
The Most Common Pesticide Containers
in the Household Market from 1989
CSMA Survey
TYPE OF
CONTAINER
Aerosol, 8-16oz
Aerosol, < 8 oz
Plastic, 16-32oz
Aerosol, > 1 6 oz
Plastic, < 1 6 oz
Aerosol, > 1 6 oz
Plastic, 16-32oz
Aerosol, 8-1 6 oz
Plastic, 1-5 gal
Plastic, < 16oz
Plastic, 1 -5 gal
Plastic, 16-32oz
Aerosol, < 8 oz
Plastic, 1-5 gal
TYPE OF
PESTICIDE
Insecticide
Insecticide
Disinfectant
Disinfectant
Insecticide
Insecticide
Herbicide
Disinfectant
Herbicide
Disinfectant
Insecticide
Insecticide
Disinfectant
Disinfectant
ESTIMATED
NUMBER OF
CONTAINERS1
7,680,000
5,250,375
3,412,125
3,096,625
2,662,500
2,627,125
2,002,500
1 .925,750
1,801,125
1,154,500
1 ,052,625
1,142,875
1,001,000
362,125
1. The estimated number of containers was calculated in the following
way. The number of containers was given in ranges, i.e., 501-1000.
These ranges were totaled, giving a wide range, i.e., 701,750-1,470,000.
The estimate is the average of the total lower and upper limits, i.e.,
1,085,875.
SOURCE: W. Stickle, Chemical Producers and Distributors Association,
letter to ]. Turner, Research Triangle Institute, (Attachment: Chemical Spe-
cialties Manufacturers Association Master Response Form), September 1,
1989.
36
-------
Pesticide Containers A Report to Congress
•Approximately one quarter of the contain-
ers listed under "room deodorizers and
disinfectants" are used to deliver disinfec-
tants (39 million containers);
•Approximately half, or 4 million, of the
"veterinarian and pet products" are pesti-
cides; and
•All of the "insect spray", or 190 million, are
pesticides.
If these values are combined, the estimated total
of pesticide aerosol containers produced in the
United States per year is 233 million units. This
value alone is greater than the total number of
pesticide containers per annum in the 1986 EPA
estimate.
4.5 Trends in Pesticide Containers
4.5.1 Plastic Containers
Current trends in the types of containers
used by the pesticide industry are driven by a
number of forces, including the industry's in-
creasing awareness of environmental and safety
concerns, federal and state regulations, market-
ing issues, concerns about container disposal,
and the needs of the customer.
Table 4-4
Number of Aerosol Cans in Categories that
Include Pesticides in 1988 CSMA Survey
TYPE OF
PRODUCT
NO. OF
CONTAINERS
IN PRODUCT
SEGMENT
ESTIMATED
NUMBER OF
CONTAINERS
IN PRODUCT
GROUP
Insect Spray
Space Insecticides
Residual Insecticides
(personal and surface
repellents, moth
proofers, etc.,
excluding pet
products)
Household Product
190,000,000
101,380,441
76,203,764
Room Deodorizers and
Disinfectants 156,591,012
Animal Products
Veterinarian and Pet
Products (shampoos,
insecticides, repellents,
etc.) 7,700.614
650,000,000
8,000,000
SOURCE: Chemical Specialties Manufacturers Association, 380t Annual
Aerosol Pressurized Products Survey - United States, 1988.
One major change in all pesticide containers
in the 1980's was the nearly universal adoption
of plastic as the major packaging type. Plastic
containers were introduced to the pesticide
market in the late 1970's and, with the exception
of aerosol products, have become the dominant
container type for liquids. Most recently, with
the advent of dry pesticide products that re-
quire smaller amounts of active ingredient per
unit area, more of these products are being
packaged in plastic bottles. Some of the advan-
tages to plastic containers from the industry's
perspective are:
•Plastic is a relatively inexpensive packag-
ing material;
•Plastic containers are plentiful and easy to
obtain in a variety of sizes and shapes;
•Plastic containers are much less likely to
break than glass containers if they are
dropped;
•Plastic containers unlike metal cans, can be
burned in the field. (This point is made
only because it is possible to burn plastic
containers; whether or not open burning is
safe and/or legal is a separate issue); and
•The use of plastic has led to the develop-
ment of smaller containers, thus reducing
the weight of the container a user must
handle. Also, the ability to mold handles
into the container makes them easier to use.
37
-------
Chapter 4 - Pesticide Containers
The data in the previous section show the
large number of plastic containers that are used
in all segments of the pesticide industry.
4.5.2 Agricultural Pesticide Containers
The major trends in the agricultural pesti-
cide market include:
•Increasing use of minibulk containers;
•Decreasing use of 2.5-gallon plastic jugs;
•Increasing interest in the use of smaller
refillable containers;
•Increasing use of water soluble packag-
ing; and
•Increasing use of plastic containers for
dry formulations, particularly dry flow-
ables.
Minibulk containers were introduced into
the agricultural pesticide industry in the late
1970's and early 1980's. Fostered by EPA's bulk
policy which allowed this repackaging, the use
of these containers at first grew exponentially.
For example, the sales of pesticide in minibulks
for one major manufacturer increased from $0
in 1986 to $30 million in 1988.(43) The use of
minibulk containers is continuing to grow, al-
though at a much slower rate. The NACA
survey showed a 3 percent increase in liquid
capacity sold in minibulks between 1988 and
1989 with a similar increase projected for 1990.(44)
The use of minibulks is most common in the
Midwest and other regions where many acres of
the same crop are farmed. It has been predicted
that the use of minibulks will continue to in-
crease for several years and then level off when
most of the potential monocrop markets have
been tapped. (45) This may already be occur-
ring, since a limited number of users need 100 or
more gallons of a concentrated pesticide at any
one time.
The interest in smaller refillable containers
is increasing. Currently, several companies are
marketing the 15- and 30-gallon small volume
returnables. However, as the market for larger
minibulks reaches its capacity, smaller refil-
lable containers must be developed to reach
markets other than the monoculture regions.
Many industry representatives believe that the
use of different small refillable containers is
essential to the future of pesticide container
management. (46)
Water soluble bags are gaining in popular-
ity as users learn to work with this kind of
packaging. Assuming that the integrity of the
bag is not compromised before it is placed in the
spray tank, end user exposure is virtually elimi-
nated and disposal of a residue-contaminated
container is not an issue. The sale of wettable
powders in water soluble bags is increasing.
Additionally, water soluble packaging is being
developed for solvent-based liquid formula-
tions.
4.5.3 Institutional and Industrial Pesticide Con-
tainers
One trend in the institutional pesticide market
is the increasing number of bag-in-a-box con-
tainers. These containers were introduced to
the institutional pesticide market in the late
1980's and have received widespread user ac-
ceptance. (47)
In the industrial segment of the pesticide in-
dustry, the trend is toward the use of refillable
containers. In general, these are small, well-
defined markets, where containers tend to be
designated for one pesticide, reducing the po-
tential for cross contamination. Also, users
generally are experienced in handling chemi-
cals in bulk.
4.5.4 Household Pesticide Containers
The major change in household pesticide
containers has been the substitution of plastic
bottles for glass containers, which provides a
significant increase in consumer safety by elimi-
nating shattered containers.
38
-------
Pesticide Containers - A Report to Congress
Endnotes
1. Environmental Information Ltd., "Drum Re-
conditioners, " E. I. Digest,, December, 1989.
2. U.S. EPA, Office of Pesticide Programs, Fourth
Open Container Meeting (August 2,1990),
meeting summary and minutes, August 29,
1990.
3. Allison, S., Monsanto, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, October
25,1990.
4. The Packaging Institute International, Glos-
sary of Packaging Terms, Sixth Edition,
1988.
5. Allison, S., Monsanto, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, October
25,1990.
6. The Packaging Institute International, Glos-
sary of Packaging Terms, Sixth Edition,
1988.
7. Anderson, L., Ecolab, letter to N. Fitz, U.S.
EPA, Office of Pesticide Programs, Septem-
ber 10,1990.
8. Chemical Packaging Committee/U.S. EPA,
meeting summary, U. S. EPA, Office of Pes-
ticide Programs, March 14,1990.
9. Ciba-Geigy/U.S. EPA, meeting summary, U.S.
EPA, Office of Pesticide Programs, August
10,1990.
10. Chemical Packaging Committee/Ecolab/
Rieke Corporation/U.S. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Programs,
October 3,1990.
11. Chase, W., Jr., Chevron Chemical Company,
personal communication with U.S. EPA,
Office of Pesticide Programs, November 16,
1990.
12. Stone Container Corporation, The Bag Pack-
aging Workshop, 126-127,1990.
13. Tytke, E., Stone Container Corporation, letter
to N. Fitz, U.S. EPA, Office of Pesticide Pro-
grams, October 9,1990..
14. Paper Shipping Sack Manufacturers Associa-
tion/Formulogics/ U.S. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Programs,
August 29,1990.
15. Tytke, E., Stone Container Corporation, letter
to N. Fitz, U.S. EPA, Office of Pesticide Pro-
grams, October 9,1990.
16. Ibid.
17. Paper Shipping Sack Manufacturers Associa-
tion/Formulogics/ U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide
Programs, August 29,1990.
18. National Agricultural Chemicals Association/
U.S. EPA, meeting summary, U.S. EPA, Of-
fice of Pesticide Programs, October 16,1990.
19. Buckeye International Inc./Formulogics/U.S.
EPA, meeting summary, U.S. EPA, Office of
Pesticide Programs, October 4,1990.
20. Lanners, B., Wilbur-Ellis Company, letter to
J. Hester, Wilbur-Ellis Company, July 24,1990.
21. The Davies-Young Company, "Another Buck-
eye Breakthrough," Informational bro-
chure, 1990.
22. Lanners, B., Wilbur-Ellis Company, letter to
J. Hester, Wilbur-Ellis Company, July 24,1990.
23. Famili, A., Air Products and Chemicals, Inc.,
letter to T. Bone, U.S. EPA, Office of Pesticide
Programs, November 14,1990.
24. Difazio, J., Chemical Specialties Manufactur-
ers Association, personal communication with
U.S. EPA, Office of Pesticide Programs, May
23,1990.
25. Chemical Specialties Manufacturers Associa-
tion, "38th Annual Aerosol Pressurized Prod-
ucts Survey - United States," 1988.
26. Rigid Intermediate Bulk Container Associa-
tion/U.S. EPA, meeting summary, U.S. EPA,
Office of Pesticide Programs, May 18,1990.
27. U.S. EPA, Methods to Manage and Control
Plastic Wastes: A Report to Congress, Febru-
ary, 1990.
28. Research Triangle Institute, Trip Report to
Rosemead, North Carolina, June 7,1989.
29. Barrows, P., FMC, personal communication
with U.S. EPA, Office of Pesticide Programs,
September 13,1990.
39
-------
Chapter 4 - Pesticide Containers
30. Bartenhagen, C, Monsanto, personal commu-
nication with U.S. EPA, Office of Pesticide
Programs, March 30,1990.
31. American Cyanamid, brochure for Counter
container, 1989.
32. Finck, C., "At Last! A Safe System for Han-
dling Insecticides," Farm Journal, Novem-
ber 1989.
33. Brandt, E., U.S. EPA, memorandum to R.
Kreuger, U.S. EPA, Office of Pesticide Pro-
grams, March 18,1986.
34. Gilding, T., National Agricultural Chemi-
cals Association, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, October
12,1989.
35. Ibid.
36. "Mini-Bulk - Small Tanks, Big Benefits,"
Custom Applicator, pp. 86-88, March, 1990.
37. Balek, W., International Sanitary Supply As-
sociation, letter to C. O'Connor, Chemical
Producers and Distributors Association, Au-
gust 25,1989.
38. Ibid.
39. Stickle, W., Chemical Producers and Dis-
tributors Association, letter to J. Turner, Re-
search Triangle Institute, (Attachment:
Chemical Specialties Manufacturers Asso-
ciation Master Response Form), September
1,1989.
40. Ibid.
41. Chemical Specialties Manufacturers Asso-
ciation, "38th Annual Aerosol Pressurized
Products Survey - United States," 1988.
42. Peck, D., "The Determination of Residue of
Certain Pesticides After Triple Rinsing,"
August 1985.
43. Ciba-Geigy/Research Triangle Institute,
meeting summary, Research Triangle Insti-
tute, June 28,1989.
44. Gilding, T., National Agricultural Chemi-
cals Association, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, October
12,1989.
45. American Cyanamid/Bray ton Chemicals Inc./
U.S. EPA, meeting summary, U.S. EPA,
Office of Pesticide Programs, February 28,1990.
46. Justmann, T., American Cyanamid, personal
communication with U.S. EPA, Office of Pesti-
cide Programs, September 24,1990.
47. Buckeye International Inc./Formulogics/
U.S.EPA, meeting summary, U.S. EPA, Office
of Pesticide Programs, October 4,1990.
40
-------
Pesticide Containers - A Report to Congress
Chapter 5
Requirements Affecting
Pesticide Containers
5.1 Introduction
This chapter addresses the requirements that
affect pesticide containers and bulk storage fa-
cilities, including regulations and policies. Ad-
ditionally, trade association standards are dis-
cussed. EPA believes that it is important to con-
sider all of the elements impacting pesticide
containers throughout the container life cycle.
This chapter summarizes the standards that
have a major impact on pesticide containers.
However, this is not a comprehensive list of all
the relevant standards.
5.2 Department of Transportation (DOT)
5.2.1 Hazardous Materials Packaging Regula-
tions
5.2.1.2 General
The Department of Transportation (DOT)
regulates the transportation of hazardous mate-
rials through the Hazardous Materials Regula-
tions (HMR) codified in 49.CFR Parts 171 179.
These regulations are based on a specification
system which has developed over the years.
Part 171 contains administrative information on
the HMR, including the definitions. Part 172
contains the Hazardous Materials Table, the
Optional Hazardous Materials Table, and the
regulations for hazard communication. Part
173 contains the definitions for each of the 22
hazard classes and specifies the packaging au-
thorized for specific chemicals, including cer-
tain pesticides. Parts 174,175,176, and 177 con-
tain specific requirements for transportation by
rail, air, water, and highway, respectively. Part
178 contains the construction specifications for
all of the DOT containers, except tank cars,
which are specified in Part 179.
A major portion of Part 178 is devoted to
specifications for non-bulk packaging. These
specifications typically describe in great detail
the requirements for most of the packaging, in-
cluding materials of construction, capacity, thick-
ness, coatings, fastenings, and openings.
New packages which are not included in the
specifications in Part 178 can be used for pack-
aging DOT hazardous materials only under the
terms and conditions of exemptions issued by
DOT. The exemption process is very labor-in-
tensive for both chemical packagers and DOT
because a detailed safety analysis must be done
and reviewed. Also, exemptions must be re-
newed every two years.(l)
41
-------
Chapters - Requirements Affecting Pesticide Containers
5.2.1.2 Non-bulk Packaging
Non-bulk packaging is defined by DOT as:
"a packaging which has (1) an internal volume
of 450 liters (118.9 gallons) or less as a receptacle
for a liquid; (2) a capacity of 400 kilograms
(881.8 pounds) or less as a receptacle for a solid;
or (3) a water capacity of 1000 pounds (453.6
kilograms) or less as a receptacle for a gas as de-
fined in §173.300." (2)
The specifications are defined for a wide va-
riety of container materials and sizes. Several of
the most common non-bulk containers that are
used with pesticides are the Specification 2U
and 2E molded or thermof ormed inner polyeth-
ylene containers, Specification 12B/12P fiber-
board boxes, Specification 17C, E, or F steel
drums, Series 44 multiwall paper bags, and
Specification 44P plastic bags.
5.2.1.3 Bulk Packaging
Bulk packaging is defined by DOT as "a
packaging, other than a vessel or a barge, in-
cluding a transport vehicle or freight container,
in which hazardous materials are loaded with
no intermediate form of containment and which
has: (1) An internal volume greater than 450
liters (118.9 gallons) as a receptacle for a liquid;
(2) a capacity greater than 400 kilograms (881.8
pounds) as a receptacle for a solid; or (3) a water
capacity greater than 1000 pounds (453.6 kilo-
grams) as a receptacle for a gas as defined in
§173.300."(3)
5.2.1.4 Minibulk Packaging
Although DOT regulations do not specifi-
cally define them, minibulk containers are regu-
lated either as non-bulk or bulk packaging, de-
pending on their size. An example of this type
of container that is commonly used with pesti-
cides is the Specification 57 metal portable tank,
which is required to have "a capacity of at least
110 gallons but not more than 660 gallons." (4)
Any plastic minibulk that is being used for a
pesticide classified as a DOT hazardous mate-
rial must receive an exemption because there
are no specifications for plastic portable tanks.
These exemptions are product-specific. (5)
5.2.2 Pesticides as DOT Hazardous Materials
The definitions for all of the 22 hazard classes
in the HMR are contained in Part 173. The three
hazard classes that encompass most pesticides
that are defined as DOT hazardous materials
are Class B poisons, flammable liquids, and
combustible liquids. (6)
Several packaging engineers have estimated
that approximately 20-25 percent of all pesti-
cides classify as DOT hazardous materials. (7)
While the 20-25 percent figure may be valid
now, this percent most likely will increase when
the recent changes to the hazard class defini-
tions in DOT's Docket HM-181 become effec-
tive.
5.2.3 Docket HM-181, Performance-Oriented
Packaging Standards
On April 15,1982, the Research and Special
Programs Administration (RSPA) of DOT pub-
lished an Advance Notice of Proposed Rule-
making (ANPRM) under Docket Number HM-
181 which was followed by a Notice of Pro-
posed Rulemaking (NPRM) on May 5,1987.(8)
Additionally, a correction document to the NPRM
was published on November 6,1987. (9) On De-
cember 21,1990, the final rule was published. (10)
The goals of these regulations are to: "(1)
simplify and reduce the volume of the HMR; (2)
enhance safety through better classification and
packaging; (3) promote flexibility and techno-
logical innovation in packaging; (4) reduce the
need for exemptions from the HMR; and
(5) facilitate international commerce."(11) Ad-
42
-------
Pesticide Containers - A Report to Congress
ditionally, "the intended effect of this action is
to align the HMR with the U.N. Recommenda-
tions ... in the areas of classification, packaging
and hazard communication in the transport of
hazardous materials." (12)
While the changes made by these regula-
tions are too numerous to explain in detail, the
importance of this rulemaking can be seen by
considering that the total volume of regulations
published in the Code of Federal Regulations
would be reduced significantly from 1250 pages.
Additionally, about 100 packaging specifica-
tions will be deleted. (13)
The final rule for HM-181 was published on
December 21,1990. A detailed analysis of these
regulations is not possible in this report. How-
ever, this rule may have a significant impact on
pesticide containers. During comprehensive
discussions with pesticide packagers, several
issues have been pointed out as having poten-
tially large impacts. These issues include: (l)the
burden of learning a new system; (2) changes in
the definitions of the hazard classes, particu-
larly Class B poisons and flammable liquids;
and (3) some currently used specification con-
tainers might not meet the new performance
standards.
5.3 United Nations
5.3.1 Transport of Dangerous Goods Recom-
mendations
5.3.2.1 General
The Transport of Dangerous Goods Recom-
mendations have been developed by the United
Nations Committee of Experts on the Transport
of Dangerous Goods and its subsidiary bodies.
It is important to realize that these are not en-
forceable regulations, but are recommendations
that set standards for a wide range of packag-
ing. In most cases, these standards contain gen-
eral requirements for materials and construc-
tion, while they address the strength and integ-
rity of the container by specifying a series of
performance tests that the container must pass
or be capable of passing. The standards in the
sixth revised edition of the U.N. Recommenda-
tions (the "Orange Book") will be discussed
briefly according to the type of container.
5.3.1.2 Non-bulk Packaging
Chapter 9 in the Orange Book contains the
standards for packages whose net mass is 400
kilograms (881.8 pounds) or less and whose ca-
pacity is 450 liters (118.9 gallons) and less. These
standards apply to drums, barrels, boxes, bags,
and composite packaging.
5.3.1.3 Intermediate Bulk Containers
Chapter 16 of the Orange Book contains the
standards for intermediate bulk containers
(IBC's), which are defined as "rigid, semi-rigid,
or flexible portable packaging, other than those
specified in Chapter 9, that: (a) have a capacity
of not more than 3.0 rrf (3000 liters) [(792.6 gal-
lons)], (b) are designed for mechanical han-
dling, (c) are resistant to the stresses produced
in handling and transport, as determined by
tests." (14) Most minibulks would be consid-
ered IBC's.
The different types include metallic IBC's,
flexible IBC's, rigid plastic IBCs, composite IBCs
with plastic inner receptacles, fiberboard IBC's,
and wooden IBC's. The actual tests that are
specified vary according to the type of IBC and
include bottom lift, top lift, stacking, leakproof-
ness, hydraulic pressure, drop, tear, topple, and
righting tests.
5.3.2 International Implementation of U.N. Re-
commendations
Several international systems of regulations
have been promulgated and are based on the
43
-------
Chapter 5 - Requirements Affecting Pesticide Containers
U.N. Recommendations, thereby making the
recommendations enforceable. Two regulatory
systems are in place worldwide: the Interna-
tional Civil Aviation Organization (ICAO) Tech-
nical Instructions and the International Mari-
time Dangerous Goods (IMDG) Code. The IMDG
Code is published and maintained by the Inter-
national Maritime Organization (IMO), which
is a specialized agency of the United Nations.
There are two other international regulatory
systems based on the U.N. Recommendations
which are applicable in Europe. The Economic
Commission for Europe (ECE) Group of Ex-
perts on the Transport of Dangerous Goods is
responsible for these regulatory systems which
include the standards for Carriage of Danger-
ous Goods by Road and Carriage of Dangerous
Goods by Rail. Additionally, several countries,
including Canada and Australia have promul-
gated national regulations based on the U.N.
Recommendations. (15)
The IMDG code and ICAO system contain a
date for ending transitional periods or "grand-
father" provisions for non-complying packag-
ing. Previously, packaging that met national
standards such as the DOT's HMR was suffi-
cient for most international shipments. After
the specified date, non-U.N. packaging will not
be acceptable. However, DOT specification
packaging also meeting U.N. standards will be
acceptable. (16) The IMO and ICAO non-speci-
fication packaging transition period ended on
December 31,1990. International shipments of
hazardous materials beginning January 1,1991
will have to meet the U.N. packaging specifica-
tion requirements. (17)
5.4 Environmental Protection Agency (EPA)
The EPA has many regulations and policies
that affect pesticide containers and bulk storage
facilities, both directly and indirectly. The most
relevant regulations and policies will be dis-
cussed individually.
5.4.1 Federal Insecticide, Fungicide, and Roden-
ticide Act (FIFRA).
5.4.1.1 Container Design and Residue Removal
Regulations
EPA will issue container design and residue
removal regulations, which were mandated in
section 19 of the 1988 amendments to FIFRA.
Specifically, according to section 19(e), EPA
must:
"promulgate regulations for the design of
pesticide containers that will promote the safe
storage and disposal of pesticides. The regula-
tions shall ensure, to the fullest extent practi-
cable, that the containers —
(i) accommodate procedures used for
the removal of pesticides from the
containers and the rinsing of con
tainers;
(ii) facilitate the safe use of the contain-
ers, including elimination of splash
and leakage of pesticides from the
containers;
(iii) facilitate the safe disposal of the con
tainers; and
(iv) facilitate the safe refill and reuse of
the containers."
These regulations are required by Congress
to be promulgated by December 24,1991 and
EPA must require compliance with these regu-
lations by December 24,1993.
Section 19(f) of FIFRA requires EPA to:
"promulgate regulations prescribing procedures
and standards for the removal of pesticides
from containers prior to disposal.
44
-------
Pesticide Containers - A Report to Congress
The regulations may —
(i) specify, for each major type of pesti-
cide container, procedures and stan-
dards providing for, at a minimum,
triple rinsing or the equivalent degree
of pesticide removal;
(ii) specify procedures that can be imple-
mented promptly and easily in various
circumstances and conditions;
(iii) provide for reuse, whenever practicable,
or disposal of rinse water and residue;
and
(iv) be coordinated with requirements for
the rinsing of containers imposed un-
der the Solid Waste Disposal Act."
EPA may, at the discretion of the Adminis-
trator, exempt products intended solely for house-
hold use from the requirements of these residue
removal regulations. The residue removal regu-
lations are required to be promulgated by De-
cember 24,1991. Section 19(f) further says that
"a State may not exercise primary enforcement
responsibility under section 26, or certify an
applicator under section 11, unless the Admin-
istrator determines that the State is carrying out
an adequate program to ensure compliance with
this subsection," effective beginning December
24,1993.
5.4.1.2 Labeling Requirements
FIFRA requires the registration of pesticides.
Registration encompasses the label and label-
ing. It is a violation of FIFRA to use any regis-
tered pesticide in a manner inconsistent with its
labeling.
Removal of residue from nonref illable pesti-
cide containers is currently regulated by EPA
through the regulations for Labeling Require-
ments for Pesticides and Devices in 40 CFR Part
156, Pesticide Registration Notice 83-3 (PR Notice
83-3), and PR Notice 84-1.
Currently, EPA requires the label of pesti-
cide containers to contain a statement on dis-
posal of the pesticide and the container. Specifi-
cally, 40 CFR 156.10(i)(2)(ix) requires that the
directions for use contain:
"Specific directions concerning the storage
and disposal of the pesticide and its container,
meeting the requirements of 40 CFR Part 165.
These instructions shall be grouped and appear
under the heading 'Storage and Disposal/ This
heading must be set in type of the same mini-
mum sizes as required for the child hazard
warning."
In 1983, EPA issued PR Notice 83-3 to guide
the pesticide industry. This document is a
notice to manufacturers, formulators, and reg-
istrants of pesticides regarding the Label Im-
provement Program (LIP) for Storage and Dis-
posal Label Statements. The PR Notice ad-
dresses several issues including the storage and
disposal information that is required to be on
the label, the type size of the heading "STOR-
AGE AND DISPOSAL," suggestions for stor-
age instructions, the pesticide disposal instruc-
tions, the container disposal instructions, and
the time frame for compliance.
The container disposal statements specified
in PR Notice 83-3 for non-household pesticides
are given below.
"Metal containers (non-aerosol)
Triple rinse (or equivalent). Then offer for
recycling or reconditioning, or puncture and
dispose of in a sanitary landfill, or by other pro-
cedures approved by state and local authorities.
45
-------
Chapter 5 - Requirements Affecting Pesticide Containers
Plastic containers
Triple rinse (or equivalent). Then offer for
recycling or reconditioning, or puncture and
dispose of in a sanitary landfill, or incineration,
or, if allowed by state and local authorities, by
burning. If burned, stay out of smoke.
Glass containers
Triple rinse (or equivalent). Then dispose of
in a sanitary landfill or by other approved state
and local procedures.
Paper and plastic bags
Completely empty bag into application equip-
ment. Then dispose of empty bag in a sanitary
landfill or by incineration, or, if allowed by
State and local authorities, by burning. If burned,
stay out of smoke."
There are also container disposal statements
for fiber drums with liners and compressed gas
cylinders. With few exceptions, the language
specified in PR Notice 83-3 or a similar state-
ment appears on all non-household pesticide
labels.
PR Notice 83-3 also provides container dis-
posal statements for household pesticide con-
tainers. However, these statements are not used
because the disposal statement for household
pesticides was updated in 1984 through PR
Notice 84-1. PRNotice84-l allows the use of the
following disposal statement: "Do not reuse
empty container (bottle, can, bucket). Wrap
(container) and put in trash."
PR Notice 84-1 also allows the disposal state-
ments for household pesticides to be used on
the labels of some institutional products. Spe-
cifically, institutional pesticides packaged in
container sizes similar to products intended for
household use can use the smaller household
disposal statement.
5.4.1.3 Child-Resistant Packaging (CRP)
Regulations
EPA has promulgated Child-Resistant Pack-
aging (CRP) Regulations for pesticide contain-
ers. FIFRA section 25 (c) (3) authorizes EPA to
establish standards for pesticide packages, con-
tainers, or wrappings in order "to protect chil-
dren and adults from serious injury or illness re-
sulting from accidental ingestion or contact with
pesticides or devices regulated" under FIFRA.
FIFRA requires that these standards be consis-
tent with those established by the Consumer
Product Safety Commission (CPSC) under the
authority of the Poison Prevention Packaging
Act. EPA's regulations implementing FIFRA
section 25(c)(3) appear in 40 CFR Part 157. CPSCs
CRP testing requirements are incorporated by
reference in EPA's CRP regulations to avoid
duplicate testing of packages for pesticidal and
non-pesticidal purposes.
These regulations were initially promulgated
in 1979 and revised in 1986. (18) CRP is required
for residential use pesticides that meet certain
toxicity criteria. Even within this segment, re-
stricted use pesticides and containers larger
than a defined cut-off are not required to have
CRP. CPSC is currently modifying the proce-
dures for its CRP testing. EPA intends to revise
the regulations in 40 CFR Part 157 accordingly
to incorporate these modifications.
5.4.1.4 Other FIFRA Regulations
There are several other sets of FIFRA regula-
tions that apply to those bulk storage facilities
that refill containers. Because repackaging is
considered production of a pesticide, facilities
that repackage pesticide into refillable contain-
ers are producing establishments and must
comply with the following regulations:
46
-------
Pesticide Containers - A Report to Congress
(1) 40 CFR Part 167, Registration of Pesticide
and Active Ingredient Producing Establishments,
Submission of Pesticide Reports (FIFRA section
7 regulations); and
(2) 40 CFR Part 169, Books and Records of
Pesticide Production and Distribution (FIFRA
section 8 regulations.)
5.4.1.5 Bulk Pesticide Enforcement Policy
An important document in the handling of
pesticides is the bulk pesticide enforcement
policy, commonly referred to as the "56-gallon
policy," which was originally written in 1977.
Bulk was defined in the 1977 policy as "any
volume of pesticide greater than 55 gallons or
100 pounds [dry weight] held in an individual
container."(19)
The policy was developed to define when
bulk shipments and transfer practices would be
allowed without a separate registration. Be-
cause the registration requirement can be bur-
densome, few bulk facilities would be willing to
obtain a separate registration simply to repack-
age. Therefore, without the bulk policy, the use
of refillable containers would be much less
common than it currently is.
As the policy explains, "Before a pesticide
product which is not encompassed within the
terms of an existing registration enters the chan-
nels of trade, a separate registration must be
obtained. Changes in the formulation of a reg-
istered product, changes in accepted labeling,
as well as any repackaging of a pesticide into
another container will activate the registration
requirement, unless the purposes of product
registration would be fully met by carrying
forward the Federal registration of the constitu-
ent product." (20)
The policy defines the conditions of repack-
aging under which the purposes of registration
continue to be satisfied upon further sale and
distribution of the pesticide. The purposes of
registration as outlined in the policy include:
"safety and efficacy review, label review, iden-
tification of the accountable party, and commu-
nication to the user of relevant information.
Thus, to the extent that a bulk transfer involves
changing the container, e.g., repackaging a reg-
istered end use pesticide with no change to the
pesticide formulation, its labeling, or the ac-
countable party, the repackaged product is
encompassed within the terms of the original
registration." (21)
In terms of repackaging, the accountability
criterion is the most difficult requirement to sat-
isfy. The policy considers the accountability re-
quirement satisfied when the pesticide is trans-
ferred in bulk (1) at an establishment owned by
the registrant, (2) at a registered establishment
operated under contract with the registrant, or
(3) at a registered establishment owned by a
party not under contract to the product regis-
trant, but who has been furnished "written au-
thorization for use of the product label by the
registrant.(22)
The policy sets forth the conditions which
the dealer must meet to repackage without having
to obtain a separate registration. These condi-
tions were summarized in a Question and Answer
document on the Bulk Enforcement Policy. A
dealer must:
" (1) register each of the repackaging sites
owned or operated by him as a 'pesticide-
producing establishment';
(2) obtain written authorization from the
product's registrant to repackage the pesti-
cide and use the registered label;
47
-------
Chapters Requirements Affecting Pesticide Containers
(3) place the dealer's EPA-assigned es-
tablishment number on the product's label;
(4) provide product's label and labeling
to the end- user;
(5) keep records as required by Section 8
of FIFRA (shipping and receiving, sales,
etc.); and
(6) report annually to EPA the types and
amounts of pesticides produced (repack-
aged) by him."(23)
A number of issues have recently been raised
regarding the bulk enforcement policy, specifi-
cally the quantity limit of greater than 55 gal-
lons. The quantity of 55 gallons was selected in
1977 before the use of refillable containers was
common. The restriction to quantities greater
than 55 gallons was intended to control the
containers into which pesticides were repack-
aged. At the time, the larger containers were
considered safer.
The greater than 55-gallon limit as estab-
lished by the 1977 policy has two major implica-
tions. First, containers with capacities 55 gal-
lons or less cannot be refilled under the bulk
pesticide enforcement policy without a regis-
tration. Second, quantities of pesticides 55 gal-
lons and less cannot be placed into a container
larger than 55 gallons under the bulk pesticide
enforcement policy without a separate registra-
tion.
However, the second of these implications
was eliminated when EPA amended the bulk
pesticide enforcement policy on March 4,1991.
The definition of bulk was deleted. The bulk
policy was amended "to allow repackaging of
any quantity of pesticide into refillable contain-
ers, provided:
(1) the container is designed and constructed
to accommodate the return and refill of
greater than 55 gallons liquid or 100 pounds
of dry material; and
(2) either: (a) the containers are dedicated to
and refilled with one specific active ingre-
dient in a compatible formulation, or (b) the
container is thoroughly cleaned according
to written instructions provided by the reg-
istrant to the dealer prior to introducing an-
other chemical to the container in order to
avoid cross-contamination; and
(3) all other conditions of the July 11,1977
policy are met." (24)
As discussed above, these changes to the
bulk pesticide enforcement policy allow quanti-
ties of pesticides 55 gallons and less to be re-
packaged into containers larger than 55 gallons
without a separate registration.
5.4.2 Resource Conservation and Recovery Act
(RCRA)
5.4.2.1 General
The regulation of solid waste was first ad-
dressed by Congress in 1965 with the passage of
the Solid Waste Disposal Act. In 1976, Congress
passed the Resource Conservation and Recov-
ery Act (RCRA), which amended the Solid Waste
Disposal Act. RCRA, which was last reauthor-
ized in 1984, addresses both solid waste and
hazardous waste.
Subtitle D of RCRA establishes the frame-
work for controlling the management of nonhaz-
ardous solid wastes. The associated regula-
tions are in 40 CFR Parts 256 257. EPA has
proposed a rule to regulate the disposal of solid
waste in municipal solid waste landfills.(25)
Subtitle C of RCRA addresses the management
48
-------
Pesticide Containers - A Report to Congress
of hazardous wastes and is codified in 40 CFR
Parts 260 - 272.
The distinction between a nonhazardous
waste and a hazardous waste is important in
practice because of the difference in the cost of
disposal. The actual cost for hazardous waste
disposal varies according to the characteristics
of the waste, the method of disposal, and the
region of the country. Pesticide users in Califor-
nia reported that it costs about $1,000 to inciner-
ate a 55-gallon drum of hazardous waste and
$5,000 to dispose of a 20-yard bin of granulated
pesticide containers in a hazardous waste landfill.
It was estimated that it would cost approxi-
mately $30,000 to incinerate the 20-yard bin.(26)
The following discussion is not intended to
be an exhaustive summary of the federal RCRA
regulations. Its purpose is to give a basic under-
standing of some requirements that may apply
to pesticide containers, bulk pesticide facilities,
container recyclers, and others in the pesticide
industry.
First, a material must be classified as a solid
waste before it can be regulated as a hazardous
waste. A solid waste is any discarded material.
This may include materials that are abandoned,
recycled in certain ways, or inherently waste-
like. A solid waste is classified as a hazardous
waste either because it is listed on one of four
lists or because it exhibits one of four character-
istics (ignitability, corrosivity, reactivity, or tox-
icity). These lists and characteristics are located
in 40 CFR Part 261.
The following discussion summarizes the
pesticides that are hazardous waste when dis-
carded.
§ 261.31 Hazardous wastes from non-spe-
cific sources:
These hazardous wastes (the "F" wastes)
include certain discarded unused pesticide for-
mulations containing tri-, tetra-, and pentachlo-
rophenols or certain compounds derived from
these chlorophenols. It also includes residues
resulting from the incineration or thermal treat-
ment of soil contaminated with these pesticides.
§ 261.32 Hazardous wastes from specific
sources:
These are known as "K" wastes and include
wastes derived from the production of specific
pesticides, such as wastewater treatment sludges
from the production of chlordane. These wastes
are listed for their toxicity. It is unlikely that
pesticide users would generate them.
§ 261.33(e) Acute Hazardous Wastes (P-list)
This list includes about 50 discarded pesti-
cides.
§ 261.33(f) Toxic Wastes (U-list)
This list contains about 83 discarded pesti-
cides
§261.21 - 261.24 Hazardous Waste Charac-
teristics
A solid waste is a hazardous waste if it
meets one or more of the four RCRA hazardous
waste characteristics. These characteristics are
ignitability (found at 40 CFR 261.21), corrosiv-
ity (found at 40 CFR 261.22), reactivity (found at
40 CFR 261.23) and toxicity (found at 40 CFR
Part 261.24.) Six organic pesticide constituents
were formerly regulated on a concentration basis
under the EP Toxicity test: endrin, lindane,
methoxychlor, toxaphene, 2,4-D, and 2,4,5-TP
Silvex. On March 29, 1990, EPA revised the
toxicity characteristic criterion for identifica-
tion as hazardous waste. The revision brought
additional pesticide formulations into the RCRA
49
-------
Chapter 5 - Requirements Affecting Pesticide Containers
hazardous waste regulatory system, because it
added 25 new organic constituents to the toxic-
ity characteristic. Some pesticides may be for-
mulated with these organic constituents, and
thus may exhibit the toxicity characteristic.
Persons who generate, transport, treat, store,
or dispose of hazardous wastes must comply
with applicable requirements relating to man-
agement of the wastes.
The regulations provide the following ex-
emption for farmers in 40 CFR 262.70. "A
farmer disposing of waste pesticides from his
own use "which are hazardous wastes is not re-
quired to comply with [RCRA hazardous waste
requirements] for those wastes provided he triple
rinses each emptied pesticide container in ac-
cordance with §261.7(b)(3) and disposes of the
pesticide residues on his own farm in a manner
consistent with the disposal instructions on the
pesticide label."
5.4.2.2 Definition of Empty Containers
The RCRA Subtitle C regulations in 40 CFR
261.7 provide that under certain circumstances
residue of hazardous waste in empty containers
or inner liners is not subject to RCRA hazardous
waste requirements. Section 261.7(a)(l) states
that "any hazardous waste remaining in either
(i) an empty container or (ii) an inner liner
removed from an empty container as defined in
paragraph (b) of this section is not subject to"
regulation as a hazardous waste. Section 261.7(b)
defines an empty container in the following
way:
"(b)(l) A container or an inner liner re-
moved from a container that has held any
hazardous waste, except a waste that is a
compressed gas or that is identified as an
acute hazardous waste listed in §§261.31,
261.32, or 261.33(e) of this chapter is empty
if:
(i) All wastes have been removed that can
be removed using the practices commonly
employed to remove materials from that
type of container, e.g. pouring, pumping,
and aspirating, and
(ii) No more than 2.5 centimeters (one inch)
of residue remain on the bottom of the
container or inner liner, or
(iii) (A) No more than 3% by weight of the
total capacity of the container remains in
the container or inner liner if the container
is less than or equal to 110 gallons in size, or
(B) No more than 0.3 % by weight of the total
capacity of the container remains in the
container or inner liner if the container is
greater than 110 gallons in size.
(2) A container that has held a hazardous
waste that is a compressed gas is empty
when the pressure in the container ap-
proaches atmospheric.
(3) A container or an inner liner removed
from a container that has held an acute haz-
ardous waste listed in §§ 261.31,261.32, or
261.33(e) is empty if:
(i) The container or inner liner has been
triple rinsed using a solvent capable of
removing the commercial chemical prod-
uct or manufacturing chemical intermedi-
ate;
(ii) The container or inner liner has been
cleaned by another method that has been
shown in the scientific literature, or by tests
conducted by the generator, to achieve
equivalent removal; or
(iii) In the case of a container, the inner
liner that prevented contact of the commer-
cial chemical product or manufacturing
chemical intermediate with the container,
has been removed."
50
-------
Pesticide Containers - A Report to Congress
It is important to note that under §261.7(b)(l),
a container with one inch of residue is consid-
ered empty. The intent of this paragraph is that
one inch of material may remain only if the
residue cannot be removed by any normal means.
This provision was added to account for tars
and other extremely viscous materials under
the assumption that ordinary means will leave
one inch (or less) of residue in the container. If
ordinary means of removing the material leaves
more than one inch of residue, however, ex-
traordinary means of removal must be util-
ized. (27) Another important point is that ac-
cording to §261.7(b)(3), containers that held an
acute hazardous waste must be triple rinsed or
cleaned to an equivalent level.
5.4.2.3 Applicability ofRCRA to Bulk Facilities
One significant consideration for bulk facili-
ties is the disposal of material which results
from normal operating practices. Some of these
materials are generated by rinsing refillable
containers and collecting routine spills and leaks.
Unless the bulk facility is also involved with
pesticide application, the facility may not have
a means to apply this material to an appropriate
site in accordance with the label. Additionally,
even if the facility does apply, there are situ-
ations where the material may contain pesti-
cides intended for different sites and therefore
cannot be applied.
In situations where the materials cannot be
beneficially used, reused, or recycled, the mate-
rial must be disposed in accordance with the ap-
plicable laws and regulations. If the rinsate or
spill clean up material is classified as a hazard-
ous waste either by being listed or exhibiting
one of the characteristics of hazardous waste, it
must be disposed of in accordance with appli-
cable hazardous waste requirements. This could
have a significant economic impact for bulk
facilities.
5.4.2.4 Applicability ofRCRA to Recyclers
Container recyclers face a similar situation.
If the recycling procedure involves a washing
process, a large quantity of rinsate may be gen-
erated. Again, if the rinsate classifies as a haz-
ardous waste, it must be managed according to
applicable federal and state hazardous waste
regulations.
5.4.2.5 Open Burning
The open burning of solid waste is prohib-
ited under EPA RCRA Subtitle D regulations at
40 CFR 257.3-7. EPA banned open burning
based on a determination that the health haz-
ards posed by this practice outweigh the bene-
fits.
5.4.3 Comprehensive Environmental Re-
sponse, Compensation, and Liability Act (CER-
CLA).
CERCLA addresses the cleanup of existing
environmental contamination. CERCLA im-
poses liability on a variety of persons for cleanup
of releases or threatened releases of hazardous
substances which cause the incurrence of re-
sponse costs.
One specific part of CERCLA that affects the
disposal of pesticide containers is the definition
of release. A release is defined, in part, in
section 101 to include "any spilling, emptying,
discharging, injecting, escaping, leaching,
dumping or disposing into the environment
(including the abandonment or discarding of
barrels, containers, and other closed receptacles
containing any hazardous substance or pollut-
ant or contaminant)."
The threat of CERCLA liability has impacted
the disposal of pesticide containers in several
ways. First, an increasing number of municipal
51
-------
Chapter 5 - Requirements Affecting Pesticide Containers
solid waste landfills (MSWLF's) are refusing to
accept pesticide containers, even those that have
been triple rinsed. (28) Other localities may ac-
cept pesticide containers but only after the county
agricultural commissioner has verified that the
containers have been adequately triple rinsed.(29)
Some companies have chosen to avoid the po-
tential CERCLA liability by sending their empty,
triple rinsed pesticide containers to hazardous
waste landfills. (30) While this is very expen-
sive, some companies have indicated that it is a
better alternative than the potential liability
involved with disposing of their containers at a
MSWLF.
5.5 States
collection and return programs, open burning,
and bulk storage and handling.
5.5.2 Residue Removal Procedures
Many states have defined procedures for
triple rinsing and/or pressure rinsing either in
educational brochures or in regulations. This is
done to help train applicators or to facilitate en-
forcement of the label. The actual procedures
are discussed in greater detail in Chapter 7.
However, an important point is that the residue
removal procedures vary greatly among states.
5.5.1 General
State regulations also play an important role
in the management of pesticide containers and
bulk pesticide facilities. While a comprehen-
sive analysis of all state regulations is beyond
the scope of this report, this section will discuss
some of the applicable state regulations and
recommendations. A summary of state regula-
tions on pesticide storage, transportation, and
disposal is being prepared as a separate docu-
ment.(31)
States are restricted in their regulation of
pesticide packaging. Section 24 (b) of FIFRA
prohibits states from imposing any requirements
for packaging in addition to or different from
those required under FIFRA. This provision
prevented California from standardizing con-
tainer closures when it developed closed sys-
tem regulations. (32) However, since all states
have adopted the DOT HMR in some form, they
apply and enforce DOT packaging standards
for pesticides that are hazardous materials under
DOT's regulations.
This section will address the approach states
have taken on residue removal procedures, use,
5.5.3 Regulations Regarding Transfer of Pesti-
cides
California has promulgated regulations re-
garding the transfer of pesticides from the origi-
nal container to the application or mix tank.
Specifically, section 6746 of the Food and Agri-
cultural Code requires the use of closed systems
for toxicity category one liquid pesticides (those
whose label contains the signal word "Danger")
under certain circumstances as follows: "6746.
Closed Systems, (a) Employers shall provide
closed systems for employees that mix or load
liquid pesticides in toxicity category one, or
load diluted liquid mixes derived from dry
pesticides in toxicity category one, for the pro-
duction of an agricultural commodity. No
employee shall be permitted to transfer, mix, or
load these pesticides except through a closed
system. The system's design and construction
shall meet the director's closed system criteria.
(b) The requirements of this section do not
apply to: (1) employees who handle a total of
one gallon or less of pesticides in toxicity cate-
gory one per day exclusively in original con-
tainers of one gallon or less; or (2) regulatory
personnel collecting samples of pesticides ac-
cording to official sampling procedures."
52
-------
Pesticide Containers A Report to Congress
California defines a closed system in section
6000.4 of the Food and Agricultural Code as "a
procedure for removing a pesticide from its
original container, rinsing the emptied container
and transferring the pesticide product, mix-
tures and dilutions and rinse solution through
connecting hoses, pipes and couplings that are
sufficiently tight to prevent exposure of any
person to the pesticide or rinse solution. Rins-
ing is not required when the pesticide is used
without dilution. The system's design and
construction shall meet the director's closed
system criteria."
5.5.4 Container Collection and Return Pro-
grams
Many states have developed or are imple-
menting container collection or return programs.
These programs will be described in greater
detail in Chapter 8. This section discusses the
programs in 3 states — Maine, Illinois, and Min-
nesota ~ where the programs are mandated by
state law.
5.5.4.2 Maine
Maine has the only mandatory deposit and
return program in the country. In response to
the discovery of 400 open dump sites in the
state, the Maine legislature enacted a manda-
tory deposit and return system for state re-
stricted and limited use pesticide containers in
1983. The program is detailed in Chapter 21 of
the Maine Board of Pesticide Control regula-
tions and involves the dealers affixing an alpha-
numeric sticker to certain restricted or limited
use pesticide containers and collecting a deposit
for each of these containers. The deposit is
returned or credited to the applicator when the
properly rinsed container is returned to a desig-
nated collection site and inspected by Board
staff.
5.5.4.2 Illinois
The Illinois Legislature enacted HB 1356 in
1989. This bill requires the Illinois Department
of Agriculture, with the consultation of the Illi-
nois Environmental Protection Agency, to de-
velop and implement a pilot container collec-
tion project by June 1991. The goals of the pilot
project are to:
•Collect and recycle empty triple rinsed
pesticide containers;
-Develop and promote proper container
management; and
•Evaluate current management.
Additionally, information will be collected and
surveys will be done on container storage and
disposal.
5.5.4.3 Minnesota
Also in 1989, the Minnesota Legislature en-
acted container collection requirements in S.F.
262. This legislation requires the Minnesota De-
partment of Agriculture (MDA), working with
the Minnesota Pollution Control Agency and
the Minnesota Agricultural Extension Service,
to develop and implement a pilot project to
collect containers by the end of June 1991. By
November 1991, the MDA must report to the
legislature with conclusions from the pilot pro-
gram and recommendations for future legisla-
tion.
While the mandate for the pilot program is
similar to Illinois' law, the Minnesota legisla-
tion goes a step further. Chapter 1813 of S.F. 262
requires that any "person distributing, offering
for sale, or selling a pesticide must accept empty
containers and the unused portion of pesticide
that remains in the original container from a
pesticide end user if:
53
-------
Chapter 5 - Requirements Affecting Pesticide Containers
(1) the pesticide was purchased after July 1,
1994; and
(2) a place is not designated in the county for
the public to return empty pesticide con-
tainers and the unused portion of the pesti-
cide."
certain conditions, such as the onsite burning of
small quantities of agricultural containers. Other
states prohibit open burning in their pesticide
regulations. Some states interpret the state air
pollution laws to prohibit open burning, while
others interpret the air pollution laws to allow
the practice.
5.5.5 Open Burning
Many states have specifically addressed the
open burning of pesticide containers, which is
discussed in detail as a disposal option in Chap-
ter 8. Some states specifically allow open burn-
ing in regulations, usually allowing it only under
Table 5-1
Bulk Storage Regulations
TYPE OF
REGULATION
Comprehensive Bulk
Storage Regulations
in Effect
Comprehensive Bulk
Storage Regulations
Proposed
Minimal Bulk Storage
Regulations in Effect
Minimal Bulk Handling
Regulations in Effect
Currently Drafting Bulk
Storage Regulations
Illinois, Iowa, Minnesota,
Vermont, and Wisconsin
Indiana, Nebraska, and
Florida (as above
groundstorage regs.)
Kansas, Mteslssippi. North
Carolina, North Dakota,
and Ohio
Louisiana and South
Dakota
California, Michigan,
Missouri, Oregon and
Virginia
SOURCE: U.S.EPA.
5.5.6 Bulk Storage Regulations
Many states have addressed or are currently
addressing the bulk storage and/or handling of
pesticides. Table 5-1 summarizes the states
active in the area of bulk pesticide regulation.
The comprehensive bulk storage regulations
in effect in several states govern construction of
storage tanks, secondary containment, mainte-
nance and inspection requirements, emergency
response, record keeping, rinsate and precipita-
tion accumulation management, loading and
mixing, and employee training. Some states
prohibit underground storage of pesticide and
rinsates. Generally, the regulations apply to
dealer storage sites and may also apply to
commercial applicator and farm storage sites
holding in excess of a certain volume of liquid
or dry product in tanks. These regulations are
discussed in greater detail in Chapter 12.
Additionally, the Association of American
Pesticide Control Officials (AAPCO), a state
group, developed model regulations regarding
bulk pesticide facilities in 1989. These model
regulations address the repackaging and distri-
bution of bulk pesticides, registering bulk pes-
ticide storage facilities, bulk pesticide storage
facility operation (including construction, op-
eration, inspection and maintenance, and rec-
ord keeping requirements), emergency and
discharge response plans, transportation, and
54
-------
Pesticide Containers - A Report to Congress
underground bulk pesticide storage. (33) Addi-
tionally, a committee of AAPCO is currently
drafting model rules for operational areas and
containment pads.
5.6 Municipalities - Landf illing
Residues in triple rinsed (or the equivalent)
pesticide containers emptied in accordance with
40 CFR 261.7 are not hazardous wastes as dis-
cussed previously. Thus, federal law does not
prohibit disposal of such containers in landfills
that accept solid waste.
In practice, however, the acceptance of pes-
ticide containers varies according to the policy
of the specific landfill. Although many landfills
may legally accept rinsed containers, it is widely
believed that potential liability under federal
and state law and concern for worker safety
have and will continue to limit the availability
of landfills, especially for agricultural chemical
users. Landfilling is discussed in detail in Chapter
8.
5.7 Industry Standards
Many industry trade groups have made sig-
nificant contributions to pesticide container man-
agement and container standards. Several ex-
amples are the Container Management Goals
developed by the National Agricultural Chemi-
cals Association and the Voluntary Manufac-
turer Specifications and User Guidelines for
Portable Agri-Chemical Tanks developed by
the Midwest Agricultural Chemicals Associa-
tion (MACA).
5.7.1 NACA Container Management Goals
The NACA Container Management Goals
were approved by the Board on February 21,
1989. The aim of the document is to outline a
scheme for the responsible management of
pesticide containers in a manner that encour-
ages resource conservation and which NACA
considers environmentally sound. The goals
are expressed in the following order of prefer-
ence:
"I. Reduction in the number of empty con-
tainers through the use of reusable contain-
ers, formulation modifications, and other
innovative container minimization ap-
proaches;
2. Recycling of empty containers for their
material or energy value; and
3. Disposal of empty containers in accor-
dance with environmentally sound and cost-
effective practices." (34)
5.7.2 MACA Container Specification Standards
The Midwest Agricultural Chemicals Asso-
ciation (MACA) has developed a set of manu-
facturer specification and user guidelines for
portable agri-chemical tanks, commonly known
as the MACA-75 standards. These voluntary
guidelines were originally adopted in 1986 and
are updated periodically. The MACA Bulk Pes-
ticide Task Force Committee with the advice of
technical, regulatory, and legal experts devel-
oped the standards to address tank quality. The
MACA-75 guidelines are widely accepted and
most of the minibulk containers currently pro-
duced meet these standards.
The standards address:
The design of the container, including the
materials of construction;
•General construction requirements;
•Closures, filling and discharge valves, and
other plumbing;
•Emergency pressure relief devices;
•The strength of protective devices;
55
-------
Chapter 5 - Requirements Affecting Pesticide Containers
•A series of performance tests;
•Displaying compliance data;
•Markings, labels, and placards; and
•Inspection and maintenance considera-
tions. (35)
56
-------
Pesticide Containers - A Report to Congress
Endnotes
1. 52 Fed. Reg. 16482, "Performance-Oriented
Packaging Standards; Miscellaneous
Proposals/ May 5,1987; 49 CFR Part 107,
"Hazardous Materials Program Procedures,"
September 25,1978.
2. 49 CFR 171.8, "Hazardous Materials
Regulations," August 10,1987.
3. Ibid.
4. 49 CFR 178.253, "Hazardous Materials Regu-
lations," February 9,1972.
5. Snyder Industries, Inc. U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide
Programs, October 1,1990.
6. Class B poisons are defined in 49 CFR
173.343, flammable liquids in 49 CFR 173.115
(a), and combustible liquids in 49 CFR 173.115
(b)-
7. Chemical Packaging Committee/U.S. EPA,
meeting summary, U.S. EPA, Office of Pesti-
cide Programs, March 14,1990.
8. 52 Fed. Reg. 16482, "Performance-Oriented
Packaging Standards; Miscellaneous Propos-
als," May 5,1987.
9. 52 Fed. Reg. 42772, "Performance-Oriented
Packaging Standards; Proposed Rulemaking,"
November 6,1987.
10.55 Fed. Reg. 52402, "Performance-Oriented
Packaging Standards; Changes to Classi-
fication, Hazard Communication, Packaging
and Handling Requirements Based on U.N.
Standards and Agency Initiative," December
21,1990.
11. Ibid.
12.52 Fed. Reg. 16482, "Performance-Oriented
Packaging Standards; Miscellaneous Propos-
als," May 5,1987.
13.55 Fed. Reg. 52402, "Performance-Oriented
Packaging Standards; Changes to Classi-
fication, Hazard Communication, Packaging
and Handling Requirements Based on U.N.
Standard and Agency Initiative," December
21,1990.
14. United Nations, Recommendations on the
Transport of Dangerous Goods, sixth revised
edition, New York, p.366,1989.
15. 52 Fed. Reg. 16482. "Performance-Oriented
Packaging Standards; Miscellaneous Propos-
als," May 5,1987.
16. Ibid.
17. Rousseau, G., Rigid Intermediate Bulk Con-
tainer Association, personal communication
with U.S. EPA, Office of Pesticide Programs,
January 5,1990.
18. 51 Fed. Reg. 21276, "Pesticide Programs; Child
Resistant Packaging," June 11,1986.
19. U.S. EPA, Office of Compliance Monitoring,
"Bulk Pesticide Enforcement Policy," 1977.
20. Ibid.
21. Ibid.
22.Ibid.
23. U.S. EPA, Office of Compliance Monitoring,
"Questions and Answers on the bulk pesti-
cide enforcement policy," 1985.
24. U.S. EPA, Office of Compliance Monitoring
"Amendment to the July 11,1977 Enforce-
ment Policy Applicable to Bulk Shipment of
Pesticides," March 4,1991.
25. 53 Fed. Reg. 33314, "Solid Waste Disposal
Facility Criteria," August 30,1988.
26. U.S. EPA, Trip Report to California, Oregon,
Washington, September 16-22,1990, U.S. EPA,
Office of Pesticide Programs, October 1990.
27. 47 Fed. Reg. 36093, "Hazardous Waste Man-
agement System; Identifying and Listing of
Hazardous Waste," August 18,1982.
28. Minnesota Department of Agriculture, "Min-
nesota Empty Container Disposal Report,"
March 1988.
29. U.S. EPA, Trip Report to California, Oregon,
Washington, September 16-22,1990, U.S. EPA,
Office of Pesticide Programs, October 1990.
30. Ibid.
31. The information on state collection programs
and regulations is taken from a report being
drafted for EPA that will summarize state re-
quirements relating to pesticide storage, trans-
portation, and disposal.
57
-------
Chapters - Requirements Affecting Pesticide Containers
32. Jacobs, W., "Government Views of Container/
Closed System Issues," Improving On-Tar-
get Placement of Pesticides, Agricultural
Research Institute, 1989, pp. 89-103.
33. Association of American Pesticide Control
Officials, (Draft) Model Bulk Pesticide Rules,
1989.
34.National Agricultural Chemicals Associa-
tion Board of Directors, Container Manage-
ment Goals, February 21,1989.
35.Mid west Agricultural Chemicals Associa-
tion, Manufacturer Specification and User
Guidelines for Portable Agri-Chemical Tanks,
December 1986.
58
-------
Pesticide Containers - A Report to Congress
Chapter 6
Nonrefillable Containers:
Use
6.1 Introduction
This is the first in a series of six chapters that
provides a systematic, detailed presentation of
the current world of pesticide containers. These
chapters present a "snap-shot" of the containers
and practices presently used in the pesticide in-
dustry. The overall discussion includes com-
mon handling practices, container design fea-
tures, technical constraints, and other issues in-
volving use, residue removal, and disposal for
both nonrefillable and refillable containers.
An underlying theme unifying the follow-
ing chapters is the inextricable relationship be-
tween design features and common container
use practices such as emptying, residue removal,
and disposal. Some of the goals and use prac-
tices force container design features in opposite
directions. In other words, a design character-
istic that is beneficial at one point in the life cycle
of a container may be detrimental at another
stage. A good illustration of these competing
goals is the hollow handle commonly found on
2.5-gallon plastic jugs. While the hollow handle
may facilitate emptying or pouring the pesti-
cide by minimizing "glugging," the handle
may retain pesticide, thereby frustrating resi-
due removal efforts. There are many examples
of these conflicting objectives that provide a
number of constraints for designing containers.
The scope of activities involved with the use
of nonrefillable containers must be defined.
For the purpose of the report, use of nonrefil-
lables begins when the container is released for
shipment and ends when the pesticide has been
removed from the container. This range of ac-
tivities includes transportation, storage, han-
dling, opening the container, and dispensing
pesticide from the package.
This chapter describes the use of rigid con-
tainers, bags, and other packages including
bag-in-a-box, water soluble packaging, and aero-
sols. Also, the "pour" test for rigid containers,
new research which was done as a part of the
container study, is described. Finally, the me-
chanical transfer systems used to remove pesti-
cide from the containers in some situations are
described. Where appropriate, the discussion
59
-------
Chapter6 Nonrefillable Containers: Use
distinguishes between the major pesticide mar-
kets.
6.2 Rigid Nonrefillable Containers
This section discusses rigid nonrefillable con-
tainers which generally hold liquid formula-
tions. However, an increasing amount of dry
formulations, particularly water dispersible gran-
ules, are also being sold in rigid containers. The
container should perform the same for both dry
and liquid formulations. Therefore, this cate-
gory of containers which includes drums, cans,
and jugs, is defined by a common characteristic,
rigidity, rather than the type of formulation it
holds.
This discussion first describes the good and
desired features of rigid nonrefillable contain-
ers. In other words, it defines an "ideal" con-
tainer. Then the issues specific to individual
kinds of containers including drums, cans, 2.5-
gallon jugs and 1-gallon jugs, are discussed.
6.2.1 Good Design Features
This subsection defines an "ideal" rigid non-
refillable container. This discussion follows the
format outlined in two draft guidance docu-
ments developed by several European advisory
groups. These sources are "Guidelines for the
Design of Containers for Liquid Pesticide" by
the Pesticide Label and Container Design Panel
and "Requirements Profile/Design Criteria for
Plastic Containers" by the Groupement Interna-
tional des Associations Nationales de Fabri-
cants de Produits AgrochLmiques (GIFAP) Pack-
aging Task Force.(l,2)
6.2.1.1 Container Integrity
The container should:
•Contain the product by preventing losses
caused by spills, leaks, or permeation;
•Provide adequate physical protection (im-
pact resistance, permeability resistance, du-
rability, and strength) to withstand the
typical external forces on the container
during transportation, storage, and han-
dling; and
•Provide sufficient protection against antici-
pated climatic conditions and generally
maintain the integrity of the pesticide for-
mulation.
6.2.1.2 Container Handling/Design
The container should:
•Be a size convenient for the user. Realisti-
cally, the maximum size that allows man-
ual handling is 5 gallons;
•Allow lifting and controlling the container
with ease;
•Have a handle unless the container is too
large to be handled manually or small
enough to be controlled with one hand. The
handle should be large enough for a gloved
hand and easy to grip even if the container
is wet;
•Allow the end user to correctly position the
container to prevent glugging and splash-
ing while pouring the pesticide;
•Have no sharp edges or projections;
•Have no external releases or rims that retain
pesticide;
•Drain well, i.e., internal releases or design
features should not retain pesticide;
•Allow the use of a mechanical transfer sys-
tem;
•Allow pesticide to be measured easily, if
necessary, either within the container or
into a smaller container; and
•Be easy to stack or otherwise minimize the
space needed to store the container.
60
-------
Pesticide Containers - A Report to Congress
6.2.1.3 Opening/Closure Performance
The opening (orifice) of the container should:
•Allow for efficient pouring, including the
minimization of dripping, glugging, and
splashing;
•Be as large as possible to facilitate dispensing
the pesticide and removing the residue;
and
•Be compatible with mechanical transfer sys-
tems considering features such as neck di-
mensions and thread specifications.
The closure should:
•Be easy to remove with a gloved hand.
Additionally, secondary seals should be
easy to remove with a gloved hand. Imple-
ments should not be necessary to remove
either the primary closure or the secondary
seal;
•Be compatible with the pesticide;
•Allow for liquid-tight re-closure for par-
tially emptied container and/or triple rins-
ing; and
•Be capable of repeated removal without
impairing its ability to reseal the container
without leaking.
6.2.2 Drums
Mechanical transfer systems are used to dis-
pense the product from 55- and 30-gallon drums
unless the drums are laid on metal racks with a
spigot in the opening which allows the operator
to empty the drum. The use of mechanical
transfer systems is not a major problem, how-
ever, because both steel and plastic drums usu-
Figure 6-1
tic drum with a pump attached
Photo Credit: Science Products.
61
-------
Chapter 6 - Nonrefillable Containers: Use
1 igure (i-2
Pesticide user removing Ihe inner seal of a flexible spout
with a screw driver
Photo Credit U.S. EPA.
62
-------
Pesticide Containers - A Report to Congress
ally have a 2-inch opening with standard NPT
threads, which is compatible with transfer pumps
and equipment. Drums with the 2-inch buttress
thread opening are usually plastic. Registrants
usually provide an adapter to facilitate com-
patibility between the plastic container and the
NPT threaded pump. (3) Figure 6-1 shows a
typical drum and pump system.
6.2.3 Five-Gallon Cans
There have been several problems reported
regarding the use of 5-gallon cans. The con-
tainer may be difficult to manipulate. A full can
weighs 40-50 pounds, which is generally con-
sidered the upper limit for safe use by the
consumer. (4) An appropriate grip in the base of
the container would allow the user to pour
pesticide from the can in a more controlled and
safer manner.
The orifice is generally several inches from
the edge of the container and is recessed from
the upper edge of the container. Therefore, if
pesticide drips while it is being poured, it is
easily trapped on the top of the container.
Most complaints about 5-gallon cans focus
on the flexible spout opening/closure system.
Users report that it is difficult to open the flex-
ible spout with rubber gloves on their hands.
The spout must be extended by grasping the
"handles" on the screw cap, which are difficult
to grasp with gloved hands. Often a screw
driver or other implement is used to perform
this task. After the closure is removed, the inner
seal is broken by pulling a ring within the spout.
Again, this operation is very difficult with a
gloved hand and a screw driver is often used, as
shown in Figure 6-2. If only part of the con-
tainer's contents is used, the closure is replaced
and the flexible spout is pushed down to its
original recessed position. The flexible spout
then acts as a dam for any pesticide that has
dripped. This could cause user exposure when
the spout is re-extended.
Figure 6-3
The container on the left is glugging, while the liquid in the container on the right
is being poured in a continuous, coherent stream
Photo CrtJit: Don GooJall
63
-------
Chapters - Nonrefillable Containers: Use
Figure 6-4
Kleenpour "no-glug" design
Extended Drip Lip
(sharp edge)
Inclined Handle
Reduced Neck
6.2.4 Two and a Half-Gallon Plastic Jugs
The most commonly reported problems with
2.5-gallon plastic jugs are with the handle and
the orifice. There are several issues involving
the handle on the jugs. The hollow handle often
assists in minimizing glugging while pouring
pesticide from the container. This will be dis-
cussed in greater detail in section 6.3 which de-
scribes the "pour tests" done for this study. On
the other hand, a hollow handle may retain
pesticide, making it difficult to thoroughly drain
or rinse the container. This will be discussed in
detail in Chapter 7.
Some handles are too small to be gripped
with a gloved hand. Additionally, some grow-
ers do not like handles that are on top of the jug
because it is difficult to pour and the user's hand
is positioned near the stream of pesticide.
The design of the orifice may lead to drip-
ping or pouring in an erratic, noncoherent stream,
commonly referred to as "glugging". Specifi-
cally, the size, shape, and position of the open-
ing play a role in whether the container glugs or
pours in a continuous, coherent stream. Figure
6-3 shows the difference between "glugging"
and a continuous, coherent stream.
Kleenpour, an Australian company, has pat-
ented a design for the orifice and handle of
plastic jugs that was developed specifically to
minimize glugging. A drawing of this design is
shown in Figure 6-4. The design is being used
by some companies for pesticide jugs, although
royalties must be paid for each container that
uses this design because of the patent.
Dripping may be a problem with plastic
jugs. The lip of the orifice, the internal slope of
64
-------
Pesticide Containers - A Report to Congress
the neck, the surface tension of the liquid, and
any remaining foil seal determine the amount of
pesticide that drips down the exterior of the
container.
Another problem with plastic jugs is the sec-
ondary heat seal on the mouth of the container.
This seal is nearly impossible to remove with
gloved hands. A user often punctures it with a
screw driver or knife, which could cause unex-
pected user exposure. Additionally, the foil
seal is usually not removed completely. The
remaining seal material fouls the lip of the
container and causes pesticide to drip down the
jug. Recently, seals with a small tab to facilitate
their removal have been produced. Depending
upon the size of the tab and the dexterity of the
user, these tabs may solve the problem. Figure
6-5 shows a plastic jug with an incompletely
removed seal.
6.2.5 One-Gallon Plastic Jugs
One-gallon plastic jugs generally present
the same problems as 2.5-gallon jugs with the
Figure 60
Plastic jug with an incom-
pletely removed seal
Photo Credit: Minnesota Department of Agriculture.
additional problem that the size of the orifice is
smaller.
Most 1-gallon jugs have a 38 mm opening,
although a few have openings as large as 63 mm.
Figure 6-6
Containers with built-in measuring devices
65
-------
Chapters - Nonrefillable Containers: Use
Some applicators report that the 38 mm size is
too small to allow pouring in a smooth, continu-
ous stream or quick withdrawal using mechani-
cal transfer systems. (5)
Some 1-gallon jugs are specifically designed
to incorporate a measuring device. Several ex-
amples are shown in Figure 6-6. These designs
may be convenient to the user for measuring the
pesticide, although they often retain residue
and are difficult to rinse.
6.3 Pour Testing
6.3.1 Background
The use of a liquid product under field con-
ditions often results in the inability to safely dis-
pense its contents into the target receptacle. The
safety problems affecting the user are the splash-
ing that occurs during the pour and the inability
to stop the pour without liquid streaming down
the face of the container.
The objective of the pour test was to deter-
mine whether and to what extent quantifying
the previously discussed phenomena was pos-
sible.
6.3.2 Introduction
The purpose of the research performed as
part of the container study was to quantify the
discontinuous flow of liquid from a container
orifice (glugging) under simulated use condi-
tions.
The research was directed toward the meas-
urement of the flow characteristics of liquid
from a container, with the hypothesis that this
quantification would correlate with observed
glugging. Once the requirements for quantifi-
cation were defined, the details for the opera-
tional requirements could be developed.
6.3.3 Methodology
The following critical requirements for the
technical development of a viable method were
determined:
•The data must be obtained in real-time, i.e.
as the data are being generated;
•The method should quantify glugging in-
dependent of container shape or size;
•The method must be able to determine both
the frequency and magnitude of glugging;
and
•The results of the approach must correlate
with observed glugging effects.
The technical approach selected to address
these requirements was an integrated system
approach consisting of a container, test fixture,
data acquisition, and computer link-up.
The development effort was directed to-
ward measurement of the internal pressure
changes when pouring. This approach permits
the real time measurement of rapid transients
for their collection, display, and analysis with-
out sensor inertia or lag.
The test fixture developed for this task:
•Is capable of holding various container sizes
and shapes up to 20 liters (5.3 gallons);
•Is able to simulate various pouring atti-
tudes (directions and preset angles); and
•Can interface with a data acquisition sys-
tem while maintaining flexibility for pour-
ing attitudes.
The data acquisition system includes:
•Labtech Notebook Software (Laboratory
Technologies Corporation);
66
-------
Pesticide Containers - A Report to Congress
•Data acquisition card with analog and digi-
tal Input/Output, 8 channels (Omega Engi-
neering, Inc.);
•Attendant hardware (power supplies, ter-
minal boards, etc.);
•Computer - IBM or IBM compatible 386;
•VGA graphical display; and
•Hard drive with floppy disk back-up for
data storage.
6.3.4 System Operational Requirements
It was determined that the operating system
should meet the following requirements:
•Automatic trigger to initiate data acquisi-
tion upon tilt of the container to the desired
pour angle;
•Real time data collection with graphical
presentation and data storage to disk for
analysis; and
•Single user operation.
6.3.5 Test Data Evaluation
The test data were analyzed to confirm the
hypothesis and methodology. Specifically, the
data were analyzed to:
•Evaluate graphical presentation of flow
oscillations to determine whether they cor-
respond to observed glugging;
•Determine whether the frequency and/or
amplitude of the oscillations corresponds to
the severity of the interrupted liquid flow;
and
•Determine whether the lack of oscillation
corresponds to a "no-gtug" or smooth-pour
situation.
6.3.6 Experimental Procedure
After preliminary evaluations confirmed the
technical feasibility of the newly-developed
method, several sizes and types of containers
were chosen to demonstrate the experimental
method.
The containers chosen for evaluation were
selected because they are considered generally
representative of several pesticide markets regu-
lated by FIFRA.
The following containers were evaluated:
1.0-quart round, 28 mm opening;
1.0-gallon "F" style, 38 mm opening;
4.0-liter (1.06-gallon) Kleenpour, 50 mm
opening;
2.5-gallon "F" style, 63 mm opening;
2.5-gallon Kleenpour, 63 mm opening;
and
5.0-gallon round steel container, 2.5-inch
opening on the drum with a 38 mm Rieke
spout.
It is to be noted that the stated diameters are
the outer diameters of the spout, which is the in-
dustry standard method of reporting these data.
The containers were evaluated on the test fix-
ture, pouring at a 120 degree angle from the
vertical position, under conditions of (1) a con-
trolled pour where the intent of the operator is to
create a "no-glug" situation, and (2) under a
condition of rapid inversion where the face of
the container orifice is parallel to the ground.
This was the minimum set of conditions. Addi-
tional angles of pour and container attitudes
were examined for certain containers.
67
-------
Chapter 6 - Nonrefillable Containers: Use
6.3.7 Experimental Parameters
The parameters for the determination of the
pressure changes versus time were chosen to
give maximum flexibility for the analysis of the
data based upon the volume of the container
chosen. The time chosen for the tests was from
10 to 30 seconds, with 60 to 40 data samples per
second respectively. Additionally, a data col-
umn corresponding to a five-point moving
average of the pressure data was accumulated
but is not graphically presented in this report.
In all cases, water was the liquid used with
a fill of 90 percent of the rated capacity of the
container. The target for the pour was a 10-inch
diameter funnel. The funnel rim was 12 18
inches below the container during the pour.
6.3.8 Experimental Data and Observations
6.3.8.1 Pour Test
The containers chosen may be placed into
three classes based upon construction. The first
class is the plastic container without a handle;
the second is the plastic container with a hollow
handle (a subset of the second class is the Kleen-
pour container designed to give a no-glug per-
formance); and the third class is the flathead 5.0-
gallon round container.
The graphs represent the measurement of
the change in pressure over time. The first class,
represented by the 1.0-quart round container, is
lightweight and may be hand poured under
controlled conditions with an uninterrupted
Figure 6-7
Controlled hand pour of 1.0-quart round container
3
V)
10
-------
Pesticide Containers A Report to Congress
Figure 6-8
Rapid inversion of 1.0-quart round container
14.7
14.6
14.5
/'-N
< 14.4
O.
0)
V-
D
V}
CL
14.3
14.2
14
13.9
13.8
10
Time (Seconds)
flow into another receptacle (Figure 6-7). When
the container was inverted (180 degree turn
from original orifice up position) or tilted 120
degrees from the original position, glugging
was observed, and rapid oscillations in pres-
sure were recorded (Figures 6-8 and 6-9).
The second class, the "F" style containers in-
cluding the Kleenpour containers, are indica-
tive of design technology applied to the "glug"
issue. The data presented graphically show the
standard "F" style container to "glug" in the 1.0-
gallon (Figures 6-10 and 6-11) and 2.5-gallon
(Figure 6-12 and 6-13) sizes when rapidly in-
verted or poured by with the test fixture at a 120
degree pour. The recorded oscillations again
compare favorably to the observed glug when
the container is emptied in its intended manner
with the handle over the spout, as shown in
Figure 6-14. In the case of the 1.0- or 2.5-gallon
"F" style, the inability to pour in a continuous
stream makes it difficult to deposit the liquid
stream on the target. The Kleenpour containers
of both the 4.0-liter and 2.5-gallon sizes demon-
strated little or no tendency to glug when poured
under conditions similar to the "F" style con-
tainers (Figures 6-15 and 6-16). Glugging also
was difficult to detect visually.
As previously stated, these containers were
evaluated as intended for use by the manufac-
turer. Under field conditions, the user often im-
provises when emptying the container. For ex-
ample, a user might immediately invert the
container in an attempt to empty it quickly.
Alternatively, the container could be positioned
differently before pouring the pesticide. In-
stead of pouring with the handle over the spout,
69
-------
Chapter 6 Nonrefillable Containers: Use
Figure 6-9
Test fixture 120 degree pour of 1.0-quart round container
15
10
Q.
-------
Pesticide Containers A Report to Congress
Figure 6-10
Rapid inversion of 1.0-gallon "F"-style
<
Q_
0)
D
V)
I/)
-------
Chapter 6 Nonrefillable Containers: Use
Figure 6-11
Test fixture 120 degree pour of 1.0-gallon "F"-style
15
v_
3
14.9 -
14.8
14.7
CO 14.6
Q_
'4.5
14.4
Q. 14.3
14.2
14.1
14
10
Time (Seconds)
•All rigid containers can be made to glug;
•Even containers designed to be "glug-free"
may glug unless poured in a manner con-
sistent with their design; and
• Certain container-spout configurations will
glug under normal use conditions.
In light of these conclusions, it is evident that
further work will be necessary to design con-
tainers in a way to avoid the human and envi-
ronmental exposure caused by the glugging of
liquids during a pour. Further study through
the use of the described visual and computer
evaluation would assist in the design of im-
proved containers in the 5-gallon or less size
range.
The second conclusion that containers de-
signed not to glug do in fact glug when not used
in a manner consistent with their design, and fi-
nal conclusion that particular container-spout
combinations glug under normal use condi-
tions, require further discussion.
The long-term answer is to improve the de-
sign of containers or to change to closed transfer
systems, where permitted by the market in
question. The near-term answer is to educate
the user not only about the product and its
application but also about the safe use of the
particular container. Educating the user to
properly use the container would hopefully
72
-------
Pesticide Containers A Report to Congress
Figure 6-12
Rapid inversion of 2.5-gallcm "F"-style
(/i
CL
3
15
14.9
14.8
14.7
14.6
14.5
(/) 14.4
ID
^ 14.3
14.2
14.1
14
10
Time (Seconds)
cause a marketing change as a result of con-
sumer demand for containers that do not glug.
Industry could best resolve these container design
problems by looking at the pesticide and the
container together. Industry currently consid-
ers the pesticide and the container separately
and normally does not include the chemical and
the package as an integrated concept, Le., "pes-
ticide/container." Under this approach, the
container would become the logical extension
of the product and not merely a choice due to
convenience. The science and development of
pesticide formulations has greatly exceeded the
development of safe, user-friendly container
designs. To remedy this deficiency, research
must be done to unify the pesticide/container
concept into an integrated entity which can be
used safely in the field. In conjunction with the
research, an educational program is needed to
inform users how to correctly handle the pesti-
cide/container package.
6.4 Bags
6.4.1 Good Design Features
This subsection defines the criteria for an
"ideal" pesticide bag. This discussion follows
the format in "Requirements Profile/ Packaging
Concept and Design Criteria" by the GIFAP
Packaging Task Force. (6)
73
-------
Chapter 6 Nonrefillable Containers: Use
Test fixture 120 degree pour of 2.5-gallon "F"-style
e
15
14.9
14.8
14 7
14.5
Pressu
<> A
14.2
14.1
14
246
Time (Seconds)
10
6.4.1.1 Container Integrity
In terms of container integrity, a bag should
meet the same criteria as the rigid nonrefillable
containers as defined in Section 6.2.1.1. An
additional requirement is that the bag should be
odor proof.
6.4.1.2 Container Handling/Design
The bag should:
•Be a size convenient for the user. Realisti-
cally, the maximum size capable of being
handled manually is 50 pounds;
•Be easy to carry, handle, and control;
•Allow the user to accurately pour pesticide
from the container. This may require handles
on larger bags, although handles might be
weak spots;
•Have no sharp edges or projections;
•Empty completely, i.e., internal recesses such
as sewn gussets should not retain pesticide;
and
•Be easy to stack or otherwise minimize the
space needed to store the container.
6.4.1.3 Closure Performance
The closure of the bag should:
•Minimize user exposure while opening the
container, transferring the pesticide, and
re-closing the bag;
•Be easy to open with gloved hands. Prefera-
bly, implements should not be necessary to
open the bag; and
74
-------
Pesticide Containers - A Report to Congress
1 igure fi-14
Pouring a container in ils intended manner with the handle over the spout
•Allow for re-closing of a partially emptied
bag.
6.4.2 Problems with Bags
Most of the concern about the use of bags fo-
cuses on the closure. Additionally, there have
been reports about bags leaking pesticide through
seams and sewn edges. The amount of residue
retained is also a concern but will be discussed
in the next chapter.
Opening a bag seems to be the most difficult
task involved with transferring pesticide from
the container. Many bags have a string which is
intended to be pulled to open the container.
However, in researching this issue, EPA found
that users rarely open bags this way. In fact,
every user seemed to open bags differently.
Most users used a knife to cut the bag, although
the actual opening method varied greatly. Us-
ers reported opening bags in the following ways:
•Cutting off a corner with a knife;
•Cutting off the entire top with a knife;
•Cutting horizontally across one face with a
knife and "cracking the bag like an egg;"
•Cutting an "X" in one face with a knife;
•Cutting the bag with a spade; and
•Slapping the bag against the opening in the
application tank. (7)
A problem associated with opening bags is
worker exposure. Problems with dust escap-
ing from bags containing a variety of dry for-
75
-------
Chapter 6 Nonrefillable Containers: Use
Figure 6-15
Test fixture 120 degree pour of 4.0-liter Kleenpour
15
14.9 -
14.8 -
14.7
I/) 146
Q_
144
0)
3
W
in
0)
_
d 143
14.2
14.1
14
10
Time (Seconds)
mulations have been reported. This is an im-
portant concern because some dry formulations,
particularly insecticides, may be very toxic.
Another problem with bags is that they can-
not be re-closed effectively. This is a very
important issue in regions where relatively small
amounts of pesticides are used in each applica-
tion, which results in many "partials," Le., partly
filled containers. The tops of these partially
filled bags are simply rolled down, which does
not provide an air-tight re-closure. Figure 6-24
is a picture of several partially filled bags.
6.5 Other Containers
6.5.1 General
This section discusses some of the major use
problems with bag-in-a-box containers, water
soluble packaging, and aerosol cans. The for-
mat is different than the sections on rigid nonre-
fillable containers and bags because an ideal
package for each container type is not defined.
In general, however, the container integrity
criteria listed for rigid nonrefillables apply to all
pesticide containers.
6.5.2 Bag-in-a-Box
A primary concern with bag-in-a-box con-
tainers involves the structural integrity of the
container. The overall strength of the container
is a significant question, particularly the punc-
ture resistance of the cardboard and its ability to
withstand a drop. The strength is especially
important and questionable for the larger bag-
in-a-box system. Also, if the outer package is
damaged, the plastic bag is difficult to manipu-
late.
76
-------
Pesticide Containers - A Report to Congress
Figure 6-16
Test fixture 120 degree pour of 2.5-gallon Kleenpour
15
t/1
Q_
14.9 -
14.8
14.7
14.6
14.5
-------
Chapters - Nonrefillable Containers: Use
Rapid inversio nter K,eenpour
in
Q.
-------
Pesticide Containers A Report to Congress
^| Side pour, by hI!fd)roeSga,,on'.F".style ^|
149
14.8
14.7
— 14.6
Q.
^ 14.5
0)
144
in
0)
£ 14'3
14.2
14.1
14
-
-
-
-
-
-
-
— _,
^^A
\
v^^^
^~~^^^______
i i i i i i i i i i
02 4 6 8 10
Time (Seconds)
6.5.3 Water-Soluble Packaging
When water-soluble bags were first intro-
duced, there were some problems with the film
dissolving incompletely and clogging the nozzles
on spray application equipment. In recent years,
however, the technology has greatly improved
and the number of reported problems has been
reduced.
Due to their sensitivity to moisture, water-
soluble bags require an outer container with a
barrier material such as foil. By necessity, the
package construction must include a feature to
re-close the container to ensure proper protec-
tion of the unused pouches. •
Most users enjoy the convenience of the pre-
determined doses and the corresponding safety
involved with this "no-touch system." Addi-
tionally, water-soluble packaging is appealing
because it eliminates or greatly reduces the
need for residue removal and container dis-
posal.
6.5.4 Aerosol Cans
Aerosol containers continue to perform a
major role primarily in the convenience aspect
of the household and the institutional/indus-
trial markets. Their ability to dispense the
pesticide under pressure in a stream or dis-
persed phase often increases the opportunity to
hit the target pest. This form of delivery system
is also extensively used in the pest control market
where the stream and dispersed phase delivery
of pesticide is required. One problem with
aerosol containers is that there is no way for the
household consumer to empty or rinse the con-
tainer, which is discussed in greater detail in
79
-------
Chapter 6 Nonrefillable Containers: Use
Figure 6-21
Test fixture 120 degree pour of 5.0-gallon round steel
container with original Rieke spout
15.1
15
14.9
14.8
<• 14.7
i/i
C. 14.6
» M.5
D
in
-------
Pesticide Containers A Report to Congress
Q)
l_
D
Figure 6-23
Hand pour through 120 degrees of 5.0-gallon round steel
container with "no-glug" Rieke spout
15
14.9
14.8
14.7
in 14.6
CL
14.4
U)
Q_ 14.3
14.2
14.1
14
_^
i i
6 8 10 12
Time (Seconds)
14
16
18
20
Chapter 7. It is estimated that between 225-250
million aerosol containers are disposed in
landfills annually. At this time, the environ-
mental burden of this large number of aerosol
containers is unknown. However, since this
number of containers far exceeds those in all of
the other pesticide markets, the effect of these
aerosol containers on the environment should
be understood.
6.6 Mechanical Transfer Systems
One way to decrease the exposure of a mixer
or loader to pesticide is to transfer the product
from the container without pouring it, i.e., to
use a mechanical transfer system, commonly
known as a closed system. Mechanical transfer
systems are currently available and used in
both agricultural and institutional pesticide
markets. This section describes the types of
systems used as well as some of the applicable
issues.
6.6.1 Agricultural Pesticides
Several conferences have been held on the
use of closed systems in the agricultural indus-
try to discuss the development of this technol-
ogy and the associated issues. At one of these
conferences, a closed system was defined as a
mechanism "for removing pesticide concentrates
from their shipping containers, mixing these
concentrates with other materials, and loading
the mixtures into pesticide application equip-
ment." (8)
81
-------
Chapters - Nonrefillable Containers: Use
[ ignre 6-24
Partially filled bags
Photo Credit: U.S. EPA.
riguro 6-2.T
A can-punch-rinse-drain-crush
mechanical transfer system
Pesticide
container
ooc'-iiea
TO mu lank \
gauge
SOURCE: Braztllon, R.W. and Akesson, N.B., "Principles, of Closed Systems for Handling
of Agricultural Pesticides." Pesticide Formulations and Application Systems: Seventh
Volume, ASTM STP968, C.B. Beestman and D.l.B. VanderHooven. Eds., American Society
for Testing and Materials, Philadelphia, 1987, pp. 15-27.
82
-------
Pesticide Containers - A Report to Congress
Because EPA does not have a definition for a
closed system, the preceding definition will be
used for the purposes of this report. It is impor-
tant to realize that the original goal for closed
systems was to prevent any escape of pesticides
from the equipment. However, this has been
unattainable to date due to a variety of technical
and practical obstacles. (9)
6.6.1.1 Types of Systems
Many varieties of closed transfer systems are
commercially available today. Some systems
are designed to completely enclose the nonref il-
lable container in a compartment where the
container is punctured, drained, and rinsed.
The pesticide and rinsate are collected and
pumped into the mix tank. Some of these sys-
tems also crush the container. These systems
are effective but cannot be used if only part of
the contents of the container is needed. An
example of this type of system is shown in
Figure 6-25.
Many other closed transfer systems use probes
that extend into the pesticide container and
withdraw pesticide using suction, i.e., a vac-
uum. A drawing that describes the operation of
a probe transfer device is shown in Figure 6-26.
A key aspect to this type of system is establish-
ing a good seal between the probe and the
opening of the container. Probe systems are
Figure 6-26
The operation of a probe transfer device
:A
/\\
Vacuum Withdrawal
of Pesticide
Empty Container
Rinsing
Vacuum Withdrawal
of Rinse Water
83
-------
Chapters - Nonrefillable Containers: Use
Figure 6-27
A system used to connect a probe transfer device to application equipment
currently the most common type of mechanical
transfer systems. Most users adapt commer-
cially available probe systems to their applica-
tion or mixing equipment. Figure 6-27 shows a
system used to connect a probe transfer device
to application equipment.
A third type of closed system that is cur-
rently being developed is a mechanism that
uses gravity and requires no pump. The con-
tainer is inverted and screwed onto the transfer
system. Several valves are engaged and the
pesticide drains from the container. This sys-
tem is simple and easy to use because no addi-
tional equipment is necessary. However, it is
impractical for containers larger than 5-gallons.
6.6.1.2 Use of Closed Systems
While closed systems are used to a certain
degree throughout the country, they are most
common in California because of the state's
Photo Credit: U.S. EPA.
regulations. In the mid-1970's, the California
Department of Food and Agriculture (CDFA)
issued a regulation requiring the use of closed
systems in order to reduce the number of pesti-
cide-related illnesses among mixer/loaders. This
regulation requires that employees use closed
systems to mix and load liquid agricultural
pesticides in toxicity category I, which includes
the most acutely toxic formulations.(lO) Addi-
tionally, CDFA defines a closed system more
narrowly than this report, because the closed
systems used in California must rinse the con-
tainer, as well as meet the criteria developed by
CDFA. The California regulations and defini-
tion of closed systems are described in detail in
section 5.5.3.
California's closed system regulations were
promulgated in 1973, although compliance was
originally delayed until 1978 because of the lack
of acceptable systems.(ll) Analysis of the early
systems showed that the designs were too diffi-
cult to use or not sturdy enough. This led to the
-------
Pesticide Containers - A Report to Congress
development of the probe systems. It was quickly
realized, however, that the size of the suction
and rinsing part of the probe was limited by the
size of the container openings.
Additionally, the probes had to be compat-
ible with a variety of container openings. In the
late 1970's, CDFA and the California Agricul-
tural Aircraft Association (CAAA) brought the
problem of the container closure varieties to
EPA's attention. (12) The results of this action
are discussed in section 6.6.1.3.
Closed systems are currently being used in
California in compliance with the regulations,
i.e., for toxicity category I pesticides. Addition-
ally, some users transfer all liquid pesticides
with closed systems, particularly if one of the
pesticides for the application is toxicity cate-
gory I, so the system is readily a variable. (13)
Although California pesticide users have adapted
their practices to incorporate closed systems,
there are still many problems with them. Many
of these issues have prevented the nationwide
adoption of closed systems.
Some of the problems reported with closed
systems include:
•Closed systems are too slow for transferring
pesticides, particularly viscous products;
•Closed systems generally are awkward and
difficult to use. It has been estimated that it
takes about two months to train a person to
effectively use a mechanical transfer sys-
tem;
•It is difficult to accurately measure pesti-
cides with a closed system if only part of the
container's contents are needed; and
•It is difficult to effectively rinse a container
with a closed system.
A major impediment to using closed sys-
tems, however, is the large number of container
closures being used in today's packaging. An
applicator who uses a wide variety of contain-
ers with different closure sizes must maintain a
multitude of adapters. In addition to purchas-
ing and maintaining a large number of adapt-
ers, there is concern that attaching and detach-
ing adapters causes user exposure, thereby
defeating the original purpose of using closed
systems.
6.6.1.3 Container Closures
When CDFA and CAAA approached EPA
in the late 1970's, the Agency looked into regu-
lating the allowable closures for agricultural
pesticide containers by issuing an Advanced
Notice of Proposed Rulemaking (ANPRM) for
closed system packaging. The comments re-
ceived on the ANPRM generally favored stan-
dardization, although not through regulation.
EPA studied many of the issues in a survey of
pesticide user groups and an economic analysis
of the potential regulatory options. (14)
In 1981, EPA decided not to promulgate
closed system regulations. As an alternative,
NACA developed a voluntary scheme for stan-
dardizing closures according to the size and
construction material of the container. In 1982,
this plan for closures and containers was pub-
lished in the Federal Register. The scheme was
adjusted to incorporate comments, and in 1984
the final version of the NACA Voluntary Indus-
try Standard for Closure for Plastic and Steel
Agricultural Chemical Containers was published.
These voluntary standards are given in Table 6-
1.
EPA believes that the NACA voluntary stan-
dards are widely adopted, although adoption is
definitely not 100 percent. Additionally, the
NACA voluntary standards allow seven clo-
sures. Many users complain that there are still
too many closures. During a recent trip to
85
-------
Chapters Nonrefillable Containers: Use
California, nearly every pesticide user inter-
viewed requested standardized closures. (15)
Therefore, EPA believes that universal adop-
tion of standardized closures is necessary to in-
crease the use of closed transfer systems with
agricultural pesticides.
6.6.2 Institutional and Industrial Pesticides
Mechanical transfer systems are also used in
the institutional and industrial pesticide mar-
ket. These systems have been developed by the
chemical companies and are compatible with a
specific type of container. For example, dis-
pensing systems for 5-gallon open head plastic
cans with 70 mm openings are currently used.
(16) Additionally, a closed system that is com-
patible with bag-in-a-box containers is also
available. (17)
Table 6-1.
NACA Voluntary Industry Standard for
Closure for Plastic and Steel Agricultural
Chemical Containers.
Container and Material
55 GALLON TIGHTHEAD
DRUM:
Steel
PE lined steel
Plastic
30 GALLON TIGHTHEAD
DRUM:
Steel
PE lined steel
Plastic
5 GALLON TIGHTHEAD
PAIL:
Steel
Plastic
2 - 1/2 GALLON
TIGHTHEAD PAIL/JUG:
Steel
Plastic
1 GALLON TIGHTHEAD
PAIL/JUG:
Steel
Plastic
1 GALLON RECTANGULAR
CAN
Steel !
A
X
x
x
X
x
x
x
x
X
B
X
x
x
X
x
x
c
x
x
x
x
D
X
x
X
x
X
x
E
X
x
x
F
x
G
x
H
X
X
X
X
X
X
X
x
X
x
X
x
x
Closure Definitions:
A. 2" (50 mm) bung, external threasding 111/2 threads/inch NPT
standard.
B. 3/4" (19mm) bung, external threading, 14 threads/inch NPT
standard.
C 2" (50 mm) bung, external threading, 5 threads/inch (butresss/
acide thread)
D. 38 mm screw cap (at least one thread revolution at 6 threads/
inch). Cap to fit on separate spout or on flexible pull-out plastic
spout designed to crimp on container with 63 mm orifice.
E. 63 mm screw cap (at least one thread revolution at 6 threads/inch).
F. 11/4" (32mm) screw nozzle, 6 threads/inch
G. 13/4" (44mm) screw nozzle, 6 threads/inch
H. Buiflt-in probe or other closed emptying systems which fit one of
the other recommended closure openings.
SOURCE 49 Fed. Reg. 212, Closed System Packaging; Industry Plan for
Standardization of Containers and Closures, October 31,1984.
86
-------
Pesticide Containers A Report to Congress
Endnotes
1. GIFAP Pesticide Label and Container Design
Panel, "Guidelines for the Design of Containers
for Liquid Pesticide," 1990.
2. GIFAP Packaging Task Force, "Requirements
Profile/Design Criteria for Plastic Containers,"
(Liquid Agrochemicals), September 14,1990.
3. Allison, S., Monsanto, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, October 25,
1990.
4. Reseach Triangle Institute, "Trip Report to Iowa,"
May 17,1989.
5. U.S. EPA, Trip Report to California, Oregon,
Washington, September 16-22,1990, U.S. EPA,
Office of Pesticide Programs, October 1990.
6. GIFAP Packaging Task Force, Requirements
Profile/Packaging Concept and Design Crite-
ria (Solid Agrochemicals), September 14,1990.
7. U.S. EPA, Trip Report to California, Oregon,
Washington, September 16-22,1990, U.S. EPA,
Office of Pesticide Programs, October 1990.
8. Jacobs, W., "Risk Reduction Through the
Use of Closed Systems: An Attainable Goal?"
Pesticide Formulations and Application
Systems: Seventh Volume, ASTM STP 968
G.B. Beestman and D.I.B. Vander Hooven, Eds.,
American Society for Testing and Materials,
Philadelphia, 1987, pp. 47-55.
9. Ibid.
10. Ibid.
11. Brazelton, R. and N.B. Akesson, "Principles
of Closed Systems for Handling of Agricultural
Pesticides," Pesticide Formulations and Appli-
cation Systems: Seventh Volume, ASTM. STP
968, G.B. Beestman and D.I.B. Vander Hooven,
Eds., American Society for Testing and Materi-
als, Philadelphia, 1987, pp. 15-27.
12. Jacobs, W., "Risk Reduction Through the
Use of Closed Systems: An Attainable Goal?"
Pesticide Formulations and Application
Systems: Seventh Volume, ASTM STP 968,
G.B. Beestman and D.I.B. Vander Hooven, Eds.,
American Society for Testing and Materials,
1987, pp. 47-55.
13. U.S. EPA, Trip Report to California, Oregon,
Washington, September 16-22,1990,U.S. EPA,
Office of Pesticide Programs, October 1990.
14. 49 Fed. Reg. 212, "Closed System Packag-
ing; Industry Plan for Standardization of
Containers and Closures," October 31,1984.
15. U.S. EPA, Trip Report to California, Oregon,
Washington, September 16-22,1990, U.S. EPA,
Office of Pesticide Programs, October 1990.
16. Andersen L., Ecolab, Inc., letter to N. Fitz,
U.S. EPA, Office of Pesticide Programs, Sep-
tember 10,1990.
17. The Davies-Young Company, "Another
Buckeye Breakthrough," Informational
Brochure, 1990.
87
-------
Pesticide Containers - A Report to Congress
Chapter 7
Nonrefillable Containers:
Residue Removal
7.1 Introduction
The safe and proper removal of the pesticide
retained in nonrefillable containers is required
if the containers are to be disposed in a safe and
approved manner. This is important because
this residue, if disposed of improperly, may
represent a risk to health and the environment.
Proper cleaning is also important because it
allows the end-user to utilize all of the pesticide
that was purchased.
This chapter describes the present situation
regarding residue removal, including residue
removal techniques and the variables affecting
residue removal. Also, the existing studies on
residue removal are summarized and the data
generated to support these studies are presented.
Finally, future areas of research are suggested.
7.2 Current Residue Removal Techniques
7.2.1 General
The residue removal procedures currently
performed in the pesticide industry vary ac-
cording to the type of container and the particu-
lar market. Rigid containers (plastic and metal)
in the agricultural market usually are cleaned
by triple rinsing, although pressure rinsing is
becoming increasingly popular. Rigid contain-
ers in the industrial and institutional sector usu-
ally are triple rinsed. Rinsing of packages con-
taining ready-to-use products poses a problem
because users may not have a way to apply the
rinsate and disposal may be difficult.
Removal of residue from nonref illable pesti-
cide containers is currently regulated by EPA
through the label statement on container dis-
posal, as described in section 5.4.1.2. With few
exceptions, the labels on metal, plastic, and
glass containers of non-household pesticides
direct the user to triple rinse or the equivalent.
The labels on bags containing non-household
pesticides direct the user to completely empty
the bag into the application equipment. The
container disposal statement on household con-
tainers does not include residue removal. The
container disposal statement is "Do not reuse
empty container. Wrap (container) and put in
trash."
89
-------
Chapter 7 Nonrefillabk Containers: Residue Removal
7.2.2 Triple Rinsing
Triple rinsing can be used in those instances
where the container rinsate can be added to the
spray tank or other application device and ap-
plied as per label instructions. Therefore, triple
rinsing pertains to those products designed to
be diluted prior to application.
7.2.2.1 Federal Standards
EPA defined triple rinsing in 1974 when the
current 40 CFR Part 165 regulations and recom-
mendations were promulgated. Specifically,
§165.1 defines triple rinsing as: "the flushing of
containers three times, each time using a vol-
ume of the normal diluent equal to approxi-
mately 10 percent of the container's capacity,
and adding the rinse liquid to the spray mixture
or disposing of it by a method prescribed for
disposing of the pesticide."
This describes a procedure for triple rinsing
that was likely to be performed. Drain times
were not included.
7.2.2.2 State Standards
States have defined procedures for triple
rinsing through regulations or guidance docu-
ments. These procedures are given in Table 7-1.
Several conclusions can be drawn from the
procedures in this table. The most obvious is
that many definitions of triple rinsing currently
exist. While many states have followed EPA's
recommendation for using a quantity of diluent
equal to 10 percent of the capacity of the con-
tainer, others have specified a greater volume,
often 20 to 25 percent. Additionally, some states
specify a drain time upon emptying the con-
tainer (the initial drain) and/or after each rinse.
One provision that is common to many of the
procedures is that triple rinsing must be per-
formed immediately upon removal of the pesti-
cide.
7.2.2.3 Agricultural Standards
The National Agricultural Chemicals Asso-
ciation (NACA) has developed and published
recommendations for triple rinsing:
"•Drain the container into the spray tank.
Hold in vertical position for at least 30
seconds.
•Add water (or other recommended diluent)
until the container is about one-fourth full.
Close the container.
•Shake or roll the container to rinse all inte-
rior areas; then drain the rinsate into the
spray tank. Be careful not to splash your-
self.
•Repeat the rinse and drain procedure two
more times.
•Puncture plastic or metal triple rinsed con-
tainers to prevent reuse.
•Crush the container to reduce volume"(1)
Several parts of this procedure can be con-
sidered "more stringent" than the current EPA
definition of triple rinsing in 40 CFR Part 165.
First, this procedure specifies a 30-second initial
drain of the container. Second, this procedure
calls for a quantity of diluent of about 25 percent
of the capacity of the container (instead of 10
percent). These differences have been incorpo-
rated into the triple rinsing protocol used in the
most recent residue removal studies.
7.2.2.4 Actual Practice
In actual practice, effective triple rinsing can
be difficult to achieve under field conditions
because the procedure is time-consuming. For
example, the Mississippi triple rinsing proce-
dure specified in Table 7-1 requires 4.5 minutes
per container, assuming that it takes 20 seconds
to fill the container and replace the closure. In
agricultural markets, time is a limited resource.
90
-------
Pesticide Containers - A Report to Congress
Table 7-1
State Triple Rinsing Procedures
fl Arizona - Pesticide Regulations, R 3-10-313
• rinsing mandatory prior to disposal in landfill •
• not applicable to: *
pressurized containers
containers less than one gallon or five *
pounds unless held a highly toxic
pesticide
^ California - Department of Food and Agriculture
• rinsing mandatory "at time of use" for: •
containers holding less than 28 gallons •
liquid that is diluted for use
• not applicable to home use pesticides in •
the home •
• not applicable to outer uncontaminated •
shipping container
triple rinse (equivalent allowed)
fill with water or diluent specified on
the label to 10% three times
rinsate to be reused as pesticide or
disposed of in accordance with all
applicable regulations
puncture or crush rigid containers
Regulations, Section 6684
triple rinse (equivalent allowed)
fill with water or designated carrier to 25%
if less than 5 gallons
fill to 20% if 5 gallons or more
replace closure and agitate
drain for 30 seconds after each rinse
into tank mix
repeat process two more times
1 Delaware - Pesticide Regulations, Section 16.02
• rinsing mandatory immediately upon completion •
of use for glass, metal, plastic containers •
• not applicable for paper, aerosols and
compressed gases, returnable containers
returned to manufacturer for refill, home •
and garden use pesticides and pesticide
containers (must be wrapped in paper prior
to disposal in trash) •
*
triple rinse (equivalent allowed)
drain for at least 30 seconds after steady
flow has ceased initially and drops are
evident
fill to 10% with solvent, usually water,
specififed by manufacturer and capable of
removing residue
agitate, shake or roll vigorously to
dislodge residues from top, bottom, sides
drain for at least 30 seconds after
each rinse, until drops are evident
add rinsate to tank or if pesticide
applied without dilution, dispose of
in accordance with DNREC regs
repeat steps 2-5 two more times
removal of inner liner is equivalent
(liner must be rinsed prior to disposal
if from pesticide that is HW)
puncture prior to disposal if metal or
plastic and not destined for return to
manufacturer or reconditioning
""^ Rorida - Extension Circular 840
• rinsing mandatory for drums, bottles, •
and cans prior to disposal •
drain for 30 seconds intially
fill to 20-25% with water
rinse thoroughly
91
-------
Chapter? Nonrefillable Containers: Residue Removal
Table 7-1
State Triple Rinsing Procedures, continued
Rorida Con't.- Extension Circular 840
add rinsate to spray tank unless pesticide
applied without dilution, allow to drain for
a few seconds
repeat steps 2-4 two more times
add water to tank to bring to needed level
puncture containers after rinsing to
prevent reuse
Louisiana - Department of Agriculture Regulations, Section 13169
triple rinse or equivalent mandatory
immediately upon removal of pesticide
applicable to commercial applicators
applicable to all metal, glass, and plastic
containers, except bulk containers
triple rinse or equivalent
fill to 10% with solvent capable of
removing the pesticide
agitate thoroughly, manually, or with
equipment approved by Department
place rinsate in containment tank for
reuse if rinsate can be used in subsequent
applications without reducing effectiveness
or place in surface impoundment
puncture metal and plastic containers at
both ends before disposal in sanitary landfill
JL Maine - Pesticide Regulations, Chapter 21
mandatory immediately upon removal of
pesticide
applicable to certified applicators
applicable to restricted or limited use
pesticides in metal, glass and plastic
containers one half pint or more in volume
(e.g., containers subject to deposit/
return program)
triple rinse (equivalent allowed)
drain for at least 30 seconds after steady
flow has ceased initially and drops are
evident
fill to 10% with solvent, usually water,
specified by manufacturers and capable of
removing residue
agitate, shake or roll vigorously to dislodge
residues from top, bottom, sides
drain for at least 30 seconds after each
rinse, until drops are evident
add rinsate to tank or if pesticide is applied
without dilution, dispose of in accordance
with label
repeat steps 2-5 two more times
removal of inner liner is equivalent
(liner must be rinsed prior to
disposal if from pesticide that is HW)
puncture prior to disposal if metal or
plastic and not destined for return to
manufacture or reconditioning
92
-------
Pesticide Containers - A Report to Congress
Table 7-1
State Triple Rinsing Procedures, continued
Michigan Extension Bulletin, E-1781 (1984)
not applicable to pressurized containers
triple rinse
drain for 30 seconds initially into spray tank
fill to 25% with appropriate diluent
replace closure, rotate
drain for 30 seconds into spray tank
repeat steps 2-4 two more times
puncture metal after rinsing or break glass
Minnesota - Flyer for Rinse and Win Program; Proper Rinsing Verification Form (4/89)
• triple rinse applicable to plastic,
non-pressurized metal, and glass
containers
• immediately after use
triple rinse or pressure rinse
drain for 30 seconds initially
fill to 10-20% with water or rinse solution
secure cover and swirl container to rinse
all inside surfaces
remove cover, add rinsate to spray tank and
let drain for 30 seconds or more
repeat steps 2-5 two more times
replace cover and dispose of container
according to label
puncture metal and plastic at container
bottom and crush if possible, unless offered
for reconditioning
remove bungs and puncture drums if unable
to recondition
Mississippi - Ryer for Container Collection Program
triple rinse or pressure rinse
drain for 30 seconds initially
fill to 10-20% with water or rinse solution
secure cover and swirl container to rinse
all inside surfaces
remover cover, add rinsate to spray tank
and let drain 30 seconds or more
repeat steps 2-5 two more times
replace cover and dispose of container
according to label
New Hampshire - Pesticide Regulations, Section 801.03
triple rinsing applicable only to
organophosphates in metal containers
other containers to be rinsed at least
twice with suitable solvent and rinsates
buried
cleaning mandatory prior to reuse for
any other purpose
for one gallon: fill with one pint
water and household detergent, rotate
for 5 gallons: fill with 2 quarts, lye,
and detergent
for 30 gallons: fill with 3 gallons, lye,
and detergent
93
-------
Chapter 7 - Nonrefillable Containers: Residue Removal
Table 7-1
State Triple Rinsing Procedures, continued
New Hampshire Con't. - Pesticide Regulations, Section 801.03
• for 50 gallons: fill with 5 gallons, lye,
and detergent
• bury rinsates
• puncture and crush prior to burial
New York - Regulations to the Department of Environmental Conservation, Section 325.4
• triple rinse mandatory for non-
combustible containers prior to
disposal
• containers with pesticide used .
undiluted need only be drained
for 30 seconds
• applicable to certified applicators
drain for 30 seconds initially
fill with water or carrier being used
1 quart for one-gallon container
1 gallon for 5-gallon container
5 gallons for 30- or 55-gallon container
rinse material should be easily measurable
drain for 30 seconds into spray tank
before filling tank or into container
for use as diluent for future formulations
of the same pesticide
repeat steps 2-4 two more times
North Dakota - Extension Brochure 10 SAF-2, 13-AEN&-5-3
• triple rinse mandatory prior to
disposal by burial or landfilling
drain completely
fill 20-25% with water or oil
close and upend container
empty rinse water into spray tank
drain completely, at least 30 seconds
repeat steps 2-5 two more times
keep crushed metal and glass separate
if metal to be sold as scrap
puncture and crush before landfilling
Oklahoma - Department of Agriculture Regulations, Section 3-387
triple rinse or equivalent mandatory
immediately upon removal of pesticide
applicable to commercial applicators
applicable to metal, glass, and plastic
containers
triple rinse (equivalent allowed)
fill to 10% with solvent capable of
removing the pesticide
agitate thoroughly, manually or with
equipment approved by Department
place rinsate in containment tank for
reuse if rinsate can be used in subsequent
applications without reducing effectiveness
or place in surface impoundment
repeat steps 1-3 two more times
puncture metal and plastic at both ends
before disposal in a sanitary landfill
94
-------
Pesticide Containers A Report to Congress
Table 7-1
State Triple Rinsing Procedures, continued
Oregon - DEO Regulations, Chapter 340, Division 109
mandatory for rigid containers prior
to disposal as ordinary solid waste
not applicable to household use containers
verification of cleaning done by observing
no residue on interior or no turbidity
(less than 5 Nephelometric units) in
sample when diluent which does not
solubilize residue is placed in container
to 5% of volume and agitated for 30
seconds
multiple rinse or pressure rinse
fill with appropriate solvent at at least 10%
agitate to rinse all interior surfaces
open container and drain, at least 30 seconds
after drips starts
repeat steps 1-3 at least two more times
puncture or remove both ends of rigid
plastic containers prior to disposal
unless beneficially reused
crush containers smaller than 30 gallons
South Carolina - Extension Brochure PIP-30 (draft), PIP-IS-21-39, PIP-15
mandatory immediately after emptying
triple or pressure rinse
drain for at least 30 seconds into spray tank
fill to 25% with water or appropriate diluent
close and shake vigorously for at least 1 minute
drain for at least 30 seconds into spray tank
(leave room in tank to fill tank after
pesticide is put in and rinsate added)
repeat steps 2-4 two times using clean
water
puncture or crush metal and plastic
unless recycled
South Dakota - Department of Agriculture Regulations, Section 12:56:01.01
rinsing mandatory prior to disposal of
containers that held organic mercury,
lead, cadium, beryllium, selenium, arsenic,
or Inorganics in sanitary landfill
(unrinsed containers may go to specially
designated landfill)
rinsing mandatory prior to selling for
scrap
fill with normal diluent to 20%
add rinsate to spray mix or dispose of
by method prescribed for the pesticide
in chapter 12:56:02
repeat steps 1-2 two more times
puncture prior to disposal in sanitary
landfill
Utah - Cooperative Extension Service Bulletin, Pesticide No. 4, December 1989
metal, glass, plastic containers
should be tripled rinsed (or equivalent)
prior to disposal
not applicable to normal household
products (up to 1 gallon liquid,
5 pounds dry) which may be wrapped
in absorbent material and disposed
of in trash
triple rinse or equivalent
empty and drain for 30 seconds into
spray tank
fill to 25%
rinse thoroughly
pour rinsate into spray tank and drain
for 30 seconds
repeat steps 2-4 two more times
95
-------
Chapter 7 - Nonrefillable Containers: Residue Removal
Therefore, the time it takes to perform the pro-
cedure can be a significant deterrent to effective
residue removal.
The difficulties associated with triple rins-
ing are documented in several studies on the
residue in pesticide containers. J.R. Miles con-
cludes that "triple rinsing is effective, but awk-
ward and time-consuming (4-5 minutes per con-
tainer)."(2) Additionally, J.K. Leasure found
that triple rinsing took an average of 2 minutes
and 40 seconds and concludes that "the triple
rinse procedure is viewed as time-consuming
and difficult to integrate into a custom-spray
operator's tank filling process." (3)
Because triple rinsing is time-consuming,
many end users do not triple rinse. The fact that
many end users do not triple rinse is indicated
by several sources.
In 1978, Southern Illinois University investi-
gated container disposal issues, including the
proportion of containers that were adequately
rinsed. Approximately 1,600 5-gallon metal
containers were collected from 10 farmers and 3
commercial applicators in Jackson and William-
son Counties. (4)
Each container was visually inspected and
classified according to the following criteria:
"rinsed: the can appeared free of visible
chemical;
probably rinsed: the can contained a thin
watery emulsion of the original pesticide; and
probably not rinsed: the can obviously
contained some of the original formulation." (5)
The results of the inspection are given in
Table 7-2. These data show that half of the
containers probably were not rinsed.
Table 7-2.
Results of Container Inspection
Class
Rinsed
Probably rinsed
Probably not rinsed
Number
of Cans
277
544
779
Percentage
/Q/\
1 ^91
17
34
49
SOURCE: Southern Illinois University. Draft of unpublished report on
pesticide container disposal in Illinois. August 24, 1978.
Southern Illinois University also conducted
a survey of farmers and commercial applicators
on actual field rinsing practices. The results of
the survey are consistent with the conclusion
from the container inspection. Approximately
84 percent of the farmers reported rinsing, while
only 35 percent reported triple rinsing. Simi-
larly, 43 percent of the commercial applicators
reported rinsing the containers and 18 percent
reported triple rinsing. (6)
Another conclusion from this survey is that
smaller users are more likely to triple rinse than
larger users. The farmers in the survey used
fewer containers than the commercial applica-
tors, and the percent of farmers reporting triple
rinsing was nearly double the percent of com-
mercial applicators reporting triple rinsing. Also,
the smaller respondents in both categories (farm-
ers and commercial applicators) were more likely
to triple rinse than the larger respondents. (7)
An argument against this data is that it was
generated in 1978 and at that time labels con-
tained inadequate rinsing directions. While
this may be true, recent information shows
similar results. A1988 survey of certified appli-
cators in South Dakota reported that "fifty-five
percent (55%) of farmers triple rinsed their
empty containers. Many of these were single or
double rinsed." (8) Again, a large percent of the
applicators did not rinse their containers. These
results, therefore, are consistent with the Illi-
nois data.
96
-------
Pesticide Containers - A Report to Congress
Additional information on current rinsing
practices is being compiled through many of the
state container collection programs. At the 1990
Iowa container collection pilot program, about
half of the containers were rejected because they
were not properly rinsed. (9) At three county
collections in the 1990 Minnesota pilot project,
the container rejection rate ranged from 14.5 to
27.7 percent.(lO)
The Minnesota Department of Agriculture
surveyed the participants in the pilot collection
programs on container disposal issues. One of
the questions was "Why do you rinse your con-
tainers?" The results of the survey at the four
collection sites are summarized in Table 7-3.
Safety and environmental concerns were the
main reasons the participants rinsed their con-
tainers.
Table 7-3
Reasons for Rinsing Pesticide Containers
from 1990 Minnesota Survey
REASON NUMBER
FOR OF
RINSING RESPONSES1
Environmental concerns
Safely concerns
Economic concerns
It is on the label
Because it is required by
this project
Other: common sense
Other because it is the law
45
44
30
13
5
2
1
PERCENT
OF TOTAL
RESPONSES
71
70
48
21
8
3
2
1. There were 63 total reponses to the question "Why do you rinse your contain-
ers?" Participants could list more than one answer. •
SOURCE: R. Hansm, Minnesota Department of Agriculture, letters to T.
Bone, U.S. EPA, Office of Pesticide Programs, October 4,1990 and November
1,1990.
7.2.3 Pressure Rinsing
Pressure rinsing, another residue removal
procedure, can be performed in several ways.
The most common method is to invert a drained
container over the spray tank and puncture the
bottom or side of the container with a special-
ized nozzle connected to a source of pressurized
water. The water is then sprayed into the con-
tainer and the rinsate drains directly into the
spray tank. Figure 7-1 shows two types of
pressure rinsing nozzles. Another method of
pressure rinsing is to invert the container over a
vertical pressure rinsing probe that is attached
to a funnel. Again, the water is sprayed into the
container and the rinsate is directed into the
spray tank by the funnel.
7.2.3.1 Federal Standards
EPA does not have a definition of pressure
rinsing because it was not a common practice in
1974 when the existing 40 CFR Part 165 regula-
tions and recommendations were written.
7.2.3.2 State Standards
Only a few states have addressed pressure
rinsing at this time, since it is a new develop-
ment. As with triple rinsing, there are varying
definitions of pressure rinsing. The available
procedures are given in Table
7.2.3.3 Agricultural Standards
As with triple rinsing, NACA has issued rec-
ommendations on pressure rinsing. The recom-
mended procedure is to:
"•Place the empty container (metal or plastic)
in a vertical position to drain into the spray
tank.
•Thrust the nozzle of the pressure rinser
through the bottom of the empty container.
97
-------
Chapter 7 - NonrefiUdble Containers: Residue Removal
»u re 7-1
Pressure rinsing nozzles
SOURCE: National Agricultural Chemicals Association, Empty Container Disposal: Safe Practices for Agricultural Chemical Users, 1986, 1990 reprint.
•Rinse for at least 30 seconds.
•Crush to reduce volume."(11)
7.2.3.4 Actual Practice
Many people in the agricultural segment of
the pesticide industry believe pressure rinsing
is the technique of the future. As currently
practiced, it is faster and less awkward than
triple rinsing. Another benefit of pressure rins-
ing is that the container is punctured, which
prevents the container from being reused.
Additionally, this hole can be used as a indica-
tor that the container was probably rinsed.
The data initially generated show that pres-
sure rinsing is more effective than triple rins-
ing. More recent data, however, show that
pressure rinsing may be less efficient than triple
rinsing. This is discussed in greater detail in
section 7.4.3.
7.2.4 Bags
7.2.4.1 Federal Standards
The only current EPA guidance on remov-
ing residue from bags is the container disposal
statement on the label. In general, the label
directs the user to completely empty the bag
into the application equipment.
7.2.4.2 State Standards
Several states have defined procedures for
emptying bags through educational brochures
or regulations. These procedures are given in
Table 7-5 and generally direct the user to shake
or tap the bag. Some of the procedures include
directions for cutting or opening the bag in a
certain manner.
7.2.4.3 Actual Practice
Bags can hold either concentrated or ready-
to-use pesticides. Regardless of the application
method of the product, bags usually are not
rinsed by the user. Bags for those pesticides
designed to be diluted with water could be
rinsed and the rinse water added to the applica-
tion mixture, although this is not a common
practice. Foil- and plastic-lined bags could
readily stand up to contact with the rinse water.
98
-------
Pesticide Containers A Report to Congress
Table 7-4
State Pressure Rinsing Procedures
^ California - Department of Food and Agriculture Regulations, Section 6684
rinsing mandatory "at time of use" for
- containers holding less than 28 gallons
liquid that is diluted for use
not applicable to home use pesticides in
the home
not applicable to outer uncontaminated
shipping container
• triple rinse or pressure rinse
• invert over nozzle in mix tank and
rinse until solution is clear
• use minimum of 50% of container
volume and 15 pounds pressure
JT Minnesota - Flyer for Rinse and Win Program; Proper Rinsing Verification Form (4/89)
• pressure rinse applicable to plastic and
non-pressurized metal
• immediately after use
triple rinse or pressure rinse
drain for 30 seconds initially
hold container over tank so rinsate runs into tank
insert nozzle through bottom of container
rinse for manufacturer's recommended time,
generally 30 seconds or more
puncture metal and plastic at container bottom
and crush if possible, unless offered for
reconditioning
remove bungs and puncture drums if unable
to recondition
Mississippi - Flyer for Container Collection Program
applicable to plastic and non-pressurized
metal
triple rinse or pressure rinse
drain for 30 seconds initially
hold container over tank so rinsate runs into tank
insert nozzle through bottom of container
rinse for manufacturer's recommended time,
generally 30 seconds or more
replace cover
Oregon - DEQ Regulations, Chapter 340, Division 109
mandatory for rigid containers prior
to disposal as ordinary solid waste
not applicable to household use
containers
verification of cleaning done by
observing no residue on interior
or no turbidity (less than 5
Nephelometric units) in sample
when diluent which does not
solubilize residue is placed in
container to 5% of volume and
agitated for 30 seconds
multiple rinse or pressure rinse
insert nozzle so that all surfaces can be rinsed
rinse thoroughly using appropriate solvent
puncture or remove both ends of rigid containers
prior to disposal unless beneficially reused
crush containers smaller than 30 gallons
99
-------
Chapter 7 Nonrefillable Containers: Residue Removal
Table 7-4
State Pressure Rinsing Procedures / continued
^^ South Carolina - Extension Brochure
• mandatory immediately after emptying
||[ Utah - Cooperative Extension Service
• metal, glass, plastic containers should
be triple rinsed (or equivalent) prior
to disposal
• not applicable to normal household
products (up to 1 gallon liquid, 5
pounds dry) which should be wrapped in
absorbent material and disposed in trash
PIP-30 (draft), PIP-15-21-89, PIP-15
• drain into spray tank for at least 30 seconds
• puncture container with nozzle over spray tank
• rinse for recommended time, at least 30 seconds
Bulletin, Pesticide No. 4, December 1989
• rinse for 60 seconds with jet spray device
or rig hose and spray rinser
• put rinsates into tank
SOURCE: B. Lounsbury, draft report, October 29, 1990.
One issue with rinsing bags is adequately clos-
ing the bag so the worker could shake the bag
without being exposed.
As discussed in Chapter 6, there are a variety
of ways to open bags. These methods include
cutting different parts of the bag with a knife,
splitting the bag with a shovel, and breaking the
bag against the application equipment. Table 7-
5 contains several state procedures that recom-
mend or require different ways to cut bags.
EPA believes that the method used to open a
bag is one of the major variables in the amount
of residue retained in the bag.
7.2.5 Ready-to-Use Pesticides
Ready-to-use pesticides are not designed to
be diluted; they are applied as purchased. These
pesticides are packaged in both rigid containers
and bags. Rinsing the rigid containers is not
currently recommended. The rinsate cannot be
added to the application mixture, because there
is no application mixture.
No studies have been published on the level
of residue remaining in the empty containers of
ready-to-use products. While these pesticides
generally have low active ingredient concentra-
tions and the amount of liquid remaining in the
container may be small, the number of contain-
ers is large. Therefore, these empty containers
potentially represent a hazard to both the worker
and the environment.
7.2.6 Aerosol Containers
Aerosol containers pose a similar problem to
bags and ready-to-use pesticide containers in
that they cannot be opened and rinsed. Addi-
tionally, even if they could be opened, aerosol
containers hold ready-to-use pesticide formula-
tions, so the resulting rinsate would be a dis-
posal problem.
100
-------
Pesticide Containers - A Report to Congress
Table 7-5
State Bag Residue Removal Procedures
Arizona - Pesticide Regulations, R3 10-313
For bags:
• fold and tie bags or enclose in secondary container
Rorida Extension Circular No. 840
For bags:
• shake clean
Louisiana - Department of Agriculture Regulations, Section 13169
For paper and plastic bags:
• remove pesticide to maximum extent possible when intially mixed
• cut sides and open fully without folds on a flat surface, shake pesticide to mix
• cut and flatten bags prior to disposal in landfill
Michigan - Extension Bulletin, E-1781 (1984)
For paper containers
• cut off ends of paper containers
North Dakota - Extension Brochure 10 SAF-2, 13-AENG-5-3
For bags or containers with dry materials:
• empty as completely as possible
• shake or tap container
Oklahoma - Department of Agriculture Regulations, Section 3-387
For paper and plastic bags:
• remove pesticide to maximum extent possible when initially mixed
• cut sides and open fully without folds on a flat surface, shake pesticide into mix
South Carolina - Extension Brochure PIP-30 (draft), PIP-IS-21-89, PIP-15
For bags:
• empty into spray tank, open both ends
• tap bags to dislodge particles or rinse bags (PIP-IS-21-89)
• cut X or H in bags (PIP-15)
Utah - Cooperative Extension Service Bulletin, Pesticide No. 4, December 1989
For paper bags:
• empty thoroughly
SOURCE: B. Lounsbury, draft report, October 29,1990.
101
-------
Chapter 7 - Nonrefillable Containers: Residue Removal
7.3 Variables in Residue Removal
Many variables are involved with the effi-
ciency of residue removal. The four main vari-
ables are the procedure used, the timing of the
procedure, the f ormulation, and the container.
The discussion of the four variables involved
with residue removal is included to show that
EPA cannot simply address one of the variables,
e.g., focusing on container designs, and hope to
solve or prevent all residue removal problems.
7.3.1 Procedure
Both triple rinsing and pressure rinsing have
been discussed in detail. Both can be effective
methods for cleaning containers. The available
information does not clarify which method of
residue removal is more efficient. This is dis-
cussed in detail in section 7.4.3.
EPA believes that the method used to open a
bag is one of the major variables in determining
the amount of residue retained in bags. With
ready-to-use pesticide containers and aerosol
cans, the only available method is to drain the
container completely.
7.3.2 Timing of the Procedure
The timing of the procedure is another fac-
tor. Many of the states specify that the residue
removal procedure be performed immediately
upon removal of the pesticide from the con-
tainer. This is important in order to prevent the
pesticide from drying or caking onto the con-
tainer. Residue is difficult to remove once the
pesticide has dried, because the product does
not disperse readily when water or other dilu-
ent is added.
One of the major reasons containers were
rejected by the Minnesota Department of Agri-
culture in its container collection programs was
the presence of visible quantities of residue.
The Department of Agriculture concluded that
these containers were not rinsed immediately at
the time of use.(12)
7.3.3 Formulation
The third major variable in residue removal
is the formulation of the pesticide, which has
been determined to affect the amount of residue
in several ways.
According to Dana Peck, a major factor de-
termining the effectiveness of triple rinsing is
the viscosity of the formulation. Clearly, "those
products with a lower viscosity typically drain
more extensively ."(13)
H.E. Braun compares the residue removal
ability of the different types of formulations.
This study concludes that the ease of removing
pesticide residues is related to the tested formu-
lation types in the following order: wettable
powder (WP) > solution (S) > emulsifiable con-
centrate (EC) >flowable suspension (FS). Braun
explains that "solutions are less viscous than
emulsifiable concentrations, while flowable
suspensions tend to settle or cake at the bottom
of the container and thus tend to be difficult to
remove." (14)
This study also discusses the issue of solu-
bility.
"Flowable suspensions which did not drain
well during inversion resulted in a large re-
moval of the retained pesticide in the first
rinse...; this removal was attributed to the
physical loosening of the deposited material by
the rinsing and shaking action. The amount of
pesticide recovered in each of the rinses may
also be correlated to the water solubility...The
highly water soluble methomyl was almost
totally removed with a single rinse, whereas
captafol and chlorothalonil, being only spar-
ingly soluble in water, were rinsed out with
much more difficulty." (15)
102
-------
Pesticide Containers A Report to Congress
T.E. Archer also discusses the idea of solu-
bility. "It has been shown in previous studies...
that the efficiency of parathion removal from
noncombustible used pesticide containers by
solvent washing is independent of the chemical
properties of the solvents, and this also appears
to be true for the 2,4-D formulations. The im-
portant factors to be considered are solubility of
the pesticide in the solvent, or partition between
the inner surface of the container and the sol-
vent, and the presence of adjuvants, or emulsi-
fiers. The latter is particularly important when
water is used."(16)
In recent years there have been significant
improvements in the physical properties of water-
based suspensions. The rinsing properties of
these pesticides now match those of emulsifi-
able concentrates, as demonstrated by the work
of Tiernan at Wright State University. This
work also shows that water-soluble products
are the easiest materials to rinse from contain-
ers.(17)
7.3.4 Container
The fourth variable regarding residue re-
moval is the container. Important factors are the
material of construction, the shape of the con-
tainer, and the size of the container.
7.3.4.1 Material of Construction
Metal containers are known to retain more
residue than plastic or glass containers. This is
probably not caused solely by the interaction of
the product and the container walls; the con-
struction of metal containers creates areas where
the product can be retained. For example, the
chime readily traps material.
Materials of construction are also important
factors for bags. Multiwall paper bags usually
have an inner layer that facilitates residue re-
moval. There does not seem to be much interac-
tion between the container and the formulation
with the commonly used barrier plies, such as
foil or laminates. However, this may not be the
case \vith plastic bags. The pesticide product
can adhere to the inner surface of plastic bags
because of the buildup of a static charge within
the plastic.(18)
7.3.4.2 Shape of the Container
The shape of the container is an important
factor in the amount of pesticide that is retained
in the container.
Peck concludes that the shape of the con-
tainer is one of the two main factors that deter-
mine the effectiveness of a triple rinse. "Those
products that were a "pour" neck, as opposed
to a flathead container, drained more exten-
sively. The flathead two (2) gallon can does not
drain thoroughly. To drain the can as much as
possible requires rocking the can back and
forth and then letting it drain 30 seconds. It
was very difficult to drain the can thoroughly
unless the rocking motion was used." (19)
A similar statement can be made regarding
5-gallon flathead metal containers. Hsieh sug-
gests that: "the important factor in determin-
ing how much formulation remains in a con-
tainer is the geometry and location of the con-
tainer's spout." (20)
The location of the container's spout is dearly
an important factor. For example, it is easy to
understand that pesticide would empty more
completely from a container shaped like a bleach
bottle than from a flathead container with the
opening several inches from the seam of the
container.
103
-------
Chapter 7 - Nonrefillable Containers: Residue Removal
Another example of a design feature that
might easily retain residue is the hollow handle
on 1- and 2.5-gallon "F"-style containers. The
handle may not receive sufficient diluent, agita-
tion, or draining when the container is triple or
pressure rinsed.
A design feature of bags that is known to
retain residue is the corners at the base of the
bag. Many bags are designed with gussets, or
folds, in the sides. When the bottom of the bag
is sewn or folded, these gussets form "pockets"
where the pesticide can be trapped and re-
tained.
7.3.4.3 Size of the Container
The size of the container is another factor de-
termining the amount of residue left in the
container. Larger containers have a larger sur-
face area; therefore, more pesticide adheres to
the interior of the container. Also, larger con-
tainers are bulkier and it is harder to effectively
"shake and swirl" them during the rinsing
procedure.
7.4 Studies of Residue Removal
7.4.1 General
Between 1972 and 1990, 11 studies meas-
ured the amount of residue left in pesticide con-
tainers after they had been used. These studies
include mainly containers for agricultural prod-
ucts, so they present a limited view of the con-
tainers and formulations that comprise the
pesticide industry. Each study had a different
purpose and utilized a variety of collecting,
rinsing, and reporting procedures. Some of the
procedures are not very clear, so comparisons
are difficult to make. About half of the studies
can be classified as laboratory studies where the
containers and the rinsing procedures were
closely controlled. The others can be consid-
ered field studies. These were conducted in the
field or were designed to simulate field condi-
tions.
The studies do provide information on con-
tainer rinsing, the residue remaining, and some
of the problems encountered in trying to re-
move the residue from the container. Many of
the studies address metal containers that were
popular in the mid-1970's. In the past decade,
small metal containers generally have been
replaced with plastic containers. Therefore,
these studies are not as applicable to the agricul-
tural market as when they were originally
published. The works of Tiernan and Formu-
logics, produced in 1990, reflect the current
market.
In order to consolidate and compare the
data, it was necessary to develop a "dimension-
less" means of comparison. For this report, the
percent removal is the basis for comparison.
Many of the studies reviewed defined percent
removal in terms of the mass of active ingredi-
ent (a.i.) removed in a particular rinse com-
pared to the mass of a.i. remaining in the con-
tainer after it had been drained, or some vari-
ation of this approach. EPA has chosen to define
percent removal in terms of the concentration of
active ingredient in a given rinsate compared to
the original concentration of active ingredient
in the formulation. This approach was chosen
for several reasons:
•The results from containers of different sizes
and formulations with varying a.i. concen-
trations can be compared;
•The amount of a. L in a given rinsate repre-
sents the quantity that could potentially
reach the environment;
•The concentration in the rinsate is actually
what is measured during the studies;
•Triple and pressure rinsing results can be
compared easily.
104
-------
Pesticide Containers - A Report to Congress
Table 7-6
Triple Rinse: Tiernan, 1990
Rinse no.
Atrazine 4L,
1
2
3
Atrazine 4L,
1
2
3
4
Mass A.I.
Rlnsate
(mg)
2.5-gallon plastic jug
16,600.00
129.00
9.48
2.5-gallon plastic jug
18,600.00
180.00
7.28
1.41
Volume
Rlnsate
(ml)
original a.i. =
1022
1035
1017
original a.i. =
1010
1002
1007
1003
Malathion-5EC, 2.5-gallon plastic jug original a.i.
1
2
3
4
2,4-D Amine,
1
2
3
4
5,050.00
17.90
3.04
1.56
2.5-gallon plastic jug
3,210.00
27.70
0.30
0.01
1001
1012
1007
1011
original a.i. =
1009
1006
1005
1001
A.I.
Cone.
(g/l)
4 Ib/gal = 479.
16.243
0.125
0.009
4 Ib/gal = 479.
18.416
0.1796
0.0072
0.0014
A
(no units)
306 g/l
0.03389
0.00026
0.00002
306 g/l
0.0384
0.0004
0.00002
0.000003
Percent
Removal (%)
96.611
99.974
99.998
96.158
99.963
99.998
99.9997
= 5 Ib/gal = 599.132 g/l
5.045
0.018
0.003
0.002
0.0084
0.00003
0.000005
0.000003
99.158
99.997
99.9995
99.9997
4 Ib/gal = 479.306 g/l
3.181
0.0275
0.0003
0.00001
0.0066
0.00006
0.0000006
0.00000002
99.336
99.994
99.99994
99.99999
SOURCE: T.O.Tie mm, Wright State University, "Assessment of Rinsing Procedures for Removing Pesticides from Containers Used by Agricultural Applicators,
Quarterly Progress Report submitted to U.S. EPA, Risk Reduction Engineering Laboratory, February 1,1990.
Percent removal is calculated in the follow-
ing way. The concentration of active ingredient
after a specific rinse or at a specified time in the
pressure rinse is determined. Then the ratio of
the concentration of a.i. in the rinsate to the
original concentration of a.L in the formulation
is calculated. This quantity is referred to as "A"
and is defined as:
7.4.2 Triple Rinsing
This section summarizes the data on triple
rinsing from the available studies. The rinse
procedures used in the different papers are
presented in Appendix A.
7.4.2.1 Data
„. . . .. r • / / i\ In 1990, Tiernan of Wright State University
A Rinsate concentration of a.L (mg/ml) , , '^ , ^ , .J
A = —— ' reported to EPA the results of a lab study de-
Original concentration of a.i. (mg/ml) signed to determine the efficiency of triple rins-
ing. (21) Tiernan used water to rinse 2.5-gallon
Finally, the percent removal, expressed as a plastic containers that had held Atrazine 4L,
percent, is calculated as: Malathion-5 EC, and 2,4-D Amine. The individ-
ual rinses were analyzed. The containers were
Percent removal = [ 1.0 - A ] X100. then rinsed with solvent and the solvent rinses
105
-------
Chapter 7 Nonrefillable Containers: Residue Removal
were analyzed.
Tiernan noted that the water-based 2,4-D
Amine formulation rinsed from the container
readily. The reduction in the mass of a. L in the
second rinsate was greater than 1000-fold. The
of a.i. The water-based suspension and the
solvent-based emulsifiable concentrate had
measurable quantities of the a.L in each water
rinse. However, when the aqueous suspension
and the emulsifiable concentrate containers were
rinsed with solvent, additional a.i. was recov-
solvent rinses did not remove significant amounts ered. In other words, quantities of pesticide
Table 7-7
Triple Rinse: Archer, 1975
Rinse No.
Formula 402,
1
2
3
4
Formula 40,
1
2
3
4
Formula 40,
1
2
3
4
Esteron 99 2,
1
2
3
4
Esteron 99,
1
2
3
4
Mass A.E.
Rinsate1
(mg)
5-gallon metal can
10,200
624
060
25
30-gallon metal drum
34,900
3,200
682
175
55-gallon metal drum
59,900
8,520
1,070
150
Sfrgallon metal drum
30,500
9,800
5,540
3,540
5&gallon metal drum
58,850
12,200
4,110
1,650
Volume
Rinsate
(ml)
250
250
250
250
750
750
750
750
1000
1000
1000
1000
750
750
750
750
1000
1000
1000
1000
A.E.
Cone.1
(g/l)
40.800
2.496
0.240
0.100
46.533
4.267
0.909
0.233
59.900
8.520
1.070
0.150
40.667
13.067
7.387
4.720
58.850
12.200
4.110
1.650
A
(no units)
0.08512
0.00521
0.00050
0.00020
0.09708
0.00890
0.00190
0.00049
0.12497
0.01778
0.00223
0.00031
0.08484
0.02726
0.01541
0.00985
0.12278
0.02545
0.00857
0.00344
Percent
Removal (%)
91.488
99.479
99.950
99.979
90.292
99.110
99.810
99.951
87.503
98.222
99.777
99.969
91.516
97.274
98.459
99.015
87.722
97.455
99.143
99.656
1.2.,4-D acid equivalent (a.e.) in alkanolamine salts of 2,4-D for the formula 40 formulation data and 2,4-D a.e. in propylene glycol butyl ether esters of
2,4-D for the Esteron 99 formulation.
2. The orignial acid equivalent concentration in both formulations was 4 Ib/gal or 479306 g/l.
SOURCE: T.E. Archer, "Removal of2,4-Dichlorophenoxyacetic Acid (2,4-D) Formulations from Noncombustible Pesticide Containers." Bulletin of Environmental
Contamination and Toxicology, Vol. 13, Number 1, (January 1975): pp. 44-51.
106
-------
Pesticide Containers A Report to Congress
Table 7-8
Triple Rinse: Peck, 1985
Rinse
Mass A.I.
no. Residual
(mg)
Carbofuran Furadaiv4F, 1-gallon plastic
1
2
3
Disulfoton
1
26.1
1.1
0.05
Disystox 8, 2-gallon flathead
160
4.7
2.9
Volume
Residual
(ml)
container
3
2
1
metal can
10
10
10
Cone. A.I.
Residual
(g/l)
original a.i. = 4
8.700
0.550
0.050
original a.i. =
16.000
0.470
0.290
Endosulfan - Thiodan SEC, 2-gallon flathead metal can original a.i.
1
2
3
37
5.4
2.3
10
10
10
Methamidophos - Monitor 4, 2-gallon flathead metal
1
2
Demeton
1
3
w
Dinoseb -
1
67.5
6.73
1.38
15
15
15
3.700
0.540
0.230
can original a.!
4.500
0.449
0.092
- Systox 6, 2-gallon flathead metal can original a.i. = 6
230
14
8.6
Premerge 3, 5-gallon flathead
760
22
3.0
10
10
10
metal can
50
50
50
Oxydemeton - Metasystox-R, 2-gallon flathead metal
1
2
Paraquat
1
Azlnphos
1
3.7
0.87
Paraquat, 1-gallon plastic jug
2.85
0.043
0.003
15
15
original a.
1
1
1
23.000
1.400
0.860
A
(no units)
Ib/gal = 479.306 g/l
0.0182
0.0011
0.0001
8 Ib/gal = 958.611 g/l
0.0167
0.0005
0.0003
= 3 Ib/gal = 359.479
0.0103
0.0015
0.0006
. = 4 Ib/gal = 479.306
0.0094
0.0009
0.0002
Ib/gal = 718.959 g/l
0.0320
0.0019
0.0012
Percent
Removal (%)
98.185
99.885
99.990
98.331
99.951
99.970
g/l
98.971
99.850
99.936
g/l
99.061
99.906
99.981
96.801
99.805
99.880
original a.i. = 3 Ib/gal = 359.479 g/l
15.200
0.440
0.060
can original a.
0.247
0.058
i. = 2 Ib/gal =
2.850
0.043
0.003
methyl Guthion, 5-gallon flathead metal can original a.i.
180
2.55
0.27
30
30
27
6.000
0.085
0.010
0.0423
0.0012
0.0002
95.772
99.878
99.983
. = 2 Ib/gal = 239.653 g/l
0.0010
0.0002
239.653 g/l
0.0119
0.0002
0.00001
= 2 Ib/gal = 239.653
0.0250
0.0004
0.00004
99.897
99.976
98.811
99.982
99.999
g/l
97.496
99.965
99.996
SOURCE: D. Peck. "The Determination of Residue of Certain Pesticides After Triple Rinsing." August 1985.
107
-------
Chapter 7 Nonrefillable Containers: Residue Removal
were recovered in excess of what the last water
rinse had removed.
The fourth rinsate from the Atrazine and
Malathion containers showed a percent removal
of 99.9997, whereas the 2,4-D Amine container
achieved 99.9999 percent removal. The data are
summarized in Table 7-6.
Tiernan also noted that the main areas of the
container that retained formulation were the
threads on the neck of the container and the
internal surfaces of the hollow container handle.
Archer published the results of a study on
the ease of removal of 2,4-Dichlorophenoxy-
acetic acid from various containers in 1975.(22)
Flathead steel drums with capacities of 5, 30,
and 55 gallons were tested. The net retention
volume or weight of active ingredient for each
formulation and container combination was
measured. The containers were then rinsed
with varying numbers of water or organic sol-
vent rinses and the efficacy of the removal was
determined.
A problem with this study was the limited
amount of water or solvent added to rinse the
containers. The volume of liquid that was added
varied from 0.5 to 1.3 percent of the container
capacity. However, the triple rinse procedures
in Table 7-1 require adding a volume of liquid at
least equal to 10 percent of the container capac-
ity. Table 7-7 shows the results of the percent
removal calculations for this study. Despite the
small volume of water added to rinse the con-
tainers, the efficacy of removal for the fourth
rinse ranges from 99.015 to 99.979 percent. The
lower value was for rinsing a 30-gallon drum
and the higher value was for a 5-gallon can.
In 1985, Peck reported on the Maine con-
tainer rinsing program. (23) This was a lab
study for triple rinsing. Estimates on the amount
of a.i. left in the drained containers were made
and used to determine the efficacy of triple rins-
ing. The data are given in Table 7-8 and gener-
ally show that a triple rinse with water can effec-
tively remove a large percent of the residue left
in the drained container. The calculation of
percent removal was difficult based on the
available data. For the values computed, the
efficiency ranged from 99.880 to 99.999 percent
for the third rinse.
Braun determined the effectiveness of rins-
ing pesticide containers with water at selected
field locations. (24) The testing was carried out
between 1979 and 1981. The rinsing was done
immediately after the normal emptying of con-
tainers by commercial applicators. The contain-
ers were rinsed a total of five times with 10
percent of the stated volume.
A comparison of the data for the fourth rinse
can be made, as shown in Table 7-9. The percent
removal ranged from 99.759 to 99.998 percent.
Most of the values "were in the 99.98 percent
range. The study included both metal and
plastic containers, varying from 1 to 5 gallons in
volume and composition. This study provides
data on a variety of containers and makes com-
parisons between different formulation types.
In 1987, Richard Frank studied the residue
remaining in drums for the Ontario Ministry of
Transportation and Communications, which was
interested in monitoring the effectiveness of its
drum rinsing system. (25) Drums of dicamba
and 2,4-D alone and in combination with di-
chlorprop and pichloram were tested. Again,
several assumptions had to be made in order to
calculate the percent removal. The resulting
data are presented in Table 7-10. The lowest
percent of removal for the fourth rinse was
99.907 and the highest 99.966 percent.
In 1972, Dennis Hsieh measured the amount
of residue left in parathion containers. (26) The
inner surfaces of the containers were coated by
108
-------
Pesticide Containers - A Report to Congress
Table 7-9
Triple Rinse: Braun, 1983
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
Rinse no.
Mass A.I.
Rlnsate (g)
A.I. Cone.*
M)
A
(no units)
Percent
Removal (%)
1979
Azinphosmethyl - Guthion, EC2, 240 g/l, 18-liter metal container
1
2
3
4
Carbofluran
1
2
3
4
16.07
5.20
1.65
1.04
8.928
2.889
0.917
0,578
0.0372
0.0120
0.0038
0.0024
96.280
98.796
99.618
99.759
Furadan FS, 575 g/l, 3.8-liter plastic container
152.15
9.64
1.10
0.04
Captafol Difolaton, FS, 240 g/l,
1
2
3
4
120.24
30.60
8.39
5.04
Methomyl - Lannate, S, 210 g/l,
1
2
3
4
1.95
0.12
0.02
<0.01
Parathion - Parathlon, EC, 80 g/l.
1
2
3
only three
1980
Azinphosmethyl
1
2
3
4
Chlorothalonil -
1
2
3
4
400.395
25.368
2.895
0.105
18-iiter metal container
66.800
17.000
4.661
2.800
3.8-liter plastic container
5.132
0.316
0.053
<0.026
4.5-liter glass container
0.6963
0.0441
0.0050
0.0002
0.2783
0.0708
0.0194
0.0117
0.0244
0.0015
0.0003
<0.0001
2.03 4.511 0.0564
0.54 1.200 0.0150
0.01 0.022 0.0003
rinses because of accidental breakage of container
- Guthion, EC, 240
3.02
0.32
0.08
0.06
Bravo, EC, 400 g/l,
1.76
1.74
0.36
0.14
g/l, 18-iiter metal container
1.678
0.178
0.044
0.033
7.6-liter metal container
2.316
2.289
0.474
0.184
0.0070
0.0007
0.0002
0.0001
0.0058
0.0057
0.0012
0.0005
30.366
95.588
99.497
99.982
72.167
92.917
98.058
98.833
97.556
99.850
99.975
>99.987
94.361
98.500
99.972
99.301
99.926
99.981
99.986
99.421
99.428
99.882
99.954
109
-------
Chapter 7 Nonrefillable Containers: Residue Removal
Table 7-9
Triple Rinse: Braun, 1983, continued
_, ., Mass A.I.
Rlnse No- Rlnsate 99.998
, FS, 480 g/l, 40-liter plastic container
8.92
5.16
2.87
2.36
FS, 480
49.60
2.44
0.45
0.13
S, 210
1.14
<0.01
2.230
1.290
0.718
0.590
g/l, 20-liter plastic container
24.800
1.220
0.225
0.065
g/l, 3.8-liter plastic container
3.000
<0.026
0.0046
0.0027
0.0015
0.0012
0.0517
0.0025
0.0005
0.0001
0.0143
<0.0001
99.535
99.731
99.851
99.877
94.833
99.746
99.953
99.986
98.571
>99.987
1. The amount of water used equals one-tenth the volume of the container.
2. EC - Emulsifiable Concentrate; PS - Flowable Sustpension; S - Solution.
SOURCE: H.E. Braun, etal., "Efficiency of Water Rinsing for tie Decontamination of Used Pesticide Containers." Archives of Environmental Contamination and
Toxicology.
110
-------
Pesticide Containers A Report to Congress
Table 7-10
Triple Rinse: Frank, 1987
Rinse No. Mass A.E.1
Rlnsate (g)
2
1
2
3
A.E. Cone. A
(g/l) (no units)
Percent
Removal (%)
,4-D Amine, 1O 205-liter drums, assume 22.5 liters rinsate
assume original a.e. concentration = 560 g/l
584
64
30
25.956
2.844
1.333
0.0463
0.0051
0.0024
95.365
99.492
99.762
Dicamba, 5 115-liter drums, assume 13.5 liters rinsate
original a.e. concentration = 400 g/l
1
2
3
4
429
106
32
4
2,4-D/dichlorprop combination
assume original a.e.
1
2
3
4
2
1
2
3
4
351/
268
23/
12
10/
6
3/
3
31.778
7.852
2.370
0.296
2, 10 205-liter drums, assume 22.
concentration = 393/305 g/l
15.600/
11.911
1.022/
0.533
0.444/
0.267
0.133/
0.133
,4-D/pichloram combination3, 10 205-liter drums, assume 22.5
original a.e. concentration = 240/60 g/l
280/
66
13/
5
7/
4
5/
1
12.444/
2.933
0.578/
0.222
0.311/
0.178
0.222/
0.044
O.O794
0.0196
0.0059
O.0007
5 liters rinsate,
0.0397/
0.0391
O.OO26/
O.O017
0.0011/
0.0009
O.OO03/
O.OOO4
liters rinsate
0.05 19/
0.0489
O.O024/
O.OO37
O.OO13/
O.OO30
O.OOO9/
O.OOO7
92.O56
98.O37
99.407
99.926
96.031/
96.095
99.74O/
99.825
99.8S7/
99.913
99.966/
99.956
94.815/
95.111
99.7S9/
99.63O
99.87O/
99.704
99.907/
99.926
1 A.E. = add equivalent.
2 The first number of each pair of numbers refers to 2,4-D and the second refers to dtehloroprop.
3 The first number of each pair of numbers refers to 2,4-D and the second refers to ptehloram.
SOURCE: R. Frank, et al, "A System for Rinsing Herbicide from Drums During Highway Right-of-Way Spray Operations." Bulletin of Environmental
Contamination and Toxicology. Vol. 39, (1987): pp. 680-687.
Ill
-------
Chapter 7 Nonrefillable Containers: Residue Removal
Table 7-11
Retention Volume: Hsieh, 1972
Container
125 ml glass
1-gallon glass
1-gallon metal
5-gallon metal
bottle
bottle
can
can
55-gallon metal drum
Volume
Residue1
(ml)
0.3
0.6
14.0
40.0
90.0
Inner
Surface
Area
(In*)
22
222
244
658
3040
Unit
Vol
Retent2
(ml/I)
2.4
0.2
3.7
2.1
0.4
Unit
Surf.
Area Res.8
(mg/ln*)
13.6
2.7
57.3
60.8
29.6
1. Volume of residual formulation.
2. Unit volume retention.
3. Unit surface area residual.
SOURCE: D.P.H. Hsieh, et. al., "Decontamination ofNoncombustible Agricultural Pesticide Containers by Removal of Emulsifwble Parathion." Environmental
Science and Toxicology. Vol. 6, Number 9, (September 1972): pp. 826-829.
swirling a limited amount of the product in the
containers. The containers were then drained
and rinsed. The data are not converted to
percent removal because they are not suited to
this calculation. The data presented in Table 7-
11 compare the inner surface area of the contain-
ers to the amount of formulation retained.
In 1976, J.G. Lamberton studied the amount
of pesticide retained in 30- and 55-gallon metal
drums. (27) This work included opening the
container, removing portions of the container
walls, and analyzing the container sections for
the active ingredient. The data generated could
not be used to calculate the percent removal.
This paper is included to inform the reader of
the existence of the study.
The work of Miles in 1983 is important be-
cause it shows \vhat can happen if the user does
not rinse the containers immediately.(28) More
than 3,500 containers from approximately 50
Canadian growers were collected and inspected
to determine if they were rinsed. The residue in
some of the unrinsed containers was measured.
The amount of product recovered from these
unrinsed containers was found to be significant.
Some of the unrinsed containers were triple
rinsed after the containers had been allowed to
remain in the field, which permitted the residue
to dry out. In general, dried residue is difficult
to remove. The amount of data presented was
not sufficient to calculate the percent removal.
Also, several of the growers were given
pressure rinse nozzles. Their pressure-rinsed
containers were collected separately and ana-
lyzed. No substantial difference was found
between the containers that were triple rinsed
and pressure rinsed.
This study revealed that several of the con-
tainers had significant amounts of product dried
onto the bottom. Two of the 1-gallon plastic
containers that held Furadan had significant
amounts of residue; one had a 200-gram dry
cake that assayed about 60 percent a.i. and the
other had a 144-gram dry cake that assayed
about 85 percent a.i. The smaller cake and its
container had a hole in the middle, indicating
that the container had been pressure rinsed. It
is reasonable to assume that the containers were
not rinsed immediately after use. The liquid in
the pesticide evaporated, which caused the
112
-------
Pesticide Containers A Report to Congress
. .. . - - - — __^^^_J^^^^^_^^^^__^^^^^^^_^^^^
Table 7-12
Triple Rinse: N AC A, 1990
PERCENT REMOVAL (%)
CONTAINER
ID
FORMULATION2
CONTAINER
1
CONTAINER
2
CONTAINER
3
2.5 Gallon Containers
CR01
CR02
CR03
CR04
CR05
CR06
CR07
CR08
CR15
CR17
CR18
CR19
CR20
CR21
1 -Gallon
CR09
CR10
CR11
CR12
CR13
5-Gallon
CR14
2-Gallon
CR16
ASU
EC
EC
EC
EC
ASU
EC
EC
ASU
FL
EC
EC
FL
FL
Containers
ASU
ASU
ASU
DF
EC
container
EC
container
EC
99.9999
99.9999
99.9991
99.9999
99.9999
99.9997
99.9999
99.9999
99.9997
99.9990
99.9999
>99.9999
99.9999
99.9981
99.9995
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9998
100.0000
99.9999
>99.9999
99.9999
99.9987
99.9986
99.9999
99.9999
99.9999
99.9999
99.9999
99.9996
99.9988
99.9999
>99.9999
99.9999
99.9990
99.9986
99.9999
98.9999
99.9998
99.9999
1. This is the percent removal for the fourth rinse.
2. FL - Flowable; EC - Emulsifiable Concentrate; ASU - Aqueous Solution; DF - Dry Flowable.
SOURCE: National Agricultural Chemicals Assotiation/U.S. EPA, meeting summary, U.S. EPA, Office of Pesticide Programs, October 16,
1990.
remaining ingredients in the formulation to rinsing immediately after emptying the con-
cake on the bottom of the container. The fact tainer.
that the container had been pressure rinsed and
still had a large cake shows the importance of
In 1990, Formulogics conducted a container
rinsing study at the request of the EPA. (29) The
113
-------
Chapter? - Nonrefillable Containers: Residue Removal
study was designed to examine pressure and
triple rinsing for a number of containers and
formulation types. In order to eliminate some of
the problems of the previous reports, EPA re-
quested that a protocol be developed for triple
and pressure rinsing. Prior to finalization, this
protocol was circulated to interested parties for
comment. These comments were considered
and the document was revised. The protocol is
summarized in Appendix A.
Using this protocol, some of the member
companies of NACA tested various formula-
tions and containers and presented the results
to the EPA. (30) These results are given in Table
7-12. These data show that the percent removal
of the fourth rinse is 99.9999 percent for most
pesticide/container combinations. There are
some for which the removal is only in the 99.9990
range.
Table 7-13
Triple Rinse - Emulsif iable Concentrate:
Formulogics, 1990
Table 7-14
Triple Rinse - Aqueous-based Flowable:
Formulogics, 1990
CONTAINER 1 .
N
1 .0-gallon "F"-style Rheem
1 .0-gallon "F"-style Kleenpour
2.5-gallon "F"-style Central
Can
2.5-gallon "F" -style, Holly
Peterson
5.0-gallon steel flathead
5.0-gallon plastic Hedwin
UMBER
4
5
4
5
4
5
4
5
4
5
4
5
PERCENT2
REMOVAL (%)
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
RINSE
CONTAINER1 NUMBER
1 .0-gallon "P'-style
1 .0-gallon plastic
round
1 .0-gallon "F'-style
Kleenpour
2.5-gallon "F'-style
Kleenpour
2.5-gallon "F'-style
Central Can
2.5-gallon "F'-style
Plastipak
2.5-gallon "F'-style,
Holly Peterson
5. 0-gallon steel
flathead
5. 0-gallon plastic
Hedwin
4
5
4
5
4
5
4
5
4
5
4
5
4
5
4
5
4
5
PERCENT 2
REMOVAL (%)
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9998
99.9999
99.9980
99.9996
99.9999
99.9999
1. The container is described by the size, shape and container manufac-
turer. The "F"-style containers are all plastic.
2. Based on the analysis of rinsate from an emulsifiable concentrate,
Pounce 3.2 EC
1. The container is described by the size, shape, and container manufac-
turer. The "F"-style containers are all plastic.
2. Based on the analysis of rinsate from an aqueous-based flowable,
Atrazine4L.
The Formulogics study investigated the triple
rinsing efficiency of a variety of containers in
the 1-, 2.5- and 5.0-gallon range, for three for-
mulations: an emulsifiable concentrate, an aque-
ous-based flowable, and an aqueous-based en-
capsulated product. The data are presented in
Tables 7-13, 7-14, and 7-15. The results are
similar to the NACA data; 99.9999 percent
removal was attained for most of the 1-, 2.5-,
and 5-gallon plastic containers regardless of the
formulation. The 5-gallon flathead steel can
was the most difficult to rinse effectively. Re-
gardless of the formulation, the fourth and fifth
114
-------
Pesticide Containers - A Report to Congress
Table 7-15
Triple Rinse - Encapsulated Formulation:
Fomuilogics, 1990
RINSE
CONTAINER1 NUMBER
2.5-gallon "P-style Penn
Plastic
2.5-gallon "F"-style Central
Can
2.5-gallon "F"-style,
Plastipak
5.0-gallon steel flathead
4
5
4
5
4
5
4
5
PERCENT2
REMOVAL (%)
99.9990
99.9999
99.9999
99.9998
99.9999
99.9999
99.9970
99.9960
1. The container is described by the size, shape and container manufac-
turer. The "P-style containers are all plastic.
2. Based on the analysis of rinsate from an encapsulated formulation,
Lasso Micro-tech.
rinses were 10 to 100-fold more concentrated
when compared to the other containers.
In addition to analyzing the rinsate for the
concentration of the active ingredient, the mass
of the retained material was recorded. The
mass was then plotted versus the number of the
rinse to see if there were any noticeable patterns
in the process. The study showed that the mass
of material retained after the first rinse is usu-
ally equal to or greater than the amount of
product left in the drained container. Table 7-
16 shows the results for atrazine 4L in a 1-gallon
"F"-style plastic jug.
The emulsif iable concentrate rinsate weight
pattern was similar to the water-based flowable
in the same container with one major exception.
The amount of emulsif iable concentrate retained
after draining was significantly less than the
amount of flowable. Pint and quart bottles were
similar in their rinsing behavior when com-
pared to the larger vessels. The actual weights
retained were much smaller but the rinsing
patterns were the same.
These studies also showed that shaking a
partially filled container could in fact increase
the amount of product retained after draining.
Hence, if a partially filled container was shaken,
drained, and not rinsed at least one time with
water before being discarded, it could pose
more of an environmental burden than a full
container of pesticide that was shaken, drained,
and discarded. The difference was about 10 to
20 grams for 1- and 2.5-gallon containers.
7.4.2.2 Observations
While conducting the triple rinse testing,
Formulogics found several problems regarding
worker safety. First, it is difficult to open certain
5-gallon containers without splashing material
Table 7-16
Mass of Retained Material: Formulogics, 1990
RINSE NO.
Drain
1
2
3
4
5
6
TEST #1
47.5
56.0
13.7
10.6
MASS RETAINED
TEST #2
46.2
46.2
20.7
(GRAMS)
TEST #3
47.9
45.8
16.2
12.1
TEST #4
47.9
45.1
15.7
6.8
2.6
1.8
2.8
l.This represents the mass of material (formulation or rinsate) retained in the container during a triple rinse procedure. A 1.0-gallon "F"-style container
was tested using Atrazine 4L.
115
-------
Chapter 7 - Nonrefillable Containers: Residue Removal
onto the surface of the container. Additionally,
removing the various plastic pieces of the spout
is a difficult task while wearing gloves. Finally,
during the residue removal process, it is diffi-
cult to manually shake, 5-gallon containers.
Of all the containers rinsed, the 5-gallon
steel can was the most difficult to reseal. This is
a concern in the triple rinsing procedure be-
cause the user is expected to place the original
cap back on the container before shaking. The
cap on the spout could not be tightened suffi-
ciently to prevent the container from dripping
when it was being shaken. The problem was
most severe with the side-to-side phase of the
agitation cycle.
A second problem associated with attempt-
ing to reseal the containers occurred with the
emulsifiable concentrate containers. In some
instances, the lining of the cap is not resistant to
the product. This is not a problem during
shipping and storage because the product is
separated from the cap by a mylar-foil seal
across the neck of the container. Once this
barrier has been removed and the product con-
tacts the cap, the sealing capabilities of the cap
can be affected. This presents a potential expo-
sure risk. To prevent possible exposure during
the rinsing it should be possible to effectively
reseal any container that is intended to be triple
rinsed.
Another problem was containers that dripped
during the emptying cycle. This study did not
quantify dripping; these conclusions were based
on observations made while handling the con-
tainers. Dripping was associated more with the
emulsifiable concentrates than the flowables.
The emulsifiable concentrate used in the study
is considered to be typical of the available
emulsifiable concentrates. Regardless of con-
tainer size, trying to carefully pour the emulsi-
fiable concentrate resulted in formulation run-
ning down the face of the container. This may
Table 7-17
Triple Rinse: Leasure,
1978
Rinse
1
2
3
Run One
A.I. Cone.
(g/l)
6.230
0.500
0.110
Run Two
A.I. Cone.
(fi/D
5.850
0.550
0.120
SOURCE: J.K. Leasure, SouOiem Illinois University, "Triple Rinsed - or
Equivalent." Unpublished report, 1978.
be due to the combination of low viscosity and
low surface tension. Once water was intro-
duced into the container for purposes of rinsing,
the dripping problem was eliminated.
The cap on a 38-mm opening can retain 0.2
to 0.3 grams of product if it is in contact with the
concentrate. The cap for a 63-mm opening can
retain 0.5 grams. Pesticide residue can accumu-
late on container caps, posting a potential expo-
sure risk.
7.4.3 Pressure Rinsing
Several of the studies also investigated the
efficacy of pressure rinsing. These data present
inconsistent evidence in regard to whether
pressure rinsing or triple rinsing is more effec-
tive.
Table 7-18
Pressure Rinse: Leasure,
1978
Time
(sec)
10
20
30
40
50
60
Run One
A.I. Cone.
(g/l)
4.350
0.380
0.060
0.025
0.010
0.007
Run Two
A.I. Cone.
(g/l)
4.100
0.380
0.065
0.024
0.007
0.006
SOURCE: J.K. Leasure, Southern Illinois University, "Triple Rinsed - or
Equivalent." Unpublished report, 1978.
116
-------
Pesticide Containers - A Report to Congress
Table 7-19
Pressure Rinse: Peck, 1985
Time
(sec)
A.I. Cone.
(ug/ml)
A (No Units)
Percentage
Removal (%)
30
60
5.04
0.39
0.0000140
0.0000011
99.9986
99.9999
SOURCE: D.Peck. "The Determination of Residue of Certain Pesticides after Triple Rinsing." August 1985.
In 1978, apparently as part of the Southern
Illinois University study, Leasure compared the
efficiency of pressure and triple rinsing.(31)
Empty Treflan containers (assumed to be 5-
gallon metal cans) were obtained from a custom
applicator and randomly assigned to be either
triple rinsed or pressure rinsed. Six containers
were rinsed by each method. Samples of rinsate
were analyzed and the results are given in
Tables 7-17 and 7-18. It was not possible to
calculate the percent removal, but a comparison
of the data shows triple rinsing to be approxi-
mately as efficient as a 30-second pressure rinse.
The 60-second pressure rinse resulted in an a.i.
concentration that was over an order of magni-
tude less than the triple rinse.
Part of the 1985 Peck study included a pres-
sure rinsing test. (32) The data, given in Table 7-
19, indicated that the 30-second pressure rinse
was slightly more effective than triple rinsing
and the 60-second pressure rinse was more
effective by an order of magnitude. The percent
removal was 99.9986 for the 30-second rinse and
99.9999 percent for the 60-second rinse.
As mentioned previously, Miles found no
substantial difference between the containers
that were triple rinsed and those that were
pressure rinsed.
The data gathered by some NACA member
companies conflicts with the conclusion that
pressure rinsing is at least as effective as triple
rinsing. The data for 30-second pressure rins-
ing are summarized in Table 7-20. Based on
these data, pressure rinsing is generally not as
efficient as triple rinsing as seen in Table 7-12,
except when the product is a water-based solu-
tion or a dry flowable.
In the 1990 Formulogics study, only a brief
amount of the research time was devoted to
pressure rinsing. Two containers were tested, a
5-gallon flathead steel can and a 2.5-gallon "F"-
style plastic container manufactured by Holly
Peterson. The selection of these containers was
based on the triple rinsing studies. The 5-gallon
can retained the greatest amount of pesticide
when triple rinsed. The 2.5-gallon container
was typical of the containers that appeared to
rinse without a significant retention of rinsate.
The Pounce 3.2 EC and atrazine formulations
were selected in order to determine if there was
a significant difference in the rinsing character-
istic of an emulsifiable concentrate and a flow-
able.
The results are presented in Table 7-21. The
retention of pesticide in the rinsate was inde-
pendent of formulation type and 100- to 1000-
fold greater than the triple rinse levels of pesti-
cide in the rinsate.
117
-------
Chapter 7 Nonrefillable Containers: Residue Removal
Formulogics found several problems associ-
ated with the handling or rinsing of the contain-
ers during the test. Because the container is
inverted during common pressure rinsing prac-
tices, the probe is placed into the bottom of the
container. The pressure rinsers examined were
designed to direct the spray through 4 equally
spaced ports on the probe. Due to this design,
the water sprays toward the container sides and
then downward through the mouth of the con-
tainer. The flow does not readily reach the
bottom surface of the container near the point of
insertion. Therefore, the operator must move
the rinser around to ensure that all the surfaces
have been rinsed. Adequate rinsing of the
bottom of the container is critical because solids
may be deposited on the surface.
Also, a problem associated with the hollow
handles of the "F"-style containers was identi-
fied. The container used was translucent, which
allowed the operator to see the rinse pattern.
During the drain cycle, the flowable formula-
tion had deposited in the handle. It was inter-
esting to note the length of time it took for the
rinse water to remove the flowable from the
handle. After rinsing for more than 1 minute,
there was still a visible residue. It required
almost 2 minutes of constant rinsing, while a
concerted effort was made to direct the flow of
Table 7-20
Pressure Rinse: NACA, 1990
CONTAINER
ID
FORMULATION 2
PERCENT REMOVAL1 (%)
CONTAINER CONTAINER CONTAINER
1 2 3
2.5 Gallon Containers
CR01
CR02
CR03
CR04
CR05
CR06
CR07
CR08
CR17
CR18
1 -Gallon
CR09
CR10
CR11
CR12
CR13
ASU
EC
EC
EC
EC
ASU
EC
EC
FL
EC
Containers
ASU
ASU
ASU
DF
EC
99.9999
99.9999
99.9936
99.9856
99.9728
99.9999
99.9901
99.9987
99.8472
99.9995
99.9996
99.9999
>99.9999
99.9999
99.9999
99.9999
99.9999
99.9614
99.9997
99.9999
99.9999
>99.9999
99.9999
99.9999
99.9999
99.9999
99.9861
99.9996
99.9999
99.9999
>99.9999
99.9999
99.9999
1. This is the percent removal for a 30-second pressure rinse.
2. FL - Flowable; EC - Emulsifiable Concentrate; ASU - Aqueous Solution; DF - Dry Flowable
SOURCE: National Agricultural Chemicals Association/U.S. EPA, muting summary, U.S.
EPA, Office of Pesticide Programs, October 16,1990.
118
-------
Pesticide Containers - A Report to Congress
Table 7-21
Pressure Rinse: Formulogics, 1990
CONTAINER
Formulation: Pounce 3.2 EC
5.0-gallon steel flathead
5.0-gallon steel flathead
Formulation: Atrazine 4L
2.5-gallon "F"-style,
Holly Peterson
TIME
(sec.)
9-10
19-20
29-30
9-10
19-20
29-30
9-10
19-20
29-30
PERCENT
REMOVAL (%)
99.97
99.97
99.98
99.82
99.995
99.984
99.72
99.82
99.961
rinsate into the handle, in order to remove the
flowable. This type of behavior was not ob-
served in the triple rinse studies.
The most current data indicate that pressure
rinsing may not be as effective as triple rinsing.
It is important to realize that the NACA and
Formulogics data are from laboratory studies
for both triple and pressure rinsing. The differ-
ence between laboratory and field results for
both rinsing methods should be considered. It
is very likely that a typical field triple rinse
procedure would be a streamlined version of
the Formulogics protocol, Le., without the 30-
second drain periods and with reduced agita-
tion periods. On the other hand, pressure rins-
ing would probably be performed similarly in
the field and lab. Therefore, in the field, pres-
sure rinsing may be a more effective method of
residue removal than triple rinsing. However,
more data is needed to confirm this. Additional
studies are needed to compare the relative effi-
ciency of triple rinsing and pressure rinsing.
7.4.4 Bags
Data or studies on the residue remaining in
bags are scarce. The available information in-
cludes an abbreviated study by Braun and the
results of testing conducted in 1990 for EPA by
Stone Container Corporation and Union Camp
Corporation.
In 1979, Braun included three paper bags in
the field study to determine the efficiency of
water rinsing. (33) Bags containing wettable
powder were emptied by normal field dispensing
practices. The bags were then rinsed with 1-
liter amounts of water up to a maximum of five
rinses. The data from the study are summarized
in Table 7-22.
Stone Container Corporation did some pre-
liminary testing on the residue in multiwall
paper bags to provide data to EPA. (34) Several
styles of bags were tested and in all instances the
residue retained was less than one gram. The
results are given in Table 7-23.
Union Camp Corporation also studied the
residue remaining in multiwall paper bags. (35)
The bag size, barrier material, and fill media
were different for each test. The amount of
residue varied greatly, as shown in Table 7-24.
7.5 Laboratory and Field Analytical Methods
There are many laboratory methods for de-
termining the level of residue removal from
rigid containers. These methods, such as gas-
liquid chromatography and high-pressure liq-
uid chromatography, use analytical equipment
commonly found in labs.
There is a growing need for the develop-
ment of analytical procedures to determine the
level of residue removal from nonrefillable con-
tainers in the field for the use of enforcement of-
ficials. This is particularly important as the
number of container collection programs grows.
Also, FIFRA section 19(f)(3) requires states to
carry out programs to ensure compliance with
the residue removal regulations that are man-
dated in section 19(f). Beginning December 24,
1993, a state may not exercise primary enforce-
119
-------
Chapter 7 Nonrefillable Containers: Residue Removal
merit responsibility or certify an applicator unless
such a program is in effect. These programs
may involve some type of field testing for the
level of residue in rinsed nonrefillable contain-
ers.
The laboratory methods utilize sophisticated
equipment that is not practical for analyzing
samples in the field. It would be advantageous
for a field screening test to be quick, relatively
inexpensive, and appropriate for use by appli-
cators and inspectors. A field test would be a
method to determine whether a violation has
occurred for enforcement purposes and would
facilitate the determination of whether contain-
ers that are headed for disposal or recycling are
clean.
One possible field screening method is sim-
ply visual inspection of the containers. While
this is not analytical, it can be very effective.
Maine has been doing container inspections
since 1985 when the container deposit and re-
turn program began. The inspectors quickly
"developed an eye" for properly cleaned con-
tainers and in 1985, visual inspections verified
adequate rinsing 98 percent of the time. Maine
enforcement officials found that the thorough-
ness of the rinsing procedure can easily be de-
termined by rinsing the container and pouring
the contents of the container into a plastic cup.
Additionally, an inspector can readily deter-
mine if a completely dry container has been
rinsed sufficiently or if chemical has crystal-
lized on the inside. (36) Pressure rinsing makes
visual inspection even easier because of the
characteristic hole in the bottom of the con-
tainer.
Another potential field method is to meas-
ure the turbidity ("clearness") of the final rin-
sate. The state of Oregon defines a level of tur-
bidity for the verification of adequate cleaning
Table 7-22
Bag Residue: Braun, 1983
RlnM Mas*
Azlnphosmethyl, Guthlon, 50% WP, 2.3Wlogram (1.05-pound)
1
2
3
4
5
Total a.l. recovered = 3.45 g
A.I. In Rlnsate (g)
paper bag
2.80
0.37
0.13
0.09
0.06
Phosalone, Zolone, 30% WP, 2.34ilogram (1.05-pound) paper bag
1
2
3
4
Total a.l. recovered - 0.44 g
Phosmet, Imldan, 50% WP, 2.3-kJlogram (1.05-pound) paper
1
2
3
4
Total a.l. recovered » 6.26 g
0.37
0.06
0.01
<0.01
bag
6.20
0.05
0.01
<0.01
SOURCE: H.E. Braun, etal., "Efficiency of Water Rinsing for Oie Decontamination of Used Pesticide Containers." Archives ofEnvirmmental Contamination and
Toxicology. Vol. 12, (1983): pp. 257-264.
120
-------
Pesticide Containers - A Report to Congress
Table 7-23
Bag Residue: Stone Container Corporation, 1990
Bag Type
Sand
Material Retained (g)
6% Dlazlnon
Pinch Bottom 3-1/2 Gusset
Square Stack
Regular
Pinch Bottom Rat Tube
Pasted Valve 5-Inch
Top
Bottom
Pinch Bottom 6-Inch Gusset
Square Stack
Regular
0.25
0.93
0.12
0.40
0.17
0.05
0.50
0.09
0.04
0.05
0.33
0.29
0.02
0.01
SOURCE: E. Tyfke, Stone Container Corporation, letter to B. Omilinsky, Formulogics, August 7,1990.
in its rinsing regulations, as defined in Table 7-
1. A container is verified as clean when no
residue on its interior or no turbidity (less than
5 Nephelometric units) is observed in a sample
when a diluent that does not solubilize residue
is placed in the container to 5 percent of the vol-
ume and agitated for 30 seconds. A method
based on the clearness of the rinsate, however,
requires basic knowledge about the pesticide
and its solubility characteristics. The state of
Oregon does not currently use this procedure to
verify proper rinsing. (37)
Immunoassay is a third potential field
method. This type of analysis is based on the
interaction of the given pesticide with a specific
antibody. There are test kits available for triazi-
nes, cyclodienes and alachlor. One supplier of
immunoassay testing kits is ImmunoSystems
Inc. in Biddeford, Maine.
Considering the variety of pesticide prod-
ucts and the different venues in which they are
used, it would be advantageous if these future
analytical procedures were inexpensive and
capable of analyzing a wide variety of chemi-
cals. In addition, the accuracy of these methods
of analysis will have to be validated over a wide
range of concentrations.
7.6 Future Research Needs
7.6.1 Adsorbed and Absorbed Pesticide
The discussion on residue removal in this
report and previous studies has focused on the
amount of pesticide in the rinsate. A major issue
that has not been addressed in the scientific
literature is the amount of pesticide that re-
mains bound to the container walls (adsorbed)
after rinsing and the amount absorbed into the
walls. The pesticide remaining after proper
rinsing must be considered and may be a crucial
issue in the development of pesticide container
recycling.
Tiernan reported that after four or five water
rinses, it was possible to remove a significant
121
-------
Chapter? - Nonrefillable Containers: Residue Removal
amount of active ingredient with a solvent rinse
for non-water-soluble pesticides. (38) The sol-
vent removed additional pesticide, although it
is not known if this material was adsorbed or
absorbed.
The amount of adsorbed and absorbed ma-
terial is an issue for both ready-to-use and di-
lutable products. The fact that ready-to-use
pesticides have lower concentrations or use
different formulations does not eliminate the
possibility of migration of the chemical into the
package. This applies to both solid and liquid
products.
7.6.2 Expand Residue Data Base
The residue removal data base needs to be
expanded. Specifically, more information is
necessary in the following areas:
•Triple rinsing for more container and for-
mulation combinations, representing all of
the pesticide markets;
•A comprehensive study of pressure rinsing
for rigid agricultural pesticide containers;
•The amount of residue remaining when a
ready-to-use pesticide container is emp-
tied;
•A comprehensive study of the residue
remaining in bags, examining effect of bag
type, bag size, barrier material, and fill
media; and
•A comprehensive study of the residue
remaining in aerosol containers.
Another potential research area is studying
and possibly improving the design of pressure
rinse nozzles.
7.6.3 Amount of Pesticide Removed in Recy-
cling
Another question involves the amount of
pesticide removed from the container during
the recycling process. This includes the amount
of pesticide that is removed through the clean-
ing process, either washing or another method,
and the amount of pesticide that may be re-
leased during the melting and extruding pro-
cesses.
Table 7-24
Bag Residue: Union Camp Corporation, 1990
BAG BAG
NUMBER TYPE
1 Pinch Bottom
Open Mouth
2 Pinch Bottom
Open Mouth
3 Pinch Bottom
Open Mouth
BAG
SIZE
4.5kg
5kg
25kg
BARRIER
1.0 mil HOPE film
30 LDPE
.000285 AF/
6 PE Nat.
Extensible Kraft
30 PE/
.00035AF/6 PE/
50 Nat. Kraft
FILL
MEDIA
Clay (Aluminum
Silicate)
28-3-9 Analysis
Fertilizer containing
3.33% Diazinon
Corn Cob Grits
(Ground Corn Cob)
RESIDUE
14.5g
1.67g
2.44 g
SOURCE: T.T. Allen, Union Camp Corporation, letter to N. Fife, U.S. EPA, Office of Pesticide Programs, October 18,1990.
122
-------
Pesticide Containers - A Report to Congress
Individual recyclers are currently address-
ing this issue. Envirecycle is developing a wash-
ing technique and is studying the effects of
varying the water temperature, detergent used,
and other factors. Restoration Plastics of Flor-
ida, Inc. is investigating the efficiency of their
proprietary "dry cleaning" process.
7.6.4 Analytical Field Testing Techniques
Another area that needs additional research
is the development of field testing techniques
that provide quick, simple, and analytical re-
sults for a variety of pesticides. The demand for
analytical techniques will probably increase as
states develop enforcement programs for the
residue removal regulations currently being
drafted by EPA.
123
-------
Chapter 7 - Nonrefillable Containers: Residue Removal
Endnotes 15. Ibid.
16. Archer, I.E., "Removal of 2,4-Dichlorophe
1. National Agricultural Chemicals Association, noxyacetic Acid (2,4-D) Formulations from Non-
"Empty Container Disposal: Safe Practices combustible Pesticide Containers," Bulletin of
for Agricultural Chemical Users," 1986, Environmental Contamination and Toxicology,
1990 reprint. Vol. 13, Number 1, (January 1975): pp. 44-51.
2. Miles, J., et al., "Assessment of Hazards 17. Tiernan, T.O., Wright State University, "As-
Associated with Pesticide Container Disposal sessment of Rinsing Procedures for Removing
and of Rinsing Procedures as a Means of Pesticides from Containers Used by Agricul-
Enabling Disposal of Pesticide Containers in tural Applicators," Quarterly Progress Report
Sanitary Landfills," Journal of Environmental submitted to the U.S. EPA, Risk Reduction
Science and Health, Vol. B18(3), pp. 305-315, Engineering Laboratory, February 1,1990.
1983. 18. Paper Shipping Sack Manufacturers Associa-
3. Leasure, J.K., "Triple Rinsed — or Equivalent," tion/Formulogics/U.S. EPA, meeting sum-
Southern Illinois University, Unpublished Re- mary, U.S. EPA, Office of Pesticide Programs,
port, 1978. August 28,1990.
4. Southern Illinois University, Draft of unpub- 19. Peck, D., "The Determination of Residue of
lished report on pesticide container disposal Certain Pesticides After Triple Rinsing," Au-
in Illinois, August 24,1978. gust 1985.
5. Ibid. 20. Hsieh, D., et al., "Decontamination of Non-
6. Ibid. combustible Agricultural Pesticide Containers
7. Ibid. by Removal of Emulsifiable Parathion," Envi-
8. South Dakota Department of Agriculture, ronmental Science and Toxicology, Vol. 6,
"South Dakota Farm Survey," 1988. Number 9, (September 1972): pp. 826-829.
9. Lounsbury, B., personal communication with 21. Tiernan, T.O, Wright State University, " As-
U.S. EPA, Office of Pesticide Programs, No- sessment of Rinsing Procedures for Removing
vember 26,1990. Pesticides from Containers Used by Agricul-
10. Hansen, R., Minnesota Department of Agri- tural Applicators," Quarterly Progress Report
culture, letter to T. Bone, U.S. EPA, Office of submitted to the U.S. EPA, Risk Reduction
Pesticide Programs, October 4,1990. Engineering Laboratory, February 1,1990.
11. National Agricultural Chemicals Association, 22. Archer, T.E., "Removal of 2,4-Dichlorophe-
" Empty Container Disposal: Safe Practices for noxyacetic Acid (2,4-D) Formulations from Non-
Agricultural Chemical Users," 1986,1990 Re- combustible Pesticide Containers," Bulletin of
print. Environmental Contamination and Toxicology,
12.Hansen, R., Minnesota Department of Agri- Vol. 13, Number 1, (January 1975): pp. 44-51.
culture, letter to T. Bone, U.S. EPA, Office of 23. Peck, D. "The Determination of Residue of
Pesticide Programs, October 4,1990. Certain Pesticides After Triple Rinsing," Au-
13-Peck, D., "The Determination of Residue of gust 1985.
Certain Pesticides After Triple Rinsing," 24. Braun, H.E., et al., "Efficiency of Water Rins-
August 1985. ing for the Decontamination of Used Pesticide
14. Braun, H.E., et al., "Efficiency of Water Rins- Containers," Archives of Environmental Con-
ing for the Decontamination of Used Pesti- tamination and Toxicology, Vol. 12 (1983): pp.
cide Containers/' Archives of Environmental 257-264.
Contamination and Toxicology. Vol. 12,1983: 25. Frank, R., et al., "A System for Rinsing Herbi-
pp. 257-264. cide Residues from Drums During Highway
124
-------
Pesticide Containers A Report to Congress
Right-of-Way Spray Operations," Bulletin of
Environmental Contamination and Toxicol-
ogy, Vol. 39,1987: pp.680-687.
26. Hsieh, D., et al., "Decontamination of Non-
combustible Agricultural Pesticide Contain-
ers by Removal of Emulsifiable Parathion,"
Environmental Science and Toxicology, Vol.
6, Number 9, September 1972: pp. 826-829.
27. Lamberton, J., et al., "Pesticide Container
Decontamination by Aqueous Wash
Procedures," Bulletin of Environmental Con-
tamination and Toxicology, Vol. 16, Number
3,1976: pp. 528-535.
28. Miles, J., et al., "Assessment of Hazards
Associated with Pesticide Container Disposal
and of Rinsing Procedures as a Means of
Enabling Disposal of Pesticide Containers in
Sanitary Landfills," Journal of Environmental
Science and Health, Vol. B18(3), 1983: pp.
305-315.
29. Omilinsky, B. and D. Lindsay, Formulogics,
Report to U.S. EPA, Office of Pesticide Pro-
grams, May 15,1990.
30. National Agricultural Chemicals Association/
U.S. EPA, meeting summary, U.S. EPA, Office
of Pesticide Programs, October 16,1990.
31. Leasure, J., Southern Illinois University,
"Triple Rinsed — or Equivalent," Unpub-
lished Report, 1978.
32. Peck, D., "The Determination of Residue of
Certain Pesticides After Triple Rinsing,"
August 1985.
33. Braun, H., et al., "Efficiency of Water Rins-
ing for the Decontamination of Used Pesticide
Containers," Archives of Environmental Con-
tamination and Toxicology, Vol. 12,1983:
pp. 257-264.
34. Tytke, E., Stone Container Corporation, letter
to B. Omilinsky, Formulogics, August 7,1990.
35. Allen, T., Union Camp Corporation, letter to
N. Fitz, U.S. EPA, Office of Pesticide Pro-
grams, October 18,1990.
36. Denny, R. and D. McLaughlin, Maine Board
of Pesticide Control, Report on Maine Pesti-
cide Container Program, 1985.
37. Calaba, G., Oregon Department of Environ-
mental Quality, personal communication with
U.S. EPA, Office of Pesticide Programs, Sep-
tember 20,1990.
38. Tiernan, T., Wright State University, "As-
sessment of Rinsing Procedures for Removing
Pesticides from Containers Used by Agri-
cultural Applicators," Quarterly Progress
Report submitted to the U.S. EPA, Risk Re-
duction Engineering Laboratory, February 1,
1990.
125
-------
Pesticide Containers A Report to Congress
Chapter 8
Nonrefillable Containers:
Disposal
8.1 Introduction
The disposal of nonrefillable containers is
rapidly becoming one of the most prominent
pesticide container issues. Nearly half a billion
nonrefillable containers are disposed each year.
More than half of these containers enter the mu-
nicipal solid waste stream and are discarded in
landfills or are incinerated. From a solid waste
minimization point of view, the number of con-
tainers being discarded should be minimized,
especially considering the decreasing capacity
of landfills in the United States. Additionally,
the options available for the disposal of agricul-
tural nonrefillable containers are decreasing in
number and increasing in cost. Overall, dis-
posal of nonrefillable containers is a significant
problem.
The options available for disposal differ sig-
nificantly between different segments of the
pesticide industry. Household and institutional/
industrial nonrefillable containers generally are
discarded and enter the municipal solid waste
stream. At this tune, this is the only practical
disposal option for containers in these two mar-
kets. On the other hand, several methods are
used for the disposal of agricultural nonrefil-
lable containers.
Within the agricultural industry, the fate of
an empty pesticide container depends on the
person who generated it. Farmers, commercial
applicators, and pesticide dealers dispose of
containers in different ways.
In order to characterize the current disposal
problems and practices, a number of surveys
were conducted to collect information on agri-
cultural pesticide container disposal. This chap-
ter describes these surveys and discusses each
container disposal method in greater detail.
8.2 Surveys on Container Disposal
In 1987, the National Agricultural Chemi-
cals Association (NACA), in conjunction with
the American Farm Bureau Federation, National
Agricultural Aviation Association, and the Na-
tional Fertilizer Solutions Association, conducted
a survey on container issues. (1) Thirty-eight
states were represented in the survey and the
breakdown of the 805 responses was:
• 418 private applicators;
• 190 commercial aerial applicators;
• 150 commercial ground applicators; and
. 47 combined commercial aerial and
ground applicators.
127
-------
Chapter 8 - Nonrefillable Containers: Disposal
The survey was not designed to present any
statistical representations; its purpose was to
help pesticide manuf acturers develop their con-
tainer management strategies. The survey pro-
vides a useful cross-section of opinions on con-
tainer disposal.
Respondents were asked to rank 5 different
container issues in terms of the impact on their
business. The results are given in Table 8-1.
Commercial applicators ranked container dis-
posal as their main concern and the ability to
empty the containers safely and completely
second. Private applicators also ranked these
two issues as their top two concerns, although
the order was reversed.
Table 8-2 summarizes the results from a
question that involved ranking specific con-
tainer disposal issues. The lack of acceptable
disposal options and future liability were ranked
as the first and second most significant issues,
respectively. If the accessibility to disposal sites
is combined with the top concern, the impor-
tance of the lack of acceptable disposal options
becomes even more pronounced.
In 1987-88, the Minnesota Department of
Agriculture conducted a statewide survey of
container disposal issues. (2) The three different
groups that were surveyed are farmers, dealers,
and users. The "users" category includes li-
censed commercial and noncommercial appli-
cators. Noncommercial applicators are people
(such as government employees) who apply
restricted use pesticides, but not for commercial
reasons. Responses were received from 535
farmers, 1,065 users, and 408 dealers.
One question involved rating disposal of
empty pesticide containers in comparison to
other environmental issues in Minnesota. More
than 60 percent of the respondents in each group
ranked container disposal as "important" and
about 21 percent of each group ranked it as
"most important." Clearly, all groups consider
empty container disposal to be a significant en-
vironmental issue.
Table 8-1
Container Issues of Most Concern: NACA, 1988
COMMERCIAL APPLICATORS
CONTAINER
ISSUE
Container Disposal
Ability to sately and
completely empty
containers
Disposal of rinsate
Container sizes and
shapes
Container closure/
openings
Percent of Total
AIR GROUND
46 38
25 30
9 26
13 3
7 3
Responses
COMBINATION
35
29
13
13
10
PRIVATE
APPLICATORS
32
45
7
9
7
SOURCE: T. Gilding, National Agricultural Chemicals Association, letter to Principal Contacts of Member Companies, August 17,1988.
128
-------
Pesticide Containers A Report to Congress
Table 8-2
Issues with Container Disposal: NACA, 1988
COMMERCIAL APPLICATORS
Percent of Total Responses
DISPOSAL ISSUE
AIR
GROUND
COMBINATION
PRIVATE
APPLICATORS
Lack of acceptable
disposal options
Future liability
Accessibility to
disposal sites
Cost of disposal
40
39
14
34
40
20
41
32
21
41
33
20
SOURCE: T. Gilding, National Agricultural Chemicals Association, letter to Principal Contacts of Member Companies, August 17, 1988.
The current pesticide container disposal prac-
tices in Minnesota, as determined by the survey,
are given in Table 8-3. Burning was the most
common disposal method for farmers, while
most "users" and dealers triple rinse and take
the containers to a landfill. The results for the
farmers in the 1988 survey are consistent with
data from surveys done in 1981-84. The meth-
ods are ranked in the same order in both the
older and the more recent surveys, although
burning and burying on the farmer's property
has increased since the early 1980's.
The Minnesota Empty Pesticide Container
Disposal Report also summarized the results of
recent surveys done by other states, specifically
Nebraska, Wisconsin, and Iowa. These data are
given in Table 8-4 and show that burning was
common in all three states. Landf illing was also
common in Nebraska and Wisconsin, while a
significant percent of the Iowa farmers returned
their herbicide containers to the dealer.
Several surveys have been done on disposal
methods used by dealers. The Illinois Depart-
ment of Agriculture requires agrichemical fa-
cilities to register with the state. (3) One ques-
tion on the application for registration asked
about methods of container disposal. Table 8-5
shows that of 1,263 responses, 60 percent of the
facilities burned their nonrefillable containers.
In 1989, the National AgriChemical Retail-
ers Association (NARA) surveyed its members
on empty pesticide container disposal.(4) The
survey represents 8 percent of the NARA mem-
bership and approximately 7 percent of retail-
ers nationwide. NARA believes that the results
are representative of the national pesticide re-
tail industry. About 53 percent of the retailers
reported disposing of empty pesticide contain-
ers by burning, 42 percent by landfilling, and 4
percent by recycling.
The survey also asked retailers to rank dis-
posal methods in terms of cost-effectiveness.
Approximately 82 percent of the retailers ranked
burning as the most cost-effective method of
disposal. Rinsing and disposing of the contain-
ers as solid waste was clearly second, followed
by recycling, rinsing and returning containers
to the dealer, and rinsing and returning contain-
ers to a hazardous waste landfill.
129
-------
Chapters - Nonrefillable Containers: Disposal
Methods
Table 8-3
of Container Disposal:
Minnesota, 1988
DISPOSAL
METHOD
Burn
Rinse/take to landfill
Rinse/bury
Return to dealer
Store on site
Salvage
Regular garbage collection
Can't dispose
Out-of-state hazardous waste landfill
Other
Percent of Respondents Who Use Method (%)1
FARMERS USERS2
65.0
23.7
27.5
17.8
11.8
3.6
—
2.8
1.3
14.2
21.1
67.1
8.9
9.9
8.5
10.0
19.2
2.3
1.0
10.8
DEALERS
30.1
56.1
8.3
7.8
7.4
11.5
...
3.2
0.7
7.6
1. The columns total to greater than 100 percent because respondents could list more than one disposal method.
2. The users category includes licensed commercial and noncommercial applicators.
SOURCE: Minnesota Department of Agriculture. Minnesota Empty Pesticide Container Disposal Report, March 1988.
Methods
Table 8-4
of Container Disposal
^^^^^^^^^^•^^^^^^^^•^••^•^•••••^^^^^^^^^•^^^^^^•^•^•^^^^^^^^^^^^^^•^^^^^^^•^^^^^^^^^^^^^^^^^•••••^^^•l^^^^^^^^^^^^^^^^^^^m^BM^H^^^^^^^^^^^^^^RMMHH^^^^^^^^B^^^^^^^^^^^^^^B
Percent of Respondents who Use Method (%)
(State)
METPH°ODL (Container)
Burn
Bury on own property
Sanitary landfill
Return to dealer
Other
NEBRASKA1
Pesticide
24
33
36
7
—
WISCONSIN2 IOWA3
Pesticide Herbicide Insecticide
32 49 86
7 22
32 94
11 24 5
19 15 4
1. Pesticide Use on Major Crops in Nebraska, 1982.
2. Pesticide Use, Wisconsin, 1985.
3. Pesticide Used in Iowa Crop Production, 1985.
SOURCE: Minnesota Department of Agriculture. Minnesota Empty Pesticide Container Disposal Report, March 1988.
130
-------
Pesticide Containers - A Report to Congress
Til Me H-o
Methods nl CniiLiiner Disposal: II., 1 WO
DISPOSAL
METHOD
PERCENT OF
AGRICHEMICAL
FACILITIES WHO
USE METHOD (%)
Burn at facility 32
Burn in field at application site 28
Triple or pressure rinse and 22
take to landfill
Waste pick-up 21
SOURCE: A.G. Taylor, Illinois Environmental Protection Agency, per-
sonal communication wiBt U.S. EPA, Office of Pesticide Programs, Decem-
ber 3,1990.
These surveys show that nonrefillable con-
tainer disposal is a serious concern with pesti-
cide users. Also, burning and landf illing are by
far the two most common disposal methods.
8.3 Open Dumping
8.3.1 General
Although it is illegal under RCRA, the open
dumping of pesticide containers is a common
practice. Pesticide containers are discarded in
fields, as shown in Figure 8-1, and piled in
many locations, as seen in Figure 8-2. Because
of the potential public health risks from pesti-
cide residues in soil, surface water, and ground
water, all 50 states have regulations prohibiting
open dumping. North Carolina, Maine, and
Minnesota have studied the prevalence of open
dumping sites.
8.3.2 North Carolina Survey
The North Carolina Department of Agricul-
ture, in 1981-82, conducted a vehicular survey
mapping pesticide container dumping sites. (5)
The study was aimed at determining the poten-
tial for adverse water quality impacts from dump
sites on both private and public lands. Depart-
ment of Agriculture staff concentrated their
search on secondary roads and high probability
locations, such as loop and dead end roads,
roads with bridges over streams and creeks,
and areas around aerial applicator strips.
A total of 356 pesticide container dump sites
were found. Woodlands were the most com-
mon location for these sites, followed by wet-
lands in the eastern region of the state, and old
fields and croplands in the mid-state area. In
the eastern part of the state, more than 37 per-
cent of the sites were in contact with surface
water, or were located within 25 feet of surface
water. About 25 percent of the dump sites in the
mid-state region were in contact with or near
surface water.
Figure 8-1
Containers discarded in a field
131
Photo Credit: Poll/Processing Company.
-------
Chapter 8 - Nonrefillable Containers: Disposal
I i gu re 8-2
A container dump
The Department of Agriculture concluded
that illegal container disposal was widespread
and posed potential adverse impacts. The study
recommended (1) changes to the North Caro-
lina pesticide regulations, (2) initiating an in-
tensive educational program, (3) increasing en-
forcement efforts, and (4) developing a supple-
mental label to be used until the U.S. EPA's 1983
Label Improvement Program had gone into effect.
8.3.3 Maine Survey
The Maine Board of Pesticide Control began
monitoring improper disposal of pesticide con-
tainers in 1981. (6) A program to detect herbi-
cide damage and improper application along
utility and railroad rights-of-way immediately
revealed 14 container dumps. The Board refo-
cused its aerial surveillance efforts and found
400 illegal, open pesticide container dumps
between 1981 and 1983. The state's awareness
that options for legal pesticide container dis-
posal were becoming increasingly limited led to
the development of Maine's deposit/refund
program.
132
Photo Credit: PolyProcrffing Company,
8.3.4 Minnesota Study
While the North Carolina and Maine sur-
veys were done nearly a decade ago, a recent
study done by the Minnesota Department of
Agriculture confirms that open dumping is a
practice that is still occurring.(7) A comprehen-
sive evaluation was done at seven open dump
sites, including a detailed description of the site,
an inventory of the containers, sampling the
contents of the containers, testing for potential
soil contamination, and sampling for possible
surface water contamination.
The sites were generally located in woodlots
and contained pesticide containers as well as
other farm and household garbage. The open
dumps were found in sensitive soil and water
areas. Containers were located buried in sink-
hole sediment, floating in surface water, in
open wells, and within a foot of subsurface
water.
Approximately 53 percent of the 364 con-
tainers inventoried were metal; the rest were
plastic. Only 9 percent of the metal containers
-------
Pesticide Containers A Report to Congress
were classified as being in good condition; nearly
all of them were rusted and 73 percent had
holes. About 74 percent of the plastic containers
were in good condition. A majority of the
remaining plastic containers were broken apart
and brittle because of exposure to sunlight. Of
the 351 metal and plastic containers that were
examined closely, 63 percent either had holes or
were uncapped.
The study concluded that open dumping of
pesticide containers is a problem in Minnesota.
Although the exact total is unknown, the num-
ber of open dump sites may be very large. Also,
the residue in improperly rinsed and discarded
containers can adversely impact surface and
ground water.
8.4 On-Site Burial
Burial is a method of disposal where the con-
tainers are placed under soil cover in a site that
does not qualify as a sanitary landfill.(8) For
many years, burying pesticide containers has
been a common practice on farms. As shown in
Tables 8-3 and 8-4, on-site burial is still a dis-
posal method used by farmers.
Some states allow on-site burial by farmers,
although it is usually restricted to certain soil
types and/or a minimum distance from surface
water or wells. In general, however, on-site
burial is not encouraged because it is difficult to
ensure that only empty, properly rinsed con-
tainers are buried. Additionally, there is the
potential to contaminate soil or ground water.
Cases of ground water contamination have been
documented.
8.5 Landfilling
Disposing of pesticide containers in a landfill
is the primary disposal method in most states.
A sanitary landfill is defined in 40 CFR Part 241
as "a land disposal site employing an engi-
neered method of disposing of solid wastes on
land in a manner that minimizes environmental
hazards by spreading the solid wastes in thin
layers, compacting the solid wastes to the small-
est practical volume, and applying and com-
pacting cover materials at the end of each oper-
ating day." Nearly all empty household and in-
stitutional and industrial pesticide containers
enter the municipal solid waste stream and are
disposed in sanitary landfills or are incinerated.
Additionally, as shown in Tables 8-3,8-4, and 8-
5, landfilling is one of the main disposal meth-
ods for empty agricultural pesticide containers.
However, many landfills are currently re-
fusing to accept certain kinds of waste, includ-
ing pesticide containers, for several reasons:
•Existing landfill space is diminishing and
siting new landfills is difficult;
•Concern for ground water contamination
from earlier disposal practices is increas-
ing;
•States are adopting solid waste manage-
ment strategies that rank landfilling as the
least desirable disposal option; and
•Potential liability for future releases of haz-
ardous substances exists, as described in
section 5.4.3.
Pesticide containers that are triple rinsed or
the equivalent are considered non-hazardous
solid waste for RCRA purposes, as described in
section 5.4.2.2. These containers are allowed to
be disposed in sanitary landfills, although many
landfills refuse to accept properly rinsed pesti-
cide containers. In the 1988 Minnesota survey,
4.7 percent of the farmers, 10.6-percent of the
users, and 12 percent of the dealers reported
that landfill operators had refused their triple
rinsed containers. (9) This occurrence is not lim-
ited to Minnesota; the problem is common na-
tionwide.
Some users choose to dispose of nonrefil-
lable pesticide containers as hazardous waste
(in a hazardous waste landfill or in a permitted
133
-------
Chapters - NonrefillableContainers:Disposal
incinerator). Even though triple rinsed contain-
ers are not considered to be hazardous waste,
this disposal method is used sometimes because
of liability concerns. Hazardous waste disposal
is expensive, although the actual cost varies ac-
cording to the characteristics of the waste, the
method of disposal, and the region of the coun-
try. Pesticide users in California reported that it
costs about $1,000 to incinerate a 55-gallon drum
of hazardous waste and $5,000 to dispose of a
20-yard bin of granulated pesticide containers
in a hazardous waste landfill. It was estimated
that it would cost approximately $30,000 to
incinerate the 20-yard bin.(10)
8.6 Open Burning
Open burning is another widely used dis-
posal method for agricultural pesticide contain-
ers, partly because it is convenient and inexpen-
sive. Plastic containers and bags are usually
burned in the field where the pesticide was
mixed. Users often replace the empty plastic
containers in the shipping box and ignite the
whole package. Containers are burned in a pit
or a drum, or on the ground.
The open burning of pesticide containers is
an interjuristictional issue in terms of regula-
tions. Federal RCRA Subtitle D regulations
prohibit open burning under 40 CFR 257.3-7,
and air emissions may be subject to Clean Air
Act restrictions. State solid and hazardous waste
and air regulations may address open burning.
Additionally, some state pesticide regulations
include provisions for burning containers.
EPA is currently evaluating the problem of
regulating the open burning of pesticide con-
tainers. Two studies are currently being done to
determine the emissions from open burning.
The U.S. EPA Office of Research and Develop-
ment, Risk Reduction Engineering Laboratory,
is investigating open burning in the field, and a
study of burning pesticide bags under more
controlled conditions is being funded by the
Office of Pesticide Programs. Based on the
results of these studies, EPA may develop a set
of regulatory options.
8.7 Other Disposal Options
Pesticide containers are occasionally reused
to hold pesticides or for other purposes. Ob-
servers report seeing plastic pesticide jugs used
by growers to hold liquid pesticides decanted
from minibulk containers. Additionally, empty
pesticide containers are sometimes used to hold
other substances such as used motor oil. The
reuse of nonrefillable containers is not a recom-
mended practice and is prohibited by some
labels.
Some pesticide users report disposing of
containers by returning them to dealers. How-
ever, this is not a permanent "disposal method,"
because it simply places the burden of disposal
on the dealers.
Another common disposal method reported
in Tables 8-3,8-4, and 8-5 is storing the contain-
ers on-site. Again, this is not a true disposal
method and may create some problems. De-
pending upon the storage conditions, storing
the containers on-site may lead to the creation of
open container dumps.
8.8 Recycling
8.8.1 General
Recycling is a method of container manage-
ment currently under development. In general,
recycling is understood to mean using a mate-
rial again. In practice, recycling includes the
following steps:
•Discarding;
•Collection;
•Separation, which may occur before
collection;
134
-------
Pesticide Containers - A Report to Congress
•Processing;
•Melting or another manufacturing activity;
•Fabrication; and
•Reuse by the consumer. (11)
An important point is that this is a loop; a
demand for the recyclable material must exist.
Separation and collection alone do not consti-
tute recycling.
This section discusses the steps of recycling,
beginning with processing, for both metal and
plastic pesticide containers. The first several
steps are discussed in the following section on
existing collection programs.
8.8.2 Metal Containers
Nearly all metal pesticide containers are
constructed of steel. Steel has been recycled for
more than 50 years. Much of the steel that is
recycled includes scrap produced within the
mills and the excess material resulting from
fabrication processes, such as can manufactur-
ing. Additionally, steel recovery is common
because of the large amounts of steel scrap
derived from automobiles, appliances, and other
large post-consumer waste. (12)
Scrap processors and dealers collect steel
scrap and separate the steel from the other
materials, such as plastics and glass. This can be
done by magnetic sorting. The recovered metal
is sold to steel mills or foundries and used to
produce new steel or steel products. (13)
Metal pesticide containers can be and are in-
corporated into the steel scrap stream. How-
ever, some steel recovery facilities are reluctant
to accept pesticide containers. Minnesota col-
lected metal pesticide containers for recycling,
until an incident with a pesticide release caused
the recycler to refuse the containers. (14) A Cali-
fornia pesticide distributor reported that a steel
drum recycler stopped accepting its pesticide
drums in the early 1980's. Pesticide containers
were a minor part of the recycler's business, but
received a disproportionate amount of regula-
tory inspection. The recycler decided to refuse
pesticide containers because it was not cost-
effective.(lS)
Several container collection programs, in-
cluding those in Mississippi and Oregon, accept
metal containers. The metal containers col-
lected in the 1989 Mississippi pilot project were
sent to a metalwork plant in Greenville, Missis-
sippi. The metal containers collected in the
Oregon program are currently sent to Schnitzer
Steel Products Company, a steel reclamation
facility in Portland, Oregon. The containers
enter the processing stream along with cars and
other scrap.(16)
8.8.3 Plastic Containers
Almost all plastic containers used for pesti-
cides are made from high density polyethylene
(HOPE). Much research and attention is being
focused on recycling this HOPE. Industry is
interested in recycling the plastic to reduce the
amount of HOPE burned or discarded in landfills.
The first step in the process for recycling
plastic pesticide containers is to remove as many
of the caps, labels, and foil heat seals as possible.
Ideally, the labels, caps, and heat seals would be
removed before collection. In the 1990 Iowa
collection and recycling program, a major prob-
lem with recycling the plastic was the foil heat
seals that remained on the containers. (17)
Next, the containers are shredded into small
flakes approximately 1/4 inch in size. The
flakes are then cleaned. Several cleaning proc-
esses are being investigated. One process in-
volves washing the plastic in warm water and
detergent. A disadvantage of this approach is
the production of a large quantity of pesticide-
containing wash water that must be treated or
disposed. Another process is a dry procedure
135
-------
Chapter 8 - NonrefiHable Containers: Disposal
that has been developed by a recycling com-
pany. The details of this process are proprie-
tary.
After the plastic is cleaned, it usually is ex-
truded into pellets, the form in which plastic
usually is sold or distributed. The HDPE, how-
ever, could be sold or distributed in the flake
form.(18)
Recycled resin can be used in products to
replace virgin materials, either partially or en-
tirely. Ideally, the plastic recycled from pesti-
cide containers would be used to make more
pesticide containers. Testing is currently being
done in this area. One approach involves mix-
ing recycled and plastic resin in varying pro-
portions and blow molding this material into
new containers. Another approach is co-extru-
sion, where several layers of plastic are ex-
truded at the same time. Sample co-extruded
bottles are currently being made with three
layers. The inner and outer layers consist of
virgin material and the middle layer is made
from recycled resin.(19)
Other uses for the plastic from containers are
being investigated. Some potential uses for this
HDPE include drainage tile, fence posts, plastic
lumber, park benches, and flower pots.
Another option is to burn the recycled pel-
lets as an energy source. The heat content of
polyethylene is relatively high. (20) Therefore,
HDPE has a potential use as an energy source.
One possible barrier to recycling plastic non-
ref illable containers is the presence of pesticide
in the resin. The potential effect of any remain-
ing -residue adsorbed to or absorbed by the
container walls may rule out or severely restrict
the reuse of the recycled plastic.
the properties of some plastics. Therefore, the
quality of recycled resins may be somewhat
inferior to that of virgin resins.
These two issues are being studied by field
testing containers made from recycled plastic.
In 1990, DuPont packaged Lorax DF herbicide
(a dry flowable) in recycled containers. These
containers were evaluated by farmers in six
states and the users found no performance dif-
ferences between jugs made from recycled resin
and 100-percent virgin material.(21)
Another potential barrier is the cost-effec-
tiveness of recycling. Recycled resins sell for
less than virgin resin. Because of the cost of
transporting and processing the resin, there
may be insufficient economic incentive for recy-
clers of plastic pesticide containers.
8.9 Collections Programs
8.9.1 General
As discussed in section 8.8.1, collection and
separation are the first two steps in recycling
after the material is discarded. With pesticide
containers, separation precedes collection. Af-
ter the pesticide is removed and the containers
are cleaned, the user separates the containers
from other agricultural waste. The plastic or
metal containers are also segregated so they can
enter the appropriate collection program.
Collection programs can be one step involved
with the disposal of empty pesticide containers.
These programs are generally attractive to end
users because they provide an inexpensive and
fairly convenient solution to the leftover con-
tainer problem. However, some programs such
as deposit and refund systems, may seem both-
ersome or time-consuming.
Also, natural degradation processes of the The number of pesticide container collection
plastic may be a pptential barrier. Environ- programs is rapidly growing. These programs
mental exposure and the reprocessing itself affect differ greatly; some of the variables include:
136
-------
Pesticide Containers A Report to Congress
•Mandatory vs. voluntary;
•State-run vs. industry-run;
•Central collection site vs. mobile collection;
•The type of container accepted (metal vs.
plastic vs. both); and
•Who inspects the containers.
Despite the differences, there are two com-
mon themes:
•Proper rinsing is essential; and
•Inspection of the containers is necessary to
ensure proper rinsing.
Many of the programs are pilot projects to
determine the feasibility and logistics of con-
tainer collection and recycling.
This section summarizes the pesticide con-
tainer collection programs that have been brought
to EPA's attention.
8.9.2 Maine Deposit and Return Program
In 1983, Maine passed a law regulating the
return and disposal of containers of limited use
and restricted use pesticide containers. Maine
initiated a return and deposit program for these
pesticide containers in 1985.
Under the program, dealers affix an alpha-
numeric identifying sticker on all limited use
and restricted use pesticides purchased in the
state. For containers purchased out of state, the
user is required to obtain a sticker from the
Maine Board of Pesticide Control. Containers
in stock before April 1,1985, were required to
have a sticker obtained from the Board.
the number of containers and their sticker
numbers is brought to the collection point by
the user. At that time, the containers are checked
to verify proper rinsing. The user receives a
refund for the containers that are returned. As
the program has evolved, a debit/credit record
has occasionally been used instead of deposits.
Collection points include dealerships or other
dealer-chosen locations, landfills or other acces-
sible locations chosen by the Board staff, or sites
arranged by farmers or applicators.
In 1985, four percent of containers were re-
jected and returned to their users for further
rinsing. Inspection for proper rinsing was done
visually in 98 percent of the cases. For contain-
ers that appeared improperly rinsed, an en-
zyme test was available if necessary.
In subsequent collection seasons, the Board
has brought enforcement actions against of-
fenders. In 1989, almost 9,000 containers were
returned; 152 containers were rejected for con-
taining improper levels of residue.
8.9.3 Mississippi Program
In 1989, the Mississippi Department of Agri-
culture and Commerce conducted a pilot pro-
gram to determine the feasibility of pesticide
container recycling. Other groups involved
with the pilot program include NACA, DuPont,
ICI Americas, the Mississippi Farm Bureau, the
Mississippi Department of Natural Resources,
the Delta Council, Mississippi State University,
local governing boards in Washington County,
the Mississippi Cooperative Extension Service,
and theU.S.EPA.
Deposits of $5 for containers smaller than 30
gallons and $10 for those 30'gallons and larger
are charged. The containers are returned on an
appointed collection day after the growing sea-
son. Users are required to triple rinse the con-
tainers (or the equivalent). An affidavit listing rinsing nozzles.
137
The first step was to educate growers about
rinsing. Washington County Extension agents
distributed educational materials on proper
rinsing and ICI Americas donated 650 pressure
-------
Chapter 8 - Nonrefillable Containers: Disposal
Users brought properly rinsed metal and
plastic containers to eight sites in Washington
county. About 30,000 pounds of pesticide con-
tainers were collected. (22) The steel containers
were shipped to a metalwork plant in Green-
ville, Mississippi Approximately 10 pounds of
plastic containers in each of 40 product groups
were separated for further study. (23) The other
plastic containers were crushed and baled in a
cotton gin and sent to two recycling facilities in
the Midwest.
With the cooperation of NACA and DuPont,
the plastic bottles that were sorted by type were
tested at various stages in the recycling process.
The three stages were:
•Shredded containers with no additional
cleaning;
•Shredded containers after a hot wash with
detergent; and
•Washed plastic that had been heated to 200
degrees Centigrade and extruded into pel-
lets.(24)
Samples from each stage were returned to
the pesticide manufacturer for additional test-
ing.
In 1990, the program was expanded to in-
clude 10 counties.(25) Approximately 300,000
pounds of plastic were collected. In the fall of
1990, a task force met in Mississippi to develop
criteria that can be used by any county within
the state to operate a container recycling pro-
gram. Subcommittees of the task force will
address topics such as collection, processing,
inspection, education, and publicity. The great-
est limiting factor for the success of any addi-
tional county programs is the limited market for
the recycled plastic.(26)
8.9.4 Minnesota
In 1989, the Minnesota Department of Agri-
culture (MDA) in cooperation with industry,
farm, and university representatives conducted
an extensive statewide program to educate users
about proper rinsing. The "Rinse and Win"
campaign included the distribution of informa-
tion about rinsing and demonstrations of triple
and pressure rinsing at farm shows and field
days throughout the state. (27) This educational
program was intended to lay the groundwork
for subsequent container collection programs.
In 1990, the MDA ran four container collec-
tion programs that included six counties and
evaluated a collection program held in another
county. The containers were required to be
properly rinsed (triple or pressure rinsed), dry,
have the labels and caps removed, and have the
bottom punctured. (28) MDA staff inspected
the containers brought to the collection site by
the users. If containers were not properly rinsed,
the user was shown how to properly do so. In
several cases, the user returned the rejected con-
tainers after thoroughly rinsing them. Figure 8-
3 shows some of the containers that were ac-
cepted at one of the collection sites.
1 igure 8-3
Containers accepted at one
1990 Minnesota collection
Photo Credit Minnesota Department of Agriculture.
138
-------
Pesticide Containers - A Report to Congress
1 igure 8-4
Containers shredded in a
mobile granulating unit in
the Minnesota collection
programs
Photo Credit Minnesota Department of Agriculture.
Envirecycle was contracted to recycle the
collected containers. Figure 8-4 shows the mobile
granulator provided by Envirecycle. The con-
tainers were granulated at the collection sites
and then transported to St. Joseph, Missouri to
be processed. Shredding the containers at the
site greatly reduces the volume of the plastic,
thereby decreasing transportation costs. (29)
The Minnesota Department of Agriculture
collected and inventoried more than 8,300 con-
tainers in 1990. (30) The rejection rate at the
three sites ranged between 14.5 and 27.7 per-
cent. MDA concluded that most of the rejected
containers were not rinsed immediately after
dispensing the pesticide, which resulted in vis-
ible residue. At the Houston County collection
site, the inspection official noticed that a few
formulation/container combinations were more
frequently rejected than others. This observa-
tion suggests that these products may have a
problem with the formulation and container
design interaction. The main problem with
these containers was residue being trapped in
the hollow handles.(31)
The users who returned containers were
asked to fill out a questionnaire. The questions
focused on participation in the program, inves-
tigating reasons for participating, the distance
traveled, and publicity. This information will
be used to develop future collection programs.
Morecollection programs are being planned
for the 1991 growing season with several vari-
ations. For example, at one of the collection
sites, dealers will inspect the containers after
being trained by MDA staff. The purpose of
these variations is to determine the most effi-
cient way to run a collection program.(32)
8.9.5 Oregon
Since 1984, the Oregon Agricultural Chemi-
cals Association (OACA) has run a collection
and recycling program at no cost to participat-
ing growers. The program began in response to
plans for legislation that would have required
dealers to accept empty containers from pesti-
cide users. The Oregon Department of Environ-
mental Quality has reviewed the program for
compliance with state regulations but does not
provide any funding or personnel. The pro-
gram has expanded continuously since 1984.
Approximately 22,000 containers were collected
in 1988.
On specified days, growers bring both metal
and plastic containers to the collection site. The
collection site is often a facility at a local dealer.
Metal containers must be rinsed, dry, crushed,
and punctured. Plastic containers must be rinsed,
dry, and have the caps and plastic sleeves re-
moved. OACA representatives inspect the
containers and catalogue them by type (metal
or plastic). The metal containers are then trans-
ported to Schnitzer Steel Products Company in
139
-------
Chapter 8 Nonrefillable Containers: Disposal
Portland, Oregon to be recycled. Plastic con-
tainers have been sent to Partek Corporation in
Vancouver, Washington for recycling. (33)
8.9.6 Iowa
Using a grant from the U.S. EPA, the Iowa
Fertilizer and Chemical Association (IFCA) and
the Iowa Department of Agriculture and Land
Stewardship ran a voluntary collection and re-
cycling program for plastic pesticide containers
during the summer of 1990. Approximately
64,000 containers were collected.
IFCA worked with trade associations, the
Iowa Farm Bureau, and Iowa State University
Extension Service to distribute the educational
material to Iowa growers. (34) The collection
project began with an educational program on
rinsing, with emphasis on pressure rinsing.
Growers brought the containers to 31 collec-
tion sites, all of which were licensed sanitary
landfills. The landfill operators were trained by
IFCA and inspected the containers themselves.
Containers were required to be triple or pres-
sure rinsed. Approximately 50 percent of the
containers were rejected. This shows the need
for more education on proper rinsing, espe-
cially the necessity of rinsing immediately after
mixing. Additionally, it was reported that the
inspection criteria may have been too stringent.
The dripping or splashing of some products
that are not water-soluble may cause stains on
the exterior of the container that cannot be
removed by rinsing.
As containers were collected throughout the
summer, they were piled behind snow fences at
the landfills. At the end of the growing season,
several people voluntarily transported the con-
tainers in their own trucks to eight sites. A
mobile granulator visited each of these sites and
the containers were shredded to reduce the
volume of the HOPE. The granulated plastic
was then transported to a recycler for process-
ing and was used to make more pesticide con-
tainers. (35)
Another part of the project involved taking
soil samples at the landfill sites before and after
the collection. This was done to show that if a
sufficient inspection program was followed, con-
tainers could be stored temporarily without
contaminating the soil. (36)
8.9.7 Illinois
A metal pesticide container collection and
recycling program began in 1979 in Illinois.(37)
The program was developed through a coop-
erative effort by the Illinois Farm Bureau, the
Illinois Environmental Protection Agency, and
the Department of Energy and Natural Resources.
The Farm Bureau Young Farmer Committees
provided the labor and management for the col-
lection projects. After the triple rinsed cans
were taken to collection sites by growers, they
were crushed and then sent to a landfill or scrap
metal dealer.
In 1979, a total of 44,000 metal cans were col-
lected in four counties. The following year the
program expanded to 26 counties and more
than 130,000 containers were collected. In 1982,
20 counties participated and about 103,000 cans
•were collected.
During this project, the number of metal
cans used by farmers in Illinois decreased from
approximately 1.5 million in 1978 to 500,000 in
1982. This drop was attributed to an increase in
the number of plastic jugs as well as the use of
minibulk containers. The program ended in
1984 because of the declining number of metal
containers.
Through legislation enacted in 1989, the Illi-
nois Department of Agriculture, in cooperation
with the -Illinois Environmental Protection
Agency, is required to design and implement a
pilot container collection and recycling project
140
-------
Pesticide Containers A Report to Congress
by June 1991. The project must also include sur-
veys and the collection of information on con-
tainer storage and disposal.
During the summer of 1990, pre-pilot dem-
onstration projects were held at three dealer-
ships throughout Illinois. At one of the sites,
several thousand pounds of plastic containers
were collected. The containers were shredded
by a portable granulator and will be processed
by Envirecycle.(38)
A countywide pilot program is planned for
next spring. The three pre-pilot programs and
the pilot program will be evaluated in terms of
collection and recycling methods as well as
cost-effectiveness. (39)
8.9.8 Florida
In 1990, the Florida Department of Environ-
mental Regulation (DER) organized a volun-
tary pilot container collection and recycling
project in southern Florida. (40) Four large farms
participated in the program which emphasizes
pressure rinsing and collection of plastic nonre-
fillable containers.
Personnel at each of the farms were trained
to properly pressure rinse containers by repre-
sentatives from the DER, DuPont, and United
Agri Products (UAP), a division of ConAgra.
The Florida Fertilizer and Agrichemical Asso-
ciation provided pressure rinsing nozzles for
the farms. Participants pressure rinsed the
containers, removed the caps, and stored the
containers in a dry location. United Agri Prod-
ucts provided a portable granulator, which was
transported to each farm to shred the contain-
ers. UAP was also responsible for selling the
granulated plastic to a recycler. The Florida
DER is testing some of the containers to deter-
mine the residue remaining after pressure rins-
ing and DuPont is testing samples of the granu-
lated plastic.
The collection program will be expanded to
northern and central Florida in 1991. The Flor-
ida Extension Service and various trade associa-
tions will help train personnel at the increased
number of farms. The DER hopes that the
Florida agricultural industry accepts recycling
pesticide containers and will be willing to manage
and fund a container collection and recycling
program, because state funds are not currently
available for a permanent program. (41)
8.9.9 North Carolina
A collection and recycling project was held
in Pitt County, North Carolina in the summer of
1990.(42) The Pitt County Extension Service
and Pitt County Engineering Department or-
ganized the program, which collected almost
7,000 pounds of plastic containers.
Metal bins were set up at five dealerships,
and containers were collected for six weeks be-
ginning in June. At the beginning of August,
the bins were transported to the East Carolina
Vocation Center in Greenville where the con-
tainers were sorted by color and baled. The
containers will be sold to the Plastic Materials
Group, a manufacturing company in Fayette-
ville to be recycled into field drainage tiles. The
program will be continued in Pitt County in
1991.
8.9.10 Missouri
The Service and Supply Co-op, a pesticide
and fertilizer distributor in Montgomery County,
Missouri ran a container collection and recy-
cling program in 1990. (43) Plastic pesticide con-
tainers were collected at two dealerships ser-
viced by the distributor and at another dealer.
Approximately 7,000 containers were collected
at the three sites. Ten farmers participated in
the program, although a majority of the contain-
ers were generated by the Service and Supply
Co-op.
141
-------
Chapter 8 - Nonrefillable Containers: Disposal
An employee of the Service and Supply Co-
op inspected the containers for residue and
odor before they were accepted. About 4 per-
cent of the containers failed this inspection and
another 3 percent were rejected by Envirecycle,
who granulated and processed the plastic. The
labels, plastic sleeves, and caps were removed
before the containers were granulated.
The Service and Supply Co-op will hold
meetings before the next growing season to
educate farmers about rinsing and recycling
and to generate enthusiasm for the collection
program.
8.9.11 Washington
The Columbia Field Men and Dealers Asso-
ciation has run a container collection and recy-
cling program for metal containers for five
years. (44) Containers must be triple rinsed,
dry, punctured, and crushed to be accepted.
Volunteers from the Columbia Field Men and
Dealers Association inspect the containers for
visual residue as well as odor. The program co-
ordinator has found that the pesticide odor
remains in the container, even when no visible
residue is present.
A collection was held in September 1990 at
three sites in Washington. A total of 22,640
pounds of metal was collected, consisting of
more than 3,000 containers which ranged in size
from 1 gallon to 55 gallons. The containers were
accepted by a local recycler and transported to
a smelter in Pasco, Washington.
In addition, some manufacturers have initi-
ated container collection programs. For ex-
ample, Monsanto encourages the return of its
30-gallon drums for forestry and small grain
pesticides. Approximately a third of these drums
were being returned on a voluntary basis. (45)
When Monsanto began to require a small de-
posit ($10) on the drums, the return rate in-
creased tremendously. Users return the rinsed
containers to the distributor where the pesticide
was purchased and receive credit for the de-
posit.
8.9.12 Other Programs
There are probably many other programs
run by distributors, dealers, or local trade or-
ganizations like those described for Missouri
and Washington that EPA was not aware of
when this report was prepared.
142
-------
Pesticide Containers A Report to Congress
Endnotes
1. Gilding, T., National Agricultural Chemicals
Association, letter to Principal Contacts of
Member Companies, August 17,1988.
2. Minnesota Department of Agriculture, Min-
nesota Empty Container Disposal Report,
March 1988.
3. Taylor, A., Illinois Environmental Protec-
tion Agency, personal communication with
U.S. EPA, Office of Pesticide Programs,
December 3,1990.
4. Myrick, C, National Agrichemical Retailers
Association, Summary of National Agrichemi-
cal Retailers Association's Empty Container
Disposal Survey, 1989.
5. McClelland, W., North Carolina Depart-
ment of Agriculture, "A Study of Pesticide
Container Disposal Sites in North Carolina,"
(1981-1983). July 18,1983.
6. Denny, R. and D. McLaughlin, Maine Board
of Pesticide Control, Report on Maine
Pesticide Container Program, 1985.
7. Buzicky, G., et al., "Evaluation of Improperly
Disposed of Pesticide Containers on Minne-
sota Farms (Draft)," FIFRA Enforcement
Special Project prepared for the U.S. EPA,
Region V, October 1990.
8. Much of the information on the disposal meth-
ods in this chapter is taken from a report
being drafted for EPA that will summa-
rize state regulations relating to pesticide
storage, transportation, and disposal.
9. Minnesota Department of Agriculture, "Min-
nesota Empty Container Disposal Report,"
March 1988.
10. U.S. EPA, Trip to California, Oregon, Wash-
ington, September 16-22,1990, U.S. EPA, Of-
fice of Pesticide Programs, October 1990.
11. Institute of Scrap Recycling Industries, Inc.,
"What is Recycling? Why Do Community
Recycling Programs Sometimes Fail?"
12. Steel Can Recycling Institute, "Recyclable
Steel Cans: An Integral Part of Your
Curbside Recycling Program," 1990.
13. Ibid.
14. Minnesota Department of Agriculture/U.S.
EPA, meeting summary, U.S. EPA, Office of
Pesticide Programs, August 3,1990.
15. Soilserv,Inc./Wilbur-Ellis/Formulogics/
U.S. EPA, meeting summary, U.S. EPA,
Office of Pesticide Programs, September 18,
1990.
16. U.S. EPA, Trip to California, Oregon, Wash-
ington, September 16-22,1990, U.S. EPA,
Office of Pesticide Programs, October 1990.
17. Frieberg, D., Iowa Fertilizer and Chemical
Association, "Interim Report on Iowa Pesti-
cide Container Recycling Project," 1990.
18. U.S. EPA, Trip Report to Missouri, May 25,
1990, U.S. EPA, Office of Pesticide Programs,
1990.
19. Morelli, G., Central Can Corporation, person-
al communication with U.S. EPA, Office of
Pesticide Programs, January 24,1991.
20. Tapas, J., Sandoz, personal communication
with U.S. EPA, Office of Pesticide Programs,
August 17,1990.
21. Nixon, G., " Container Recycling: Mississippi
Program is Industry First," Custom Applica-
tor, Vol. 20, Number 9, pecember 1990):
pp.!4-22b.
22. Johnson, K., "Getting a Handle on Contain-
er Disposal," Farm Industry News, February
1990.
23.Ibid.
24. Ibid.
25. Nixon, G., "Container Recycling: Mississippi
Program is Industry First," Custom Appli-
cator, Vol. 20, Number 9, (December 1990):
pp.!4-22b.
26. McCarty, R., Mississippi Department of Agri-
culture and Commerce, personal communi-
cation with U.S. EPA, Office of Pesticide Pro-
grams, October 23,1990.
27. Johnson, K., "Getting a Handle on Contain-
er Disposal/'Farm Industry News, February
1990.
28. Wegner, D., "Pesticide Container Drive Set,"
Crookston Daily Times, Crookston, Min-
nesota, October 12,1990.
143
-------
Chapter 8 Nonrefillable Containers: Disposal
29. Envirecycle/U.S. EPA, meeting summary, U.S.
EPA, Office of Pesticide Programs, October
29,1990.
30. Hansen, R., Minnesota Department of Agricul-
ture, letters to T. Bone, U.S. EPA, Office of Pes-
ticide Programs, October 4,1990 and Novem-
ber 1,1990.
31. Kelleher, K., Houston County Recycling Co-
ordinator, letter to T. Bone, U.S. EPA, Office
of Pesticide Programs, October 24,1990.
32. Hansen, R., Minnesota Department of Agri-
culture, personal communication with U.S.
EPA, Office of Pesticide Programs, December
31,1990.
33.U.S. EPA, Trip to California, Oregon, Wash-
ington, September 16-22,1990, U.S. EPA, Of-
fice of Pesticide Programs, October 1990.
34. Nixon, G., "Recycling Pesticide Containers
Catches on in Other States," Custom Applica-
tor, Vol. 20, Number 9, (December 1990): pp.18-
22.
35. Ibid.
36. Ibid.
37. Mergen, J., "The Illinois Farm Bureau Pesti-
cide Can Recycling Project 1979-1982," June 3,
1983.
38. Nixon, G., "Recycling Pesticide Containers
Catches on in Other States," Custom Applica-
tor, Vol. 20, Number 9, (December 1990): pp.18-
22.
39. Ibid.
40. Dwinell, S., Florida Department of Environ-
mental Regulation, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, August 8,
1990.
4I.Nixon, G., "Recycling Pesticide Containers
Catches on in Other States," Custom Applica-
tor, Vol. 20, Number 9, (December 1990): pp.18-
22.
42. Ibid.
43. Ricks, T., Service and Supply Co-op, personal
communication with the U.S. EPA, Office of
Pesticide Programs, November 1,1990.
44. Lynch, K., Wilbur-Ellis, personal communi-
cation with U.S. EPA, Office of Pesticide
Programs, November 1,1990.
45. Allison, S., Monsanto, personal communi-
cation with U.S. EPA, Office of Pesticide
Programs, October 23,1990.
144
-------
Pesticide Containers A Report to Congress
Chapter 9
Refillable Containers:
Use
9.1 Introduction
Refillable containers present significantly dif-
ferent issues and concerns than nonrefillable
containers. One of the major problems with
nonrefillable containers, worker exposure while
pouring the pesticide, is virtually eliminated in
refillable containers. Refillable containers that
include pumps and meters, such as those pro-
vided by the pesticide registrant, act as closed
systems, greatly reducing the potential for ex-
posure during the transfer of the pesticide. Ciba-
Geigy claims that the use of their minibulk con-
tainer (the Farm-Pak) instead of 2.5-gallonplas-
tic jugs reduces exposure by 95 percent. (1) How-
ever, many of the minibulk containers used at
the distributor/dealer level do not have self-
contained pumps and meters. These containers
have large openings where pumps, hoses, and
meters can be attached as a transfer system. Al-
though worker exposure is still decreased com-
pared to 2.5-gallon plastic jugs, these containers
are not considered closed systems because of
the potential worker contact when mounting or
removing the pump and meter. (2)
dresses topics including ownership of the con-
tainer, transportation, specific design features,
associated hardware, and the potential for stan-
dardization. These topics are discussed for each
type of refillable container: minibulk, small
volume returnable, bulk, and dry refillable.
Because refillable containers are used pre-
dominantly in the agricultural sector, this chap-
ter and the following two focus on issues in-
volved with refillable containers in the agricul-
tural market.
9.2 Minibulk Containers
9.2.1 Ownership
Ownership of the containers is an important
issue today because container quality, filling
practices, container integrity, and residue re-
moval procedures vary according to the mini-
bulk owner. Minibulk containers are owned by
registrants, distributors, dealers, and farmers.
The exact distribution of minibulks among these
groups is not known, although dealers own
more than any of the other groups.
Refillable containers have a different set of Practices vary among major pesticide pro-
potential problems and issues. This chapter ad- ducers. Originally, Ciba-Geigy intended that
145
-------
Chapter 9 - Refillable Containers: Use
dealers sell their Farm-Pak minibulks to farm-
ers. Given the option of selling or maintaining
ownership, however, most dealers chose to own
the Farm-Paks themselves. (3) Id prefers to
have the dealers own their minibulk containers,
called "Satellite 110" systems. In fact, the name
was chosen to encourage dealers to use the
minibulks as "satellites of their plants ~ small
storage systems for the pesticide. "(4) On the
other hand, Monsanto maintains ownership of
its minibulk containers, called Shuttles. The
Shuttles are leased to the dealer. (5) American
Cyanamid has two programs for their mini-
bulks. In the South, American Gyanamid re-
tains ownership of the containers, and the mini-
bulks are returned to the company for cleaning
and inspection. In the rest of the country, deal-
ers own most American Cyanamid minibulks. (6)
As described above, one way for dealers to
obtain minibulk containers is through the regis-
trant. Another way is for the dealer to purchase
minibulks directly from a container manufac-
turer. Often the containers obtained directly by
the dealer are of poorer quality than those pro-
vided by a registrant.
There are several common methods for an
end user to obtain minibulks. When the bulk
pesticide market was evolving several years
ago, some registrants gave the minibulk con-
tainers to farmers as an incentive to use refil-
lable containers. This practice has been discon-
tinued with the better quality minibulks, i.e.,
those meeting the MACA-75 or DOT-57 stan-
dards, because of the high container cost. How-
ever, some retailers still provide the cheaper
minibulk containers free of charge to end users
as an incentive. In some cases a dealer who does
not store bulk products may provide minibulks
to end users. These dealers would not maintain
ownership because they do not refill the con-
tainers^?)
Perhaps the biggest issue is not the owner-
ship of the container, but the quality of the con-
tainer, which tends to vary according to the
owner. In terms of container quality, minibulk
containers fit into one of two very different gen-
eral categories. (8) The better quality minibulks
meet the MACA-75 or DOT Specification 57
standards, which are described in chapter 5,
and cost approximately $250. The minibulks
owned by the registrant or provided to a dis-
tributor or dealer by the registrant are generally
in this class. The cheaper minibulks that cost
about $50 are in the other category. Some dealer-
owned and most farmer-owned containers fit
into this category. A large amount of concern
has been expressed about the poorer quality
minibulks, because the widespread use of these
containers may lead to an increase in the num-
ber of large spills.
Dealers vary in their desire to own mini-
bulks. Dealers who prefer to control the con-
tainers cite several reasons for doing so:
•The dealer can regulate the condition of the
minibulk through regular maintenance and
proper storage during the off-season;
•The dealer has more leverage in removing
old, damaged, or potentially dangerous
containers from the distribution chain. If a
farmer wants a self-owned minibulk in
poor condition to be filled, a dealer may be
forced to choose between environmental
safety and losing a sale;
•Service is sold with the pesticide itself. In
other words, regular maintenance is used
as a promotional tool by dealers, as well as
being to their general advantage; and
•A dealer loses control of the account if the
minibulk is sold to the farmer. (9)
146
-------
Pesticide Containers - A Report to Congress
There are several reasons dealers may prefer
not to own or control the minibulks.
•Storing minibulk containers requires a large
amount of space;
•Cleaning, inspecting, and maintaining the
containers is a large additional cost of busi-
ness — an estimated $100 per year to handle,
clean, and maintain one minibulk;(10) and
•The dealer is responsible for disposing of
the minibulk.
9.2.2 Refilling
The refilling of minibulk containers requires
a separate registration for the repackaged pesti-
cide, except as provided by EPA's bulk pesti-
cide enforcement policy. The policy was devel-
oped to define when bulk shipments and trans-
fer practices would be allowed without a sepa-
rate registration. The development of the bulk
pesticide enforcement policy in 1977 fostered
the use of refillable containers to the current
level.
A number of issues have recently been raised
regarding the bulk enforcement policy, specifi-
cally the quantity limit of greater than 55 gal-
lons. The quantity of 55 gallons was selected in
1977 before the use of refillable containers was
common. The restriction to quantities greater
than 55 gallons was intended to control the
containers into which pesticides were repack-
aged. At the time, the larger containers were
considered safer.
The greater than 55-gallon limit as estab-
lished by the 1977 policy has two major impli-
cations. First, containers with capacities 55 gal-
lons or less cannot be refilled under the bulk
pesticide enforcement policy without a regis-
tration. Second, quantities of pesticides 55 gal-
lons and less cannot be placed into a container
larger than 55 gallons under the bulk pesticide
enforcement policy without a separate registra-
tion.
These two implications have been suggested
as obstacles to increasing the use of refillable
containers. As described below, EPA amended
the bulk policy in 1991 to provide that quantities
less than 55 gallons or 100 pounds could be
repackaged into refillable containers under
certain conditions. Industry representatives have
suggested further modifying the 55-gallon limit
for the following reasons.
First, the demand for refillable containers
with capacities of less than 55 gallons is increas-
ing. Several companies are now using the 15-
and 30-gallon small volume returnables.
However, these containers may be refilled only
by the registrant.
Many industry representatives believe that
the use of "smaller" refillable containers (those
less than 55 gallons) that can be refilled is essen-
tial to the future of pesticide container manage-
ment. (11) As discussed in section 4.5.2, it has
been predicted that the use of minibulks will
continue to increase for several years and then
will level off when most of the potential mono-
crop markets have been tapped. (12) Smaller
refillable containers are desirable because many
applications do not require 55 gallons of pesti-
cide. This is true for small fields and for pesti-
cides that are applied at a low dosage per acre.
Smaller refillables may become increasingly
important if the trend towards more concen-
trated pesticide formulations continues.
However, reducing the quantity limit with-
out adding standards for the containers to be
refilled could lead to problems with cross-con-
tamination and container integrity. Decreasing
147
-------
Chapter 9 Refillable Containers: Use
the quantity limit without such standards could
allow any pesticide container to be refilled,
including 2.5-gallon plastic jugs. This could be
prevented by establishing minimum criteria for
the containers.
The second issue related to the 55-gallon
limit involves the amount of pesticide repack-
aged into containers larger than 55 gallons.
Under the 1977 version of the bulk policy, less
than 55 gallons of pesticide product could not
be placed into a container "without a separate
registration unless the repackaging was done to
complete an earlier sale and application of a
bulk pesticide and this was documented. This
limitation created some problematic situations.
For example, if only 40 gallons of pesticide were
needed for an application, a grower could not
buy 40 gallons of pesticide in a 110-gallon con-
tainer. The grower had to purchase some com-
bination of nonref illable containers, such as eight
5-gallon cans. The National AgriChemical Re-
tailers Association (NARA) has estimated that
allowing less than 55 gallons of pesticide to be
repackaged into minibulk containers with ca-
pacities of 100 gallons or greater would reduce
the number of 2.5-gallon jugs used each year by
approximately 2.3 million.(13)
However, these problems were eliminated
when EPA amended the bulk pesticide enforce-
ment policy on March 4, 1991. One of the
revisions redefined the definition of bulk. The
bulk policy was amended to allow the repack-
aging of any quantity of pesticide into ref illable
containers, provided the container is designed
and constructed to accommodate the return and
refill of greater than 55 gallons liquid or 100
pounds of dry material, certain rinsing proce-
dures are followed, and the other conditions of
the bulk policy are met. (14)
In 1990, a pilot program on the "56-gallon
policy" was run in Iowa through the coopera-
tion of the Iowa Fertilizer and Chemical Asso-
ciation (IFCA), the Iowa Department of Agri-
culture and Land Stewardship (IDALS), and
the EPA, particularly Region VII and the Office
of Compliance Monitor ing. (15) Under this pro-
gram, dealers were allowed to repackage less
than 56 gallons of pesticide product into mini-
bulks under the following conditions:(16)
•The dealers were authorized to participate
by IDALS, which involved sending a letter
of authorization to IDALS;
•The minibulk containers were 100 gallons
or larger, met the DOT-57 or MACA-75
specifications, and were owned by a dealer,
distributor, or registrant;
•The pesticide sold under the program was
sold and used only in Iowa;
•The dealers tracked all sales of less than 56
gallons via the container serial number;
•The dealer had an EPA pesticide produc-
ing establishment number (which was al-
ready a requirement for repackaging) and
otherwise complied with FIFRA; and
•The dealers had received from registrants
written amendments to their existing re-
packaging agreements that authorized re-
filling .in amounts less than 56 gallons.
In addition, the pilot project studied cross-
contamination in the minibulk containers that
are currently being used in Iowa. IDALS agreed
to sample a percent of the containers that were
refilled to test for cross-contamination. Also,
IFCA surveyed participating dealers on the
minibulk tanks in use. The survey was de-
signed to collect information such as the percent
of minibulks that meet the DOT-57 or MACA-
75 standards and the average age of the contain-
ers being used.
9.2.3 Transportation
Transportation plays a more important role
in the design and use of minibulk containers
148
-------
Pesticide Containers - A Report to Congress
than nonrefillable containers. End users often
do not have the necessary equipment to move
minibulk containers. Therefore, when a dealer
uses a f orklif t to place the container in the back
of a pickup or on a flat-bed truck, the container
usually stays in the same place until the end
user returns it. Alternatively, if a dealer deliv-
ers a minibulk to the end user, the container
remains stationary until the dealer retrieves it.
In other words, use of a minibulk may restrict
the mobility of the container and the flexibility
of the end user.
Another important issue is whether or not
the minibulk containers are secured to or within
the vehicle. Some dealers insist that minibulks
be tied down when the container leaves the
dealership.(17) However, these precautionary
measures are not always taken.
A number of minibulk incidents have been
reported. For example, in 1989, the Illinois EPA
investigated at least four incidents involving
minibulk tanks falling off trucks.(18) State offi-
cials in Illinois, as well as those in other states,
are very concerned about minibulk tanks being
inadequately secured during transportation.
Also, 11 incidents involving spills from mini-
bulk tanks during transportation were reported
between 1985 and 1989 to the Coast Guard's Na-
tional Response Center (NRC). Most pesticide
spills are not required to be reported to the
NRC. Therefore, the actual number of spills
was probably much larger. Most of these inci-
dents involved the minibulk falling off the truck
during delivery or as the vehicle was turning a
corner.(19)
Preventing this type of incident is particu-
larly important because minibulks are usually
transported from the dealer to the field with the
associated hardware, Le., pump, meter, and
hoses attached. If the equipment is not recessed
or otherwise protected, it can shear off if the
container falls from the truck.
9.2.4 Container Construction — Potential Issues
This section describes some of the minibulk
issues and potential problems raised by dealers,
end users, or other people in the pesticide in-
dustry. Some of these problems, such as diffi-
culty in draining or emptying, are specific to
certain minibulk designs. Minibulk design,
use, and marketing are still evolving; these is-
sues may be viewed as benchmarks of that
evolution. However, EPA believes that these
problems should be reduced or eliminated if the
use of refillable containers continues to grow
and is encouraged by EPA.
9.2.4.1 Durability of the Container
Minibulk containers must be durable and
rugged enough to withstand repeated transpor-
tation, rinsing, and refilling. While this han-
dling is difficult to simulate, certain standards
such as performance tests can be established to
ensure that the containers are sturdy enough to
withstand some potential abuse, such as sud-
den impacts, jars, or drops from vehicles. One
example of an appropriate performance test is a
drop test, commonly required in container speci-
fications. Both the DOT specification 57 for
metal portable tanks and the MACA-75 stan-
dards specify a 2-foot drop test. It has been
estimated that 65 to 70 percent of minibulk
containers produced today meet the MACA-75
standards. (20) Therefore, these containers, as
well as the specification 57 steel minibulks,
have met a certain durability standard.
9.2.4.2 Protection of Hardware
As discussed previously, protection of the
pumps, meters, and hoses is necessary because
minibulks are generally transported with the
hardware attached. Protection of hardware can
be achieved in several ways. The pump can be
recessed, Le., the minibulk can be designed
149
-------
Chapter 9 • Refillable Containers: Use
1 i^ure 9-1
A minibulk container where the pump and
hoses are not protected
with a depression or place for the pump inside
the contour of the container. Another type of
protection is a 10- to 12-inch lip or ridge on the
top of the container. Figure 9-1 shows a con-
tainer where the pump and hoses are not pro-
tected. Figure 9-2 is a picture of a minibulk that
protects the pump with an extended rim on the
top of the container.
An alternative design with the same pur-
pose is a check valve in the connection between
the pump and the minibulk. If the pump is
sheared off the container, the valve automati-
cally closes and leakage is prevented.(21) Fig-
ure 9-3 is a drawing of an appropriate check
valve. Both of these options — hardware protec-
tion and the use of a check valve ~ offer equal
environmental protection.
9.2.4.3 Difficult To Empty Completely
Photo Credit: U.S. EPA.
pump may not be near the bottom of the con-
tainer. Alternatively, the inside bottom of the
container may not be designed to drain well. A
minimum slope is needed for the pesticide to
flow to one location where it can be pumped
from the container. (22) When significant quan-
tities (about 1 gallon) remain in the minibulk, an
end user may be tempted to remove the pump
and retrieve the pesticide by other means.(23)
This is unnecessary, because dealers account for
the normally unrecoverable quantity when fill-
ing the container. Additionally, this situation is
problematic for the dealer because the tamper-
evident device would have been compromised,
meaning that the dealer has no assurance about
the prior contents of the minibulk.
9.2.4.4 Difficult to Drain
Some minibulk containers are difficult to Some minibulks, specifically most DOT
empty completely which may be caused by specification 57 containers, have a valve or
several factors. The dip tube attached to the withdrawal mechanism on the bottom of the
150
-------
Pesticide Containers - A Report to Congress
\ minibulk container lh.il is designed! for pump protection
tank which is used to drain excess pesticide and
rinse water. Most plastic minibulks, however,
have openings only on the top of the container.(24)
This makes it difficult for dealers to drain the
minibulk completely because the container must
be tipped on its side or top edge.
9.2.4.5 Storage Space
Some dealers and distributors do not like
minibulk containers because they require too
much storage space. Some minibulks are not
designed to stack, while others cannot be stacked
more than 2 high. (25)
As mentioned in the discussion on transpor-
tation, moving minibulk containers requires
heavy equipment, which could be problematic
or inconvenient for end users. Additionally, the
design of the base of the minibulk container de-
termines the stability of the container and how
conveniently it can be moved with a forklift.(26)
Photo Credit: U.S. EPA.
9.2.4.6 Effect of UV Light
Some concern has been expressed regarding
the effect of UV light on the integrity of mini-
bulks that are exposed to sunlight for extended
periods of time. Exposure to UV light can cause
stress cracking on the surface of the minibulks.
A long-term result of exposure to sunlight is
that the tanks become brittle. (27)
9.2.4.7 Lifetime of Containers
The lifetime of a minibulk depends on the
factors specific to that container, including the
material (s) of construction, exposure to sun-
light, and the storage and handling conditions.
Figure 9-4 is a picture of an old minibulk in poor
condition that had been stored outside for a
long time. Most of the concern has centered on
the expected lifetime of plastic containers; the
extended integrity of stainless steel containers
is generally not considered a problem. MACA
recommends a 5-year lifetime for plastic mini-
bulks. (28) This figure was not determined from
151
-------
Chapter 9 - Refillable Containers: Use
Figure 9-3
Drawing of a check valve
Spring loaded
recirculation
tube
shut off
Spring loaded
suction tube
shut off
BUNG ADAPTER
STAND PIPE
SOURCE: Ciba-Geigy, 1990.
data on failures; it was based more on a lack of
knowledge of what happens to a tank after 5
years. Many minibulk containers have suc-
cessfully been in the field for 5 years, but after
that point the integrity of the container is
questionable. Additionally, the U.N. recom-
mendations contain a 5-year limit for the use of
plastic intermediate bulk containers.
Minibulks should be inspected regularly,
even during the first few years of use. The
containers can be damaged at any point in their
lifetimes due to accidents or particularly rough
152
-------
Pesticide Containers - A Report to Congress
handling. In other words, 5 years is not a
guaranteed lifetime and regular inspection is
necessary to maintain container integrity.
9.2.4.8 Return of Container
Containers that are owned or leased by the
dealer must be returned to the dealer. Dealers
have several ways to encourage end users to
return minibulks. For example, a dealer may
require a deposit — usually about $100 — for
each minibulk.(29) Other dealers charge a flat
rate for the use of a minibulk with an additional
charge per month if the container is not re-
turned on time. (30) Some dealers do not use
monetary incentives, but rely on the user to
return the minibulk. Factors in this situation
include a close working relationship between
the dealer and end user and the end user's
unwillingness to store the minibulk during the
off-season.
9.2.5 Associated Hardware
Because of their large size, minibulk con-
tainers need additional equipment or "hard-
ware" to transfer the pesticide from the con-
tainer to the application or mix tank. This
hardware includes pumps, meters, and hoses.
Some minibulks do not require this additional
equipment, although this type of tank is not
very common.
9.2.5.2 Manufacturers
Several companies supply most of the hard-
ware for minibulk containers, although more
companies are looking to enter the hardware
market as the use of refillable containers in-
creases. Great Plains Industry manufactures
pumps, meters, and couplings that could attach
to the application tank. (31) Science Products, a
division of the Ingersoll Rand Company, pro-
duces pumps, meters, couplings, motors, and
dry breaks. (32) Additionally, other companies,
such as those who produce dry breaks, are
looking to enter the agricultural industry. (33)
9.2.5.2 Potential Problems With Hardware
When registrants provide minibulk contain-
ers to the dealer or distributor, they usually
include the hardware. In this case, the regis-
trants are marketing the entire system as well as
service. Additionally, the registrant may re-
place the equipment periodically. For example,
one manufacturer replaces the hoses used on its
minibulks yearly. (34) On the other hand, this
service usually is not included when a distribu-
tor or registrant provides a minibulk to the end
user. In most cases, these are simply minibulk
containers with a lid and tamper-evident seal. (35)
There is some concern about pumps not
working properly. Generally, pumps break
down because they are not cleaned thoroughly.
Maintenance and regular cleaning can extend
the lifetime of a pump. (36) If a pump breaks
down in the field, it can be very inconvenient for
the user if a back-up pump is not readily avail-
able.
The part of the hardware that raises the most
concern in the pesticide industry is the flowme-
ter, which measures the quantity of pesticide
pumped from the container. There is wide-
spread distrust in the accuracy of the meters. At
least part of this may be a perception problem.
To a user, there is a big difference between
emptying several nonrefillable containers into
an application tank where the amount of pesti-
cide can be seen, and pumping pesticide into
the application tank while relying on the read-
ing on the meter.
Additionally, flowmeters are not always used
correctly. The meters are calibrated by pump-
ing 5 gallons of pesticide into a container marked
for that volume. The meters must be calibrated
for each pesticide product because of differ-
ences in viscosity although this is not necessar-
153
-------
Chapter 9 - Refillable Containers: Use
1'i 14 u re 9-4
An old miniLuilk container that is in poor condition
Photo credit U.S. EPA.
ily done. (37) Also, the viscosity of a product
may change throughout the course of a day,
particularly if the minibulk is stored in the sun.
For example, Ciba-Geigy tested one flowmeter
and found that the temperature change of the
product could not be more than +/- 2 degrees
Centigrade for an accuracy of 100 +/- 5 per-
cent. (38) Requiring a user to perform the time-
consuming calibrations at various times during
the day is impractical.
The flowmeters also have technical limita-
tions. They may record too much pesticide
pumped if there is air in the lines, or too little
pesticide if it is pumped too slowly.(39)
Another problem with flowmeters is that some
farmers do not train their laborers to use them.
Instead, pesticide is pumped into smaller con-
tainers (2.5-gallon or 5-gallon containers) and
taken to the field by the workers. (40) This prac-
tice negates one of the advantages of minibulks
(reducing worker exposure).
9.2.6 Standardization
The issue of standardizing minibulk con-
tainers is one topic that incites quick debate
with strong opinions on both ends of the spec-
trum. The idea of standardization has been
discussed by registrants, container manufactur-
ers, dealers, hardware manufacturers, users,
equipment manufacturers, and regulatory offi-
cials.
9.2.6.1 Potential Areas for Standardization
The first question regarding standardiza-
tion is, "What does standardization of minibulk
containers mean?" The answer is that it could
mean one of several things because there are
several potential areas for standardization. These
areas are:
1. The connection between the container
and the pump connection;
154
-------
Pesticide Containers - A Report to Congress
2. The connection between the pump and
the hose; and
3. The connection between the hose and the
application tank.(41)
The opening on the container is currently in
the range of 4 to 10 inches. The people involved
with the standardization debate disagree about
whether this connection is already standard-
ized. However, the opening size could become
a more prominent issue if smaller refillable
containers become common.
The second potential area for standardiza-
tion is the connection between the pump and
the hose, although this is not really an issue.
Nearly all pumps have standard connections
where a hose with a pipe thread adapter easily
attaches. A hose usually is not removed once it
has been attached. Additionally, pumps gener-
ally are sold with a discharge hose. Therefore,
this is not an area where standardization would
be particularly helpful. (42)
The third potential area is the connection be-
tween the hose and application tank. This type
of connection is not common now, although
some applicators in the West use quick-discon-
nect devices on application tanks. Currently,
pesticide is usually pumped into the top open-
ing of the application or mix tank. A coupler
such as a quick disconnect device or dry break
between the hose and application equipment
would make a minibulk container a truly closed
system. Potential standardization could specify
the size and design of the dry break where one
part would be permanently attached to the
application equipment and the other half would
be on the hose.
9.2.6.2 Advantages of Standardizing
The second question is, "Why consider stan-
dardizing rninibulk containers?" First, some
sort of standardization could ease the burden
on dealers. Currently, hoses, connections, open-
ings, and nozzles are found in a variety of sizes
and threads, which cause the dealer to handle
multiple adapters and products to serve all its
containers. (43) This is particularly burdensome
for small dealers and applicators. Second, stan-
dardization could increase the familiarity of the
user with the equipment. Such an increase in fa-
miliarity of the user could lead to an increase in
safety and acceptance of minibulks. Third, use
of minibulk containers in the agricultural in-
dustry is still a relatively new technology.
Therefore, it would be logical to standardize
before all of the companies invest in research to
develop their own individual systems.
9.2.6.3 Barriers/Disadvantages
The third question that needs to be addressed
is, "What are the barriers or disadvantages to
standardizing minibulk containers?" One bar-
rier is reaching a consensus on rapidly develop-
ing technology within a diverse group of com-
panies and people. A decision on the standardi-
zation of minibulk containers involves repre-
sentatives from nearly every step in the pesti-
cide distribution chain as well as container,
hardware, and application equipment manu-
facturers. Additional obstacles include:
•Selecting the area(s) to standardize, deter-
mining the standard, and developing crite-
ria to make the decisions are all difficult
tasks;
•Registrants have designed minibulk sys-
tems to optimize their performance. These
systems, or certain features of these sys-
tems, are used as marketing tools;
•Specific components of the various systems
are patented, and those holding the patent
may not want to share it;
•Antitrust laws may complicate the issues if
industry standardizes in the absence of regu-
lations;
155
-------
Chapter 9 - Refillable Containers: Use
•There is a potential for significant adverse
economic impact on those companies with
a substantial investment in equipment that
does not comply with the standard; and
•Standardization may decrease competition,
which could decrease the incentive to im-
prove existing systems.
Standardization of minibulks is currently
being discussed. A work group jointly spon-
sored by the Equipment Manufacturers Insti-
tute (EMI) and NACA, is addressing the issues
of container standardization.
EPA believes that standardization is a desir-
able goal, but the issues need to be defined more
clearly through discussions with all interested
parties. A clear definition of the standardiza-
tion of minibulks would include:
•The current problems;
•The different areas for potential standardi-
zation and how each option would address
the problems;
•The costs and benefits of any standardiza-
tion option;
•The potential implementation strategies (Le.,
voluntary industry standards vs. regula-
tions); and
•The potential impacts of "no action".
This discussion should take place as soon as
possible because decisions will only become
more difficult if smaller refillable containers
become common.
9.3 Small Volume Returnable Containers
Small volume returnable (SVR) containers
present several of the same issues as minibulks.
These similarities are highlighted in this sec-
tion. There are significant differences, how-
ever, due to the smaller size and the predomi-
nant material of construction. SVR containers
are generally considered to be sturdy because
they are relatively small and, in a majority of
cases, are currently constructed of steel. An-
other difference is that SVR containers are used
not only in the agricultural industry, but also in
the pest control business. Currently, several
companies package termiticide in SVR contain-
ers. (44) A SVR container used in the pest con-
trol business is shown in Figure 9-5.
9.3.1 Ownership
A major difference between minibulks and
SVR containers is that because of the current
refilling practices, SVR's are owned solely by
the registrant. Because these containers hold
less than 55 gallons, the small volume returnables
can be filled only by the registrant. The respon-
sibilities at each step in the distribution chain
are much different for SVR's than for minibulks.
The SVR is filled by the registrant, sealed, and
then passed down the distribution chain (dis-
tributor to dealer to end user). When the con-
tainer is empty, it proceeds back up the distribu-
tion chain. (45) Dealers have a much smaller
role in the use of SVR's than in the use of
minibulks.
9.3.2 Transportation
Transportation of SVR's is generally not as
problematic as transporting minibulks. Small
volume returnables are not usually transported
with any hardware other than the originally
attached valve. In most cases, SVR's have a dry
break coupling that connects to a withdrawal or
pumping device. This connection is usually
made at the application site, so the pumping
mechanisms are normally not attached to the
container during transportation. (46) Small vol-
ume returnables, because of their decreased
size, are more easily transported than minibulk
containers. Although it is not required, it would
be considered a good management practice to
secure SVR containers during transportation.
156
-------
Pesticide Containers - A Report to Congress
9.3.3 Container Construction/Potential Issues
Generally, small volume returnable contain-
ers pose fewer concerns than minibulks. Be-
cause SVR's are currently constructed of stain-
less steel, deterioration due to ultraviolet light
and container lifetime are not pressing issues.
In the future, however, small volume returnables
are predicted to be constructed of different ma-
terials, such as mild steel or HDPE.(47) Addi-
tionally, because of their decreased size, han-
dling is not a problem; one or two people can
carry them by hand.
9.3.3.2 Protection of Valving
As mentioned previously, the original valv-
ing is usually left on the container during trans-
portation. Most SVR's have a lip or rim around
the top of the container; however, depending on
the design of the container, the valving may
extend beyond the top of the lid. If this kind of
container fell on its top, the valving could be
damaged and the contents of the container could
leak.
9.3.3.2 Return of the Container
The return of SVR containers is more diffi-
cult than the return of minibulks because SVR's
must pass through the commercial distribution
chain back to the registrant. Additionally, the
return of SVR's is more expensive due to the
distance the container must travel from the user
to the registrant. (48) Consequently, registrants
may require substantial deposits on these con-
tainers. For example, one distributor was re-
quired to put a $100 deposit on each FMC U-
turn container.(49) This deposit may or may not
be passed down the distribution chain.
9.3.4 Associated Hardware
Most SVR's have a dry break coupler built
into the container. This coupler can be con-
Figure 9-5
A small volume returnable used for
termiticide
Dragnet
Termiticidf
Philo CrtJit: TMC.
nected to a pump or other withdrawal device to
dispense the product. Additionally, most SVR
container systems have a one-way valve, al-
though the location of this one-way valve var-
ies. For some containers, the one-way valve is
built into the container. (50) For other SVR's, the
one-way valve is in the equipment that attaches
to the coupling built into the container. (51) This
may be an important distinction, because a
substance could be introduced into the SVR by
an unauthorized person if the one-way valve is
not permanently part of the container. Realisti-
cally, however, this would be very difficult and
may not be a significant issue.
157
-------
Chapter 9 - Refillable Containers: Use
9.3.5 Standardization
9.3.5.1 Comparison to Minibulks
The issues involving standardization of small
volume returnables are very similar to the is-
sues for minibulks. The three potential areas for
standardization are the same except "the valve"
(for SVR's) replaces "the pump" (for minibulks).
In other words, the potential connections are:
(1) container/valve; (2) valve/hose; and
(3) hose/application tank.
Most SVR containers have the dry break
valve permanently attached to the container, ef-
fectively making the container/valve connec-
tion part of the container design. Therefore,
standardization of this connection is not an
issue in terms of dealers or users connecting
additional equipment. (52) Second, while stan-
dardizing the opening between the pump and
hose for minibulks is not a high priority, there is
a significant opportunity to standardize the
connection between the valve and the hose that
leads to the pump for SVR containers.
Standardizing the connection between the
hose and application tank is as viable an option
for SVR's as it is for minibulks. The relative ad-
vantages and disadvantages of standardization
for these two containers are also very similar.
One minor difference is that the use of SVR's in
the pesticide industry is not as widespread as
minibulks and, therefore, potentially easier to
standardize.
9.3.5.2 Standardization of Beer Kegs
An interesting case study in standardizing
refillable containers and connections is found in
the beer industry. This is particularly appropri-
ate because small volume returnable containers
utilize much of the same technology as beer
kegs.
Until the 1970's, each individual company
within the United States used different couplers
for beer kegs. In the early 1970's, the tap system
used today was adapted from England by a
relatively small brewery. In 1976, Miller, one of
the major breweries, decided to standardize all
of its kegs to couple with this tap. A short time
after this, Anheuser-Busch, another major brew-
ery, faced the decision of standardizing on this
tap or a proprietary coupling system. Anhe-
user-Busch chose to standardize on the same
tap as Miller in order to facilitate safety through
user familiarity. Because two of the major
companies standardized on the same coupling
system, the rest of the industry followed the
same path.(53) The large companies provided
the driving force in the choice for standardiza-
tion.
9.4 Bulk Containers
As discussed in section 4.3.1 and for the pur-
poses of this report, bulk containers are consid-
ered to be large, permanent storage tanks.
Because they are much larger and they are used
for the stationary storage of pesticide rather
than for transporting pesticide, bulk containers
have a set of issues much different from either
minibulks or small volume returnables. There-
fore, a comparison among these types of con-
tainers is not particularly enlightening. For the
sake of consistency, however, the discussion of
bulk containers will follow the same organiza-
tion — ownership, transportation, container con-
struction/potential issues, and associated hard-
ware.
9.4.1 Ownership
The ownership of bulk containers varies
among dealers. Most dealers own the bulk
containers themselves. Other dealers lease the
containers from the pesticide manufacturer. In
other cases, a dealer may own some of the bulk
158
-------
Pesticide Containers - A Report to Congress
containers and lease the rest. A dealer may also
purchase the bulk containers independently.
Alternatively, a registrant might give the dealer
a bulk container as part of an incentive program
to sell its pesticide in bulk. For example, some
pesticide manufacturers provide a bulk storage
tank for the dealer. The dealer then "earns" the
cost of the container by meeting a certain obliga-
tion for the volume of pesticide sold.(54)
9.4.2 Transportation
Transportation is not an issue for bulk con-
tainers, because they are permanent storage
tanks. Initially, the bulk container is trans-
ported empty to a dealer and installed with the
appropriate support and securing construction.
9.4.3 Container Construction/Potential Issues
9.4.3.1 Container Durability
Bulk containers generally are designed and
constructed to be strong and durable because of
the significant investment in the pesticide in the
tank as well as the high cost of cleanup if a tank
fails. Generally, registrants inspect tanks con-
taining their products regularly, even if they do
not own them. (55) In some cases, a registrant
may establish specifications for bulk containers
for particular pesticides. Steel bulk containers
are often marked with an expected life span,
which is limited by the impacts of the weather.(56)
Accordingly, similar procedures could be fol-
lowed for polyethylene storage tanks to account
for temperature extremes and exposure to ultra-
violet radiation.
9.4.3.2 Draining Ability
Cone-bottomed bulk containers drain more
easily than flat-bottomed tanks. This is advan-
tageous when dispensing the pesticide and clean-
ing the container. However, there is a trade-off
between draining ability and the distribution of
weight. Flat-bottomed bulk containers distrib-
ute the weight of the tank more evenly. In a
cone-bottomed bulk container, the weight is
concentrated in several discrete locations, caus-
ing stress points.
9.4.3.3 Effect of UV light
The effect of UV light over an extended pe-
riod of time may be a legitimate concern when
considering the integrity of plastic bulk con-
tainers. This could be a potentially significant
concern because bulk tanks are generally lo-
cated outside and, therefore, often in direct
sunlight. However, the construction of polyeth-
ylene bulk tanks is generally very strong; there-
fore, it is unlikely that exposure to heat, cold,
and ultraviolet radiation will have a substantial
impact on the lifetime of the tank.
9.4.4 Associated Hardware
Bulk containers have pumps, meters, valves,
and hoses used to transfer and measure the
pesticide. Because bulk containers are station-
ary, the associated hardware can also be se-
cured. Figure 9-6 is a picture of a pump and
hoses for a bulk container that are permanently
secured to the secondary containment struc-
ture.
There are several mechanisms to recirculate
pesticide in a bulk tank. Pesticide may be
pumped from the bottom connection into an
inlet approximately halfway up the bulk con-
tainer. Another common recirculation mecha-
nism is to inject air into the bottom of the con-
tainer.^?)
Some dealers have experienced problems
with leakage from the fittings on bulk contain-
ers. This has been found mostly with corrosive
pesticides. One solution to this problem is to
159
-------
Chapters - Refillable Containers: Use
weld all connections instead of relying on the
threaded fittings. This welding, however, must
be done by an expert welder to achieve an
airtight seal. Additionally, because of safety
concerns, the welding should be done before
the tank is filled for the first time. Another
significant point is that welding the connections
is appropriate only in climates without tem-
perature extremes. There is no "give" in welded
plumbing, which may lead to stress cracks in
cold weather.
9.5 Dry Ref illable Containers
9.5.1 Refillable Bags
Ref illable bags are currently used mainly by
dealers, but also by commercial applicators and
large growers. There may be straps on the con-
tainer to lift it. Alternatively, the refillable bags
may be secured to a pallet for transportation.
Because these containers are used mainly at
dealer sites, the equipment necessary to move
them is usually available. When the refillable
bag is empty, the container is folded, put in a
cardboard box, and returned to the registrant to
be refilled.(58)
9.5.2 Rigid Refillable Containers
American Cyanamid maintains ownership
of the rigid refillable containers used to package
Counter, a granular product. A deposit is charged
on these containers. The containers are returned
up the commercial distribution chain to an Ameri-
can Cyanamid formulating plant where they
are refilled. (59)
I i^ure 9-f>
The pump and hoses for a bulk container
Photo Credit: U.S. EPA.
160
-------
Pesticide Containers - A Report to Congress
Endnotes
1. Qba-Geigy/Research Triangle Institute, meet-
ing summary, Research Triangle Institute, July
28,1989.
2. Farrell, R., Wilbur-Ellis Company, letter to
W. Holtzman, U.S. EPA, Office of Pesticide
Programs, October 26,1990.
3. Qba-Geigy/Research Triangle Institute, meet-
ing summary, Research Triangle Institute, July
28,1989.
4. "Minibulk - Small Tanks, Big Benefits," Cus-
tom Applicator, (March 1990): pp.86-88.
5. Research Triangle Institute, Trip Report to
Windsor, North Carolina, June 8,1989.
6. Bradley, D., American Cyanamid, personal
communication with U.S. EPA, Office of Pes-
ticide Programs, November 19,1990.
7. Farrell, R., Wilbur-Ellis Company, letter to
W. Holtzman, U.S. EPA, Office of Pesticide
Programs, October 26,1990.
8. U.S. EPA, Trip Report to Missouri, May 25,
1990, U.S. EPA, Office of Pesticide ftograms.
9. "Minibulk - Small Tanks, Big Benefits/'Cwsfom
Applicator, (March 1990): pp.86-88.
10. PolyProcessing Company/U.S. EPA, meet-
ing summary, U.S. EPA, Office of Pesticide
Programs, November 13,1990.
11. Justmann, T., American Cyanamid, personal
communication with U.S. EPA, Office of Pes-
ticide Programs, September 24,1990.
12. American Cyanamid/Brayton Chemicals/US.
EPA, meeting summary, U.S. EPA, Office of
Pesticide Programs, February 28,1990.
13.Myrick, C, National AgriChemical Retailers
Association, letter to the NACA Container
Committee, Januarty 11,1990.
This estimate is based on current minibulk
use. EPA estimates that 29.4 million gallons
of pesticide product is currently being handled
in minibulks. It was assumed that 20 percent
of this amount would be handled in mini-
bulks if "small" quantities of product were al-
lowed to be repackaged in "large" minibulks.
Therefore, the equivalent of 5.88 million gal-
lons of nonrefillable containers, or approximat-
ely 2.3 million 2.5-gallon jugs, would be
eliminated.
14. U.S. EPA, Office of Compliance Monitoring,
"Amendment to the July 11,1977 Enforce-
ment Policy Applicable to Bulk Shipment of
Pesticides," March 4,1991.
15. Raherty, P., U.S. EPA, Office of Compliance
Monitoring, memorandum to L. Alderman,
U.S. EPA, Region VII, May 10,1990.
16. Frieberg, D., et al., Proposal for an EPA Pilot
Project on the "56 Gallon" Rule, April 30,
1990.
17. "Minibulk - Small Tanks, Big Benefits."Cz
-------
Chapters Refutable Containers: Use
28. Rigid Intermediate Bulk Container Associa-
tion/U.S. EPA, meeting summary, U.S. EPA,
Office of Pesticide Programs, May 18,1990.
29. Research Triangle Institute, Trip Report to
Aulander, North Carolina, June 7,1989.
30. Lindsay, D., Formulogics, personal communi
cation with U.S. EPA, Office of Pesticide Pro-
grams, July 23,1990.
31. Science Products/U.S. EPA, meeting summary,
U.S. EPA, Office of Pesticide Programs, Sep-
tember 25,1990.
32. Victaulic Company of America/U.S. EPA,
meeting summary, U.S. EPA, Office of Pesti-
cide Programs, March 30,1990.
33. Research Triangle Institute, Trip Report to
Windsor, North Carolina, June 8,1989.
34. Farrell, R., Wilbur-Ellis Company, letter to W.
Holtzman, U.S. EPA, Office of Pesticide Pro-
grams, October 26,1990.
35. Science Products/U5. EPA, meeting summary,
U.S. EPA, Office of Pesticide Programs, Sep-
tember 25,1990.
36. Ibid.
37. Ciba-Geigy, Study of Exposure Using Farm
Pak System, 1988.
38. Science Products/US. EPA, meeting summary,
U.S. EPA, Office of Pesticide Programs, Sep-
tember 25,1990.
39. Research Triangle Institute, Trip Report to
Tennessee, Arkansas, Mississippi, July 6-7,
1989.
40. Aeroquip Corporation/U.5. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Programs,
July 12,1990.
41. Ibid.
42. Research Triangle Institute, Trip Report to
Ahoskie, North Carolina, June 7,1989.
43. Barrows, P., FMC, personal communication
with U.S. EPA, Office of Pesticide Programs,
September 13,1990.
44. Megargle, W., FMC, personal communication
with Research Triangle Institute, June 9,1989.
45. Farrell, R., Wilbur-Ellis Company, letter to
W. Holtzman, U.S. EPA, Office of Pesticide
Programs, October 26,1990.
46. Ibid.
47. Donaldson, G., Wilbur-Ellis Company, letter
to J. Jensen, U.S. EPA, Office of Pesticide Pro-
grams, October 29,1990.
48. Research Triangle Institute, Trip Report to
Portland and Umatilla, Oregon, July 11-14,
1989.
49. Barrows, P., FMC, personal communication
with U.S. EPA, Office of Pesticide Programs,
September 13,1990.
50. Micromatic/DowElanco/U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide Pro-
grams, September 25,1990.
51. Farrell, R., Wilbur-Ellis Company, letter to
W. Holtzman, U.S. EPA, Office of Pesticide
Programs, October 26,1990.
52. Micromatic/DowElanco/U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide Pro-
grams, September 25,1990.
53. Farrell, R., Wilbur-Ellis Company, letter to
W. Holtzman, U.S. EPA, Office of Pesticide
Programs, October 26,1990.
54. Ibid.
55. Ibid.
56. Ibid.
57. Bartenhagen, C., Monsanto, personal com-
58. munication with U.S. EPA, Office of Pesti-
cide Programs, March 30,1990.
59. Bradley, D., American Cyanamid, personal
communication with U.S. EPA, Office of
Pesticide Programs, November 19,1990.
162
-------
Pesticide Containers - A Report to Congress
Chapter 10
Refillable Containers:
Residue Removal
10.1 Introduction
Residue removal from refillable containers
can be split into two distinct categories: residue
removal before refilling the container and resi-
due removal before disposal. Each situation
presents different concerns and reasons for re-
moving the residue, although the same cleaning
procedures are used for each process. Because
of the potential for cross-contamination, most
discussion in the industry has focused on resi-
due removal before refilling. Additionally, due
to the nature of these containers, refilling occurs
more often in the lifetime of the container than
disposal. Accordingly, this chapter focuses on
residue removal before refilling.
There are several reasons for performing a
residue removal procedure before refilling a
container. The main reason is to prevent cross-
contamination if a different pesticide is to be in-
troduced into the container. Additionally, de-
pending on the formulation and the manage-
ment of the container, crystals or other dried
material may need to be removed, even if the
same pesticide is intended to be repackaged
into the container. The container should also be
cleaned thoroughly if the repackager does not
know the identity of the previous contents. The
refiller has no assurance of the integrity or the
identity of material previously held in the con-
tainer if the container does not have tamper-evi-
dent devices or if the tamper-evident devices
have been violated.
Residue removal prior to disposal is done to
reduce worker exposure during disposal and to
minimize the environmental impact of disposal.
Before the actual residue removal proce-
dures are described, several ideas crucial to cur-
rent residue removal practices must be under-
stood. These concepts are cross-contamination
and the definition of dedicated containers and/
or allowable refilling practices. The discussion
on cross-contamination and dedicated contain-
ers is followed by a description of current resi-
due removal practices before refilling and the
options available for handling the resulting rin-
sate.
10.2 Cross-Contamination
Cross-contamination is a relatively simple
concept to understand qualitatively. It can be
defined as an impurity in the pesticide formula-
163
-------
Chapter 10 - Refillable Containers: Residue Removal
tion resulting from some external source. De-
fining cross-contamination quantitatively is more
difficult and generally must be done on a case-
by-case basis.
The regulations in 40 CFR Part 158, Data Re-
quirements for Registration, define the limits
for impurities, including those resulting from
cross-contamination from other products in Sub-
part C, Product Chemistry Data Requirements.
Any impurity must be listed as part of a prod-
uct's registration or the product may be consid-
ered adulterated.
The potential for cross-contamination is not
limited solely to ref illable containers. Contami-
nation of pesticide formulations may be caused
by a variety of occurrences including produc-
tion and formulation mix-ups, failure to clean
production equipment, and the reuse of inade-
quately cleaned containers.
Proper rinsing and minibulk container de-
signs that provide adequate draining are essen-
tial to preventing cross-contamination of refil-
lable containers.
As discussed in section 9.2.2, the 1990 Iowa
pilot project on the "56-gallon policy," included
sampling some of the refilled minibulks to test
for cross-contamination.
Twelve minibulk containers were tested and
no cross-contamination was detected in 6
samples. Cross-contamination could not be de-
tected in two samples, because the second pes-
ticide product contained the same active ingre-
dient as the previous product. Of the remaining
four samples, cross-contamination with the prod-
uct previously contained in the minibulk was
detected in 2 samples. Additionally, the detec-
tion of an active ingredient other than that of the
previously held product occurred in 2 samples
(both were from the same dealer).(1)
In addition to complying with the product
chemistry data requirements, a concern of re-
packagers is crop damage due to cross-contami-
nation. The potential financial impact of reim-
bursing a grower for crops that have been dam-
aged because of improperly managed ref illable
containers makes residue removal important to
repackagers.
10.3 Dedicated Containers/Allowable Refill-
ing Practices
The term "dedicated container" can be used
to describe two different situations. On one
hand, a strict, limited definition of a dedicated
container is a refillable container used for a
single pesticide product. On the other hand, a
"dedicated container" may be described by the
conditions that define when the container may
be refilled. A truly dedicated minibulk con-
tainer, as described by the first definition, would
put a considerable burden on the repackage!
because of the large number of minibulks that
would need to be purchased, handled, or stored.
In practice, minibulk containers are often rinsed
and then refilled with a different pesticide, in
agreement with the second definition. The fol-
lowing section discusses the issues involving
dedicated containers and allowable refilling prac-
tices for the different types of refillable contain-
ers.
10.3.1 Minibulk Containers
Most of the debate about dedicated contain-
ers/allowable refilling practices focuses on mini-
bulk containers and involves discussion by sev-
eral state groups, EPA, dealers, and registrants.
In general, the state groups have attempted to
limit the allowable refilling practices more se-
verely than the other parties.
10.3.1.1 States
Two state groups, the Association of Ameri-
can Pesticide Control Officials (AAPCO) and
the State-FIFRA Issues Research and Evaluation
164
-------
Pesticide Containers - A Report to Congress
Group (SFIREG), an advisory committee to EPA
representing the states, have been involved with
defining dedicated containers. In its draft bulk
pesticide rules (1989), AAPCO specifically de-
fines a "dedicated pesticide container" as "a
pesticide container effectively designed and con-
structed to hold a specific pesticide and to be
reused, repackaged, or refilled." This is consis-
tent with the narrow definition of a dedicated
container.
Discussions between EPA officials and rep-
resentatives from the states in Region V reveal a
similar concern. A substantial amount of re-
packaging is done in Region V, which includes
Ohio, Indiana, Illinois, Minnesota, Wisconsin,
and Michigan. At a meeting in December 1989,
officials from all of these states agreed that pes-
ticides should be refilled only into containers
dedicated to a specific product unless the regis-
trant can demonstrate to EPA that the contain-
ers can be adequately cleaned. (2)
More recently, SFIREG proposed to allow
refilling in a manner meeting the second defini-
tion, Le., if the container:
" -Is ready for reuse and in a good state of
repair, provided the container remains dedi-
cated to the same registered material; or
•Is returned sealed, well drained, relabeled
and refilled with a product containing the
same active ingredient in a compatible for-
mulation; or
•Is thoroughly cleaned according to a writ-
ten procedure provided to the filling estab-
lishment by the registrant of the pesticide
intended for introduction into the refillable
container." (3)
10.3.1.2 EPA
At an October 18,1989, meeting with EPA,
the National AgriChemical Retailers Associa-
tion (NARA), and Monsanto, the following defi-
nition for a "dedicated container" was sug-
gested by EPA staff:
A "dedicated container" is a container that:
•Will be refilled with the product having the
identical registration number as the previ-
ous contents; or
•Will be refilled with a product of the same
chemical class, e.g., herbicide or insecti-
cide, as the previous contents and provided
that the container is drained well and rela-
beled; or
•Will be thoroughly cleaned according to a
procedure provided by the registrant of the
pesticide to be introduced into the con-
tainer and the container is relabeled.(4)
In reality, this set of circumstances, as well as
SFEREG's proposal, defines the conditions when
refilling is allowed. The key to understanding
these two proposals is that refilling would be
allowed if any one of the conditions were met.
The first two conditions in each proposal are
designed to exempt refillers from cleaning the
containers; they are not intended to require the
use of truly dedicated containers.
10.3.1.3 National AgriChemical Retailers Associa-
tion
The National AgriChemical Retailers Asso-
ciation has also proposed to define when a
minibulk can be refilled. NARA proposed that
"minibulk containers must be thoroughly rinsed
following use if a different pesticide is to be
filled into the container for its next use." (5) The
intent of this is essentially the same as the EPA
and SFIREG proposals. Under the NARA pro-
posal, however, introducing a similar pesticide
into the container would require rinsing.
165
-------
Chapter 10 - Refillable Containers: Residue Removal
10.3.1.4 Registrants
Policies on allowable refilling practices vary
among registrants. Because of the accountabil-
ity requirement for the integrity of the pesticide,
some registrants control the circumstances for
rinsing through their agreements with dealers.
Individual companies choose to deal with this
in different ways. Ciba-Geigy dedicates its
minibulk (the Farm-Pak) to specific products
and distinguishes them by color. A Farm-Pak
for Dual, for example, is a different color than a
Bicep Farm-Pak. In addition, the appropriate
product name is embossed on container. (6)
Monsanto, on the other hand, allows the dealer
more flexibility. Monsanto leases its minibulk
containers, called Shuttles, to dealers and al-
lows the containers to be refilled with any
Monsanto product, as long as the retailers re-
package according to Monsanto's bulk repack-
aging agreement. (7) In actual practice, how-
ever, Farm-Paks are sometimes refilled with
pesticides other than those originally placed in
the container, and Shuttles are often refilled
with pesticides manufactured by companies other
than Monsanto. (8) Additionally, a registrant
may choose to dedicate a container for product-
specific reasons. For example, Monsanto dedi-
cates minibulks for Round-up because the pes-
ticide is used in a different geographic market
segment than other Monsanto pesticides. (9)
10.3.2 Small Volume Returnable Containers
Generally, small volume returnable con-
tainers are dedicated to one pesticide. The reg-
istrant, however, may choose to refill the SVR
with another product. (10) One important dif-
ference is that the registrant can carefully con-
trol the residue removal procedure because
currently only the registrant can refill small
volume returnable containers.
10.3.3 Bulk Containers
Bulk containers may be dedicated to one
product or they may be refilled with different
pesticides throughout the year, depending on
the product, the area of the country, and the use
pattern of the pesticide. For example, a bulk
tank might be dedicated to one product if a
large demand exists for that pesticide. This
could be the case if the pesticide can be applied
to a wide variety of crops in the region, if it is
applied often, or if there are several growing
seasons per annum. On the other hand, the
contents of the bulk container might change
depending on the time of the planting (Le., pre-
emergence or post-emergence) and the storage
capacity of the refiller.(ll)
10.3.4 Dry Refillable Containers
Dry refillable containers generally are dedi-
cated to one product. Super Sacks are refilled
with the same pesticide. (12) American Cyan-
amid's 40-pound rigid container is dedicated to
one pesticide, Counter.
10.4 Residue Removal Procedures
10.4.1 Minibulk Containers
Minibulk containers that are owned by the
registrant or retailer usually are rinsed only by
the refillers for several reasons. First, the con-
tainers are relatively large, bulky, and difficult
to handle. A dealer is more likely than an end
user to have the equipment necessary for ade-
quate cleaning. Secondly, and more impor-
tantly, if an end user rinses the container, the
minibulk must have been "opened" somehow.
In other words, either a tamper-evident device
was violated or there was no tamper-evident
device. If the minibulk is opened, the dealer has
no assurance that the container has not been
contaminated. Due to cross-contamination
166
-------
Pesticide Containers - A Report to Congress
concerns, the dealer might have to rinse the
container anyway.
On the other hand, there are a significant
number of minibulks owned by end users. These
containers are rinsed, stored, and reused by the
end user. (13) In this situation, the dealer has no
control over the previous contents of the con-
tainer. Assurance of cleanliness sufficient to
allow refilling could be provided by requiring
the repackager to clean all containers that have
been opened and all containers with a violated
tamper-evident device.
In general, however, end users do not rinse
the containers. In fact, one of the biggest advan-
tages of using minibulks is that the growers do
not have to rinse the containers. This exemption
from rinsing reduces worker exposure and saves
time in the field. (14)
In mid-season, minibulk containers usually
are not rinsed before being refilled with the
same pesticide. (15) Minibulks are rinsed if a
different product will be introduced, and they
are returned for rinsing at the end of the grow-
ing season.
Pressure rinsing is the residue removal tech-
nique for minibulk containers recommended
by NARA. It has been estimated that it takes 5
to 15 minutes to clean a minibulk thoroughly. (16)
Monsanto prepared a video for dealers that
describes the company's recommended annual
maintenance and storage program. The pro-
gram includes three procedures: (1) cleaning
and inspection of the tank and pumping mecha-
nism; (2) inspection and repair of components;
and (3) proper storage. The cleaning procedure
for the interior of the container involves the
following steps:
•Place the minibulk on a rinse pad;
•Spray about 10 gallons of clean water into
the tank;
•Recirculate the water for 1 to 2 minutes;
•Pump the water into the grate or other
rinsate collection system;
•Refill the container with about 5 gallons of
water; and
•Repeat the rinsing process until the rinsate
is clear. Usually two rinses are sufficient.(17)
10.4.2 Small Volume Returnable Containers
When a registrant or the registrant's agent
receives a small volume returnable, the con-
tainer is carefully inspected. The manufac-
turer's seal is inspected to determine if it is still
intact, and the container serial number is com-
pared to the shipping records to determine if it
has been returned through the correct chan-
nels. (18) Containers that pass the inspection
usually are not rinsed if they are being refilled
with the same pesticide.
Depending on the design of the container,
SVR's can be rinsed in several ways. Some SVR
containers must be cleaned individually by
pressure rinsing. DowElanco's SVR, the Trav-
eler, on the other hand, is designed to be rinsed
and filled on an automatic line.(19)
10.4.3 Bulk Containers
When a bulk container is intended to be
refilled with a different pesticide than it previ-
ously contained, the container is pressure rinsed
by the dealer. The dealer may use a pressure
nozzle and rinse the container until the rinsate is
dear. One dealer estimates that 65 to 150 gal-
lons of water are used to rinse a 6,200-gallon
tank.(20)
167
-------
Chapter 10 - Refillable Containers: Residue Removal
10.4.4 Dry Refillable Containers
Because most dry refillable containers are of-
ten dedicated to one product, they usually are
not cleaned before refilling. Monsanto, for ex-
ample, does not clean its Super Sacks before
refilling and has not had cross-contamination
problems. (21) American Cyanamid inspects its
rigid dry refillable containers upon receipt. If
the tamper-evident seal is intact, only the out-
side of the container is cleaned. However, if the
tamper-evident seal is broken, the container is
inspected more thoroughly and both the inte-
rior and exterior of the container are cleaned. (22)
10.5 Management of Rinsate
The management of rinsate resulting from
cleaning refillable containers is an important
issue for dealers. Because dealers handle large
quantities of pesticides, the volume of rinsate to
be managed is significantly larger than that
generated by an individual user. Unlike nonre-
fillable containers which are rinsed in the field
at the time of application, refillable containers
are rinsed at the dealer's facility. Therefore, the
rinsate cannot easily be added to the application
mixture, as with nonrefillable containers. Ad-
ditionally, unless a dealer is also a custom appli-
cator, the viable management options are more
limited. This section discusses the management
of container rinsates at the dealer level. While
the same options exist for distributors and reg-
istrants, they are likely to have fewer options
than custom applicators.
10.5.1 Use as a Diluent
One potential option for managing the rin-
sate is to use it as a diluent in a later application.
However, several restrictions apply to this prac-
tice. The restrictions include:
•The application must be made to a site
specified on the label of the pesticide in the
rinsate; and
•The application must be made in accor-
dance with the label of the pesticide in the
rinsate including the maximum allowable
rate, the frequency, and the timing of the
application.
These constraints present a logistical prob-
lem for the dealer. First, the rinsate must be col-
lected and stored. This must be done for any of
the available rinsate management options.
However, if the rinsate is going to be used as a
diluent, the dealer may need to separate the
rinsates from different containers to facilitate
application in accordance with the label. In
other words, several storage tanks may be nec-
essary, as well as a drainage, pumping, or pip-
ing system that allows distribution to the differ-
ent storage vessels. Depending on the location
of the dealer and the variety of crops grown in
that area, this may not present a major problem.
For example, one dealer in Missouri has two
separate collection systems; one is used to col-
lect the rinsate from pesticides used on corn and
the other for soybean chemical rinsates.(23)
Separate collection systems or even separate
storage tanks may not be feasible in regions
where a wide variety of crops are grown. The
logistics of designing, installing, and managing
such a system are complex and the cost is high.
10.5.2 Apply to Labeled Site
Another potential option for the manage-
ment of rinsate is to apply the material directly
to a site specified on the label of the pesticide in
the rinsate. As discussed above, the application
must be made in accordance with the label of
the pesticide in the rinsate, including the allow-
able rate, frequency, and timing of the applica-
168
-------
Pesticide Containers - A Report to Congress
tion. Additionally, the same logistical con-
straints exist in terms of collecting and separat-
ing the rinsate. Depending on the pesticide and
when the rinsate is generated, the dealer may
not have access to an appropriate application
site.
10.5.3 Rinsate Treatment System
Another option for managing rinsate is to
utilize a treatment system. A treatment system
can be designed individually or a commercially
available system can be purchased. One ex-
ample of such a system, which is marketed by
Wilbur-Ellis, involves several stages including
filtration, oil removal, ozonation, and activated
carbon adsorption. In most cases, a rinsate
treatment system is part of a recycling and reuse
system. In other words, the rinsate is treated to
remove the pesticide, stored, and reused as
rinse water. (24)
10.5.4 Other Disposal Options
If the rinsate is considered a waste under ap-
plicable law, the rinsate must be managed in ac-
cordance with any applicable federal, state, and
local regulations, including solid or hazardous
waste requirements. Water quality regulations
also may be applicable. The appropriate dis-
posal method depends on the contents of the
rinsate and the requirements specific to the
169
-------
Chapter 10 - Refillable Containers: Residue Removal
Endnotes
1. Lohaf er, M., Iowa Department of Agriculture
and Land Stewardship, letter to L. Alderman,
U.S. EPA, Region VII, December 7,1990.
2. Ward, J., U.S. EPA, Region V, memorandum
to P. Flaherty, U.S. EPA, Office of Compliance
Monitoring, December 15,1989.
3. Wells, J., California Department of Food and
Agriculture, letter to P. Flaherty, U.S. EPA,
Office of Compliance Monitoring, January 17,
1990.
4. National AgriChemical Retailers Asso-
ciation/Monsanto/U.S. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Programs,
October 18,1989.
5. Myrick, C, National AgriChemical Retailers
Association, memorandum to U.S. EPA, Oc-
tober 18,1989.
6. Snyder Industries/U.S. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Programs,
October 1,1990.
7. Yates-Parker, N., Monsanto, letter to C. My-
rick, National AgriChemical Retailers Asso-
ciation, November 6,1989.
8. Farrell, R., Wilbur-Ellis Company, letter to
W. Holtzman, U.S. EPA, Office of Pesticide
Programs, October 26,1990.
9. Allison, S., Monsanto, memorandum to T.
Gilding, National AgriChemicals Association,
November 26,1990.
10. Megargle, W., FMC, personal communica-
tion with Research Triangle Institute, June 9,
1989.
11. Hester, J., Wilbur-Ellis Company, personal
communication with U.S. EPA Office of Pes-
ticide Programs, May 21,1990.
12. Bartenhagen, C., Monsanto, personal com-
munication with U.S. EPA, Office of Pesticide
Programs, March 30,1990.
13. Farrell, R., Wilbur-Ellis Company, letter to
W. Holtzman, U.S. EPA, Office of Pesticide
Programs, October 26,1990.
14. Mills, T., California Agricultual Aviation Asso-
ciation, "Reusable Containers are 'One Way
Ouf", On the Deck, November 1987: pp. 12-15
15. Research Triangle Institute, Trip Report
to Windsor, North Carolina, June 8,1989.
16. U.S. EPA, Trip Report to Missouri, May 25,
1990, U.S. EPA, Office of Pesticide Programs.
17. Monsanto, "Shuttle Annual Maintenance and
Storage" video, 1988.
18. Research Triangle Institute, Trip Report to
Tennessee, Arkansas, Mississippi, July 6-7,1989.
19. Micromatic/DowElanco/U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide Pro-
grams, September 25,1990.
20. Research Triangle Institute, Trip Report to
Corcoran, California, July 17,1989.
21. Bartenhagen, C., Monsanto Agricultural Com-
pany, personal communication with U.S. EPA,
Office of Pesticide Programs, March 30,1990.
22. Bradley, D., American Cyanamid Company,
personal communication with U.S. EPA, Of-
fice of Pesticide Programs, November 19,1990.
23. U.S. EPA, Trip Report to Missouri, May 25,
1990, U.S. EPA, Office of Pesticide Programs.
24. U.S. EPA, Trip Report to California, Oregon,
Washington, September 16-22,1990, U.S. EPA,
Office of Pesticide Programs, October 1990.
170
-------
Pesticide Containers A Report to Congress
Chapter 11
Refillable Containers:
Disposal
11.1 Introduction
Due to the nature of ref illable containers and
to the fact that they have been introduced fairly
recently, their disposal has been a neglected or
overlooked issue. Since their introduction in
the late 1970's, most of the attention has focused
on establishing an efficient distribution net-
work, minirnizing the potential for cross-con-
tamination, and developing effective contain-
ers and equipment. At some point, however, a
refillable container must be disposed. Because
this occurs at the end of a relatively long life-
time, disposal of refillable containers is not as
prominent as some of the other issues. Cur-
rently, little information exists on the disposal
of refillable containers, and many disposal op-
tions are just now being developed. This chap-
ter summarizes the current situation, although
the options available today probably will change
as more attention is focused upon refillable con-
tainer disposal.
For several reasons, this chapter will focus
on the disposal of minibulk containers. Bulk
containers are stationary storage tanks and rarely
require disposal. Also, because minibulks have
been available for a longer period of time, there
are more minibulk containers in service than
any other type of portable returnable container.
Currently, many minibulk containers are near
the end of their lifespan, when disposal options
become critical. Disposal of small volume re-
turnable containers has not yet become an issue,
partly because of the relatively recent develop-
ment of SVR's. Additionally, these containers
are constructed of stainless steel and therefore
have a longer anticipated lifetime than most
minibulk containers. Disposal of dry refillable
containers has not yet been an issue. Currently,
registrants dispose of the flexible refillable
containers. (1) Rigid dry refillable containers
were introduced in 1990. Consequently, not
enough time has elapsed for disposal to become
an issue. Plans for the disposal of these contain-
ers are under development. An important point
is that the disposal of these other portable refil-
lable containers will be necessary at some point
in the future, although the development of con-
venient and viable disposal options for all refil-
lable containers should begin now.
Disposal of minibulk containers is depend-
ent on two interrelated issues — removing the
containers from service and the ownership of
the containers. The first step in disposal ~ re-
171
-------
Chapter 11 - Refilhble Containers: Disposal
moving damaged, weakened, or otherwise struc-
turally compromised minibulk containers from
service, can easily be done by dealers and dis-
tributors during their regular inspection and
maintenance program. Currently, some regis-
trants are establishing collection programs to
remove their old minibulks from service. In
general, removing the minibulk from service is
easiest when the container is owned by a dealer,
distributor, or registrant. Also, some minibulk
manufacturers are now addressing the disposal
of these containers and have expressed interest
in cradle-to-grave management of minibulks. (2)
If an end user owns a minibulk, the dealer
and registrant do not have as much leverage to
remove the container from service. Because of
the investment in the container or the potential
loss of convenience, an end user may demand
that a container be refilled even if it is structur-
ally unsound. As discussed in Chapter 9, this
could put the dealer in an awkward and com-
promising situation. This problem could be
miriirriized by establishing standards for the
condition of the container and/ or requiring the
removal of the minibulk from service after a
specified period of time.
Another issue with the ownership of the
containers is the available disposal options. End
users are less likely to have access to the appro-
priate equipment and facilities than dealers,
distributors, and registrants. Minibulks are
generally more difficult to dispose than small
nonrefillable containers such as 2.5-gallon plas-
tic jugs.
The disposal options for minibulk contain-
ers are similar to those for nonrefillables, al-
though the relative use of each method varies
between refillables and nonrefillables. For ex-
ample, on-site burial is not a viable disposal
method for minibulks, because the large size
makes this optionprohibitive. A rapidly devel-
oping disposal method for registrant-controlled
minibulks is burning in a permitted incinerator
with the recovery of energy. End users gener-
ally do not have access to these permitted incin-
erators, so this option is limited primarily to
registrants. Currently, most minibulk contain-
ers are broken into small pieces and landfilled,
burned, or stored in anticipation of better dis-
posal methods.(3) This chapter briefly discusses
the difficulties and restrictions involved with
landfilling, open burning, stockpiling, burning
for energy recovery, recycling, and collection
programs.
11.2 Landfilling
Landfilling is one option available for the
disposal of minibulks. The restrictions and dif-
ficulties with landfilling, such as liability con-
cerns, expense, and refusal of landfill operators
to accept pesticide containers, are problems com-
mon to both refillable and nonrefillable contain-
ers. An additional problem with minibulks is
the large volume of space needed to landfill the
containers. To reduce the volume, the container
is cut into smaller pieces with equipment such
as a chain saw. Shredding the containers after
cutting them into pieces could substantially re-
duce the volume of plastic minibulks, although
a durable, tough shredder would be necessary.
Improperly cleaned containers can lead to po-
tential worker exposure when the containers
are cut and shredded.
11.3 Open Burning
Open burning is another method used to
dispose of minibulk containers, which several
dealers have reported. (4) However, as dis-
cussed in Chapter 5, open burning in general is
prohibited by the RCRA Subtitle D regulations.
Also, the state regulations in place which allow
limited burning of pesticide containers do not
include minibulks. From a practical stand-
172
-------
Pesticide Containers - A Report to Congress
point, it is difficult to burn plastic minibulk con-
tainers unless a strong fire has been established.
This disposal method frequently does not pro-
vide complete combustion, which may cause
problems with emissions, ash, and container
remnants.
11.4 Stockpiling
Many minibulk containers are currently "dis-
posed" by stockpiling. These containers are
being stored until convenient, viable, and eco-
nomically feasible disposal options become avail-
able. Minibulks awaiting disposal are usually
stored outside in an unprotected location.
11.5 Energy Recovery
Burning for energy recovery is a rapidly de-
veloping minibulk disposal method practiced
by registrants. For example, several registrants
reported collecting old minibulk containers,
cutting them into several pieces and then incin-
erating them. (5) In early 1991, Monsanto will
burn collected minibulks with the recovery of
energy at a permitted cement kiln facility. (6)
This process involves combustion at a high tem-
perature and it achieves an efficient degree of
destruction of both the plastic resin and pesti-
cide retained in the resin. Under good operat-
ing conditions, the primary combustion prod-
ucts of polyethylene are carbon dioxide and
water. In general, relatively small amounts of
ash and corrosive or toxic gases are produced. (7)
However, little research has been done on the
constituents that could form from incomplete
combustion of either the minibulk or the pesti-
cide residue. One disadvantage to incineration
is the scarcity of available furnaces or boilers in
some parts of the country. In some instances,
the registrant operates a private incinerator.
11.6 Recycling
In addition to the topics discussed in Chap-
ter 7 for recycling nonrefillable containers, there
are several issues involved with recycling plas-
tic minibulks. These issues include the amount
of pesticide remaining in the resin and the con-
struction material of the minibulk.
As discussed in Chapter 7, the amount of
pesticide that absorbs into the walls of the con-
tainer is a crucial issue. The amount of pesticide
that remains in the plastic may be a greater con-
cern for minibulks than for nonrefillable con-
tainers because minibulks typically are not fluori-
nated. Fluorination slows down the migration
of solvents into the plastic, but treatment of
minibulks is difficult because of the size of the
containers. (8) Many companies are doing ab-
sorption testing, although the results generally
are not published.(9)
Another important factor in recycling mini-
bulk containers is the material of construction.
Steel minibulks can be recycled in the same way
as the smaller steel nonrefillable containers.
Plastic minibulks, however, must be handled
differently depending on the type of plastic.
Minibulks constructed of linear HDPE can be
ground into small flakes that can be melted and
extruded into pellets or remolded for another
use.(10) Cross-linked polyethylene, on the other
hand, cannot be melted and remolded because
of the characteristics of the material. Once the
molecular structures are formed, cross-linked
plastics cannot be reshaped.(ll) However, re-
search has shown that cross-linked polyethyl-
ene can be recycled by other means. Additional
testing is being done on this topic.(12)
Although several registrants, including ICI
and BASF, are looking into minibulk recycling,
it is not currently a widespread option for the
disposal of minibulk containers. (13) Additional
study is needed on the amount of pesticide ab-
sorbed into the resin and on demonstrating the
feasibility of recycling minibulk containers con-
structed of different kinds of plastic. Ciba-
173
-------
Chapter 11- Refillable Containers: Disposal
Geigy has recycled minibulks by grinding the
containers and using the plastic to make addi-
tional products.(14)
11.7 Collection Programs
Several registrants are developing programs
to collect their old minibulk containers with the
intention of burning them for energy recovery
or recycling them.
Early in 1990, Ciba-Geigy organized a col-
lection program for the minibulks that the com-
pany had introduced in 1987 (the pre-Farm-Pak
minibulks). Ciba-Geigy offered to collect the
old minibulks and replace them with Farm-
Paks free of charge. About half of the old con-
tainers have been collected. The containers
were granulated and recycled into other plastic
products. As an outgrowth of the 1990 Iowa "56
gallon policy" pilot program discussed in sec-
tion 9.2.2, the Iowa Department of Agriculture
and Land Stewardship, the Iowa Fertilizer and
Chemical Association, and Monsanto are plan-
ning a project to dispose of old minibulks. Mon-
santo is collecting its old containers by offering
to pick up unusable Shuttles from the deal-
ers. (15) As discussed in section 11.5, these con-
tainers will be burned and the energy will be re-
covered.
174
-------
Pesticide Containers - A Report to Congress
Endnotes
1.
2.
3.
4.
5.
Bartenhagen, C., Monsanto, personal com-
munication with U.S. EPA,Office of Pesticide
Programs, March 30,1990.
Snyder Industries/U.S. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Pro-
grams, October 1,1990.
Allison, S., Monsanto, memorandum to T.
Gilding, National Agricultural Chemicals
Association, November 26,1990.
U.S. EPA, Trip Report to Missouri, May 25,
1990, U.S. EPA, Office of Pesticide Programs.
U.S. EPA Fourth Open Container Meeting,
August 2,1990, meeting summary and min-
utes, U.S. EPA, Office of Pesticide Programs,
August 29,1990.
Allison, S., Monsanto, memorandum to T.
Gilding, National Agricultural Chemicals
Association, November 26,1990.
U.S. EPA, Methods to Manage and Control
Plastic Wastes, A Report to Congress, Febru-
ary 1990.
Allison, S., Monsanto, memorandum to T.
Gilding, National Agricultural Chemicals
Association, November 26,1990.
Aeroquip/U.S. EPA, meeting summary, U.S.
EPA, Office of Pesticide Programs, July 12,
1990.
10. Allison, S., Monsanto, memorandum to T.
Gilding, National Agricultural Chemicals
Association, November 26,1990.
11. U.S. EPA, Methods to Manage and Control
Plastic Wastes, A Report to Congress, February,
1990.
12. Sansburn, J., PolyProcessing Company, per-
sonal communication with U.S. EPA, Office
of Pesticide Programs, September 10,1990.
13. "Minibulk - Small Tanks, Big Benefits," Cus-
tom Applicator, March 1990: pp.86-88.
14. This information and the data on minibulk
collection programs is taken from a report
being prepared for EPA that will summarize
state requirements relating to pesticide stor-
age, transportation, and disposal.
15. Allison, S., Monsanto, memorandum to T.
Gilding, National Agricultural Chemicals
Association, November 26,1990.
6.
7.
8.
9.
175
-------
Pesticide Containers - A Report to Congress
Chapter 12
Bulk Storage
Facilities
12.1 Introduction
FIFRA section 19(g) requires EPA to study
options to encourage or require "the use of bulk
storage facilities to reduce the number of pesti-
cide containers requiring disposal." For the
purposes of this report, a bulk storage facility is
considered to be a location that has one or more
bulk storage tanks where the pesticide stored in
the container(s) is repackaged into smaller con-
tainers. Bulk storage facilities are usually deal-
ers, although they also can be distributors. Be-
cause the product is repackaged, these facilities
are also pesticide-producing establishments as
defined by FIFRA. Facilities must register with
EPA and obtain a pesticide-producing estab-
lishment number.
This definition of a bulk storage facility does
not include all locations where pesticide is stored
in bulk containers. Some facilities only fill ap-
plication equipment and do not repackage, al-
though this is not common. In addition, the
state bulk storage and handling regulations that
are discussed in section 12.5 define their appli-
cability more narrowly than this report.
Bulk storage facilities and refillable contain-
ers are closely related. By definition, pesticides
are repackaged into refillable containers at all
bulk storage facilities. On the other hand, refil-
lable containers may be sold or distributed at lo-
cations that are not bulk storage facilities; small
volume returnable containers that simply pass
through the hands of a distributor or dealer are
an example of this.
Because of the connection between bulk s tor-
age facilities and refillable containers, the dis-
cussion of bulk pesticide facilities overlaps much
of the information in the three previous chap-
ters on refillable containers. This chapter be-
gins with a brief description of bulk storage fa-
cilities. Then the types of pesticide releases that
may occur at bulk storage facilities are described,
as well as the containment structures used to
minimize the environmental effects of these re-
leases. Next, some of the state regulations that
address bulk storage facilities are presented. Fi-
nally, several other issues regarding the opera-
tion of bulk storage facilities are discussed.
12.2 Description of Bulk Storage Facilities
A "typical" bulk storage facility has one or
more bulk containers which have been described
in detail in other sections of this report. Many
bulk storage facilities have secondary contain-
177
-------
Chapter 12 - Bulk Storage Facilities
meat, usually a concrete dike/ surrounding the
tanks. Also, many bulk storage facilities have a
concrete pad where operations such as filling
and cleaning minibulk containers occur. In ad-
dition, this pad can be used to load application
equipment if the repackager is also a custom ap-
plicator, which is common in the Midwest. The
bulk storage facility usually sells or distributes
pesticide in nonrefillable containers as well as
refillables, although the quantity of pesticide
varies according to the region of the country. In
the Midwest, the sale of pesticide in refillable
containers and/or custom application is typi-
cally the majority of the business of the bulk fa-
cility, so the proportion of pesticide in nonrefil-
lable containers might be relatively low.(l) On
the other hand, a dealer might have only one
bulk container dedicated to a single pesticide so
the majority of sales are in nonrefillable contain-
ers.
There are an estimated 3,000 bulk storage fa-
cilities in the United States at this time. (2) In
general, these bulk storage facilities are concen-
trated in the Midwest. For example, there are
approximately 450 bulk storage facilities in Iowa
alone. (3) Additionally, bulk storage facilities
are present in other areas of the country where
a few crops are cultivated over a large area. Re-
gions meeting these characteristics include the
cotton-growing regions of California and the
South and the tobacco-growing areas of Vir-
ginia and North Carolina.
12.3 Pesticide Releases at Bulk Storage Facili-
ties
Several kinds of pesticide releases occur at
bulk storage facilities. First, leaks and drips
from the bulk container connections are an ex-
pected part of this business. Even if dry break
couplers are used, a certain amount of pesticide
is spilled when the coupler is disconnected.
Second, a certain amount of spillage is expected
when refilling minibulks. Also, the rinsate pro-
duced when minibulk or bulk containers are
cleaned must be collected. This is usually done
by intentionally releasing the rinsate to a pad
that is connected to a collection system. The
third type of pesticide release is an accidental,
large spill from a bulk container. While a cata-
strophic incident is rare, it can occur due to the
failure of hoses or valves, human error such as
accidentally leaving a valve open, vandalism,
or some other cause. This type of uncontrolled
release is usually fairly large and can lead to
high cleanup costs if precautionary measures
are not taken.
12.4 Containment Structures
The environmental effect of these releases
can be minimized by having containment struc-
tures and by following good management and
maintenance practices. Secondary containment
around bulk containers is one common type of
containment structure, with the bulk tank itself
functioning as the primary containment. Secon-
dary containment, commonly known as diking,
usually consists of a floor and walls constructed
of concrete, although other materials such as
cinder blocks are used occasionally. Also, the
entire secondary containment system might be
coated with an impervious sealant. An average-
sized concrete dike and rinse pad meeting the
requirements of the Iowa bulk regulations costs
approximately $25,000 to design and build, al-
though the actual amount varies according to
the size of the system. (4) While the predomi-
nant construction material is concrete, secon-
dary containment structures of fiberglass or
steel are also being made. (5,6) An example of a
concrete secondary containment structure is
shown in Figure 12-1.
Secondary containment structures serve sev-
eral purposes: (1) they contain the routine
drips and leaks associated with bulk tanks, al-
lowing for easy recovery and management; and
(2) the diking system is designed to contain the
178
-------
Pesticide Containers - A Report to Congress
Secondary containment s
surrounding bulk storage tanks
Photo Credit: U.S. EPA.
contents of a tank in the case of catastrophic fail-
ure.
Secondary containment is required in sev-
eral states by their bulk facility regulations.
Also, at least five major pesticide manufactur-
ers require diking at bulk storage facilities where
their products are repackaged, regardless of
whether the states require it.(7) Additionally,
some pesticide manufacturers provide guid-
ance to the bulk storage facility regarding the
design, construction, and maintenance of the
secondary containment structure. Some bulk
facility owners have chosen to build dikes vol-
untarily when secondary containment is not re-
quired. A major concern of these people is that
the dikes will not comply with future regula-
tions. The cost and uncertainty of investing in a
secondary containment structure that may have
to be rebuilt or retrofitted in a few years is a
major barrier to the voluntary construction of
dikes.
The other type of containment structure is a
pad, which is usually constructed of concrete.
Pads are also called operational area contain-
ment structures because this is where activities
such as refilling or rinsing minibulks take place.
Pads are intended to contain and collect the
routine spills and releases associated with these
activities. A containment pad that slopes to a
sump to collect rinse water is shown in Figure
12-2.
12.5 State Regulations
As discussed in Chapter 5, many states have
addressed or are currently addressing the bulk
storage and/or handling of pesticides. Five
states have comprehensive bulk storage regula-
tions in effect. Three states have proposed com-
prehensive bulk storage regulations, while seven
states have minimal bulk storage or handling
regulations in effect. Additionally, at least five
other states are drafting bulk storage regula-
tions.
179
-------
Chapter 12-Bulk Storage Facilities
1 i^ure 12-2
A containment pad that slopes to a sump to collect rinse water
The comprehensive bulk pesticide regula-
tions of four major bulk pesticide use states —
Iowa, Illinois, Minnesota, and Wisconsin—con-
tain many of the same basic requirements.(8)
All four sets of regulations were promulgated
between 1986 and 1989. This section describes
the major points of these regulations, which are
summarized in Table 12-1.
The following discussion is not an exhaus-
tive explanation of the requirements; it is a de-
scription of some of the common standards. All
four states have requirements for containers
and appurtenances, secondary containment,
loading area containment, management of re-
covered material, and inspection and mainte-
nance.
12.5.1 Containers and Appurtenances
The regulations include general standards
for the design and construction of containers
and appurtenances. Minnesota defines appur-
Photo Credit: U.S. EPA
tenances as the "valves, pumps, fittings, pipes,
hoses, and metering devices that are connected
to a bulk pesticide container or used for trans-
ferring liquid bulk pesticide between contain-
ers," which is representative of the definitions
found in the other state regulations.(9) Typical
requirements include:
•The containers and appurtenances are con-
structed of material compatible with the
pesticides being stored and are resistant to
corrosion, puncture, and cracking;
•The containers and appurtenances are de-
signed to handle all operating stresses;
•The containers are vented and anchored;
•The valves are locked or otherwise secured
when they are unattended;
•Pipes and fittings are adequately supported;
and
•Containers and appurtenances are protected
against reasonably foreseeable risks of
damage by motor vehicles.
180
-------
Pesticide Containers A Report to Congress
Table 12-1
Comparison of State Bulk Pesticide Regulations
REQUIREMENT
INTERACTION WITH STATE AGENCY
(permit, register, etc.)
CONTAINERS AND APPURTENANCES
- Material characteristics
- Vent on container
- Containers anchored
- Valves locked or secured when unattended
- Pipes and fittings adequately supported
SECONDARY CONTAINMENT
Minimum capacity specified
- Detailed requirements for base, wall, and liner
material
- Prohibit relief discharge outlet
LOADING AREA CONTAINMENT
Liquid-tight area to contain spills, leaks,
discharges, releases
- Minimum capacity specified
MANAGEMENT OF RECOVERED MATERIAL
- Prohibit accumulation of precipitation
- Releases into secondary containment promptly
recovered
- Releases into loading area containment promptly
recovered
- Recovered material applied in accordance with label
or disposed according to applicable regulations
- Discharge response plan
- Spill clean-up equipment
INSPECTION AND MAINTENANCE
- Routine inspection of secondary containment and
maintenance if necessary
- Routine inspection of loading areas and maintenance
if necessary
- Routine inspection of containers and appurtenances
and maintenance if necessary
- Routinely measure and record liquid pesticide level
in containers
RECORDKEEPING
UNDERGROUND STORAGE PROHIBITION
IA
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
IL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
MN
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Wl
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
181
-------
Chapter 12 - Bulk Storage Facilities
12.5.2 Secondary Containment
In all four states, secondary containment
structures around bulk storage containers are
required to contain releases and prevent the
movement of liquid pesticide to surface water
or ground water. All four states specify a mini-
mum capacity for secondary containment, al-
though the actual quantity varies.
The minimum capacity must be at least the
capacity of the largest storage container. In de-
termining this capacity, the volume of liquid
that would be displaced by the submerged
portions of all storage containers and equip-
ment if the structure was completely filled must
be taken into account. Additional capacity is
required for outdoor storage facilities, which
varies between the states as follows:
•Wisconsin and Minnesota: 25 percent of the
capacity of the largest storage container;
•Iowa: 10 percent of the capacity of the larg-
est storage container; and
•Illinois: the volume of a 6-inch rain storm (a
25-year, 24-hour rain).
Three of the states include detailed stan-
dards for the construction materials used for the
base, walls, and liners of the secondary contain-
ment structure. Another common feature of the
regulations is the prohibition of discharge out-
lets.
12.5.3 Loading Area Containment
All four states require a liquid-tight area to
contain spills, leaks, discharges, and other re-
leases. This pad is the location for repackaging
pesticide into mobile containers as well as
washing equipment.
Three of the states define a minimum capac-
ity for the loading area containment. The re-
quirements are too different to describe in de-
tail, although the minimum capacity is gener-
ally about 1,000 gallons, with several specified
exceptions. The capacity requirement may be
met by having a curbed pad and/or a sloped
pad that drains into a liquid-tight collection and
catch basin system.
12.5.4 Management of Recovered Material
All of the states address management of the
material recovered from containment structures.
Common features of the regulations include:
•The accumulation of precipitation is pro-
hibited;
•Releases into secondary or loading area
containment structures are recovered
promptly; and
•The recovered material is applied in accor-
dance with the label or disposed according
to applicable regulations.
In addition, Minnesota and Wisconsin re-
quire a discharge response plan and specify a
minimum amount of spill cleanup equipment
that must be available at the facility.
12.5.5 Inspection and Maintenance
All four sets of regulations include provi-
sions for inspection and maintenance of secon-
dary containment structures. Most of the states
require the routine inspection of containers and
appurtenances, including any necessary main-
tenance. In addition, Illinois and Wisconsin
require that the level of liquid pesticide in the
containers be routinely measured and recorded.
12.5.6 Other Requirements
There are many other requirements in the
bulk storage and handling regulations of these
four states such as provisions for recordkeep-
ing and a prohibition of storing bulk pesticide
underground. The regulations should be con-
sulted for more details.
182
-------
Pesticide Containers - A Report to Congress
12.6 Other Operational Issues
Several other aspects of the operation of
bulk storage facilities are summarized in this
section. Bulk pesticide facilities may be re-
quired to comply with a number of require-
ments other than the state bulk pesticide regula-
tions. Some of the other standards that a bulk
pesticide facility might have to meet include the
Superfund Amendments and Reauthorization
Act (SARA) Title III requirements, Occupational
Safety and Health Administration (OSHA) regu-
lations, and local building and fire codes. Also,
the storage of minibulk containers may be a
problem. Minibulks require a large storage area
because they cannot be stacked very high. Fi-
nally, disposal of rinsate generated by cleaning
minibulk and bulk containers is a significant
issue. As discussed in Chapter 10, the options
available for managing the rinsate may be lim-
ited.
183
-------
Chapter 12 - Bulk Storage Facilities
Endnotes
1. U.S. EPA, Trip Report to Missouri, May 25,
1990, U.S. EPA, Office of Pesticide Pro-
grams.
2. Gilding, T., National Agricultural Chemi-
cals Association, letter to R. Denny and N.
Fitz, U.S. EPA, Office of Pesticide Pro-
grams, November 26,1990.
3. American Cyanamid/Brayton Chemicals
Inc./U.S. EPA, meeting summary, U.S.
EPA, Office of Pesticide Programs, Febru-
ary 28,1990.
4. Ibid.
5. U.S. EPA, Trip to California, Oregon,
Washington, September 16-22,1990, U.S.
EPA, Office of Pesticide Programs, October
1990.
6. U.S. EPA, Office of Pesticide Programs,
Fourth Open Container Meeting (August 2,
1990), meeting summary and minutes,
August 29,1990.
7. American Cyanamid/Brayton Chemicals
Inc./U.S. EPA, meeting summary, U.S.
EPA, Office of Pesticide Programs, Febru-
ary 28,1990.
8. Information in this discussion is taken from
the following state regulations:
• Iowa Department of Agriculture and Land
Stewardship, Iowa Administrative Code,
Chapter 9, On-Site Containment of Pesti-
cides;
• State of Illinois, Department of Agricul-
ture, Containment Rules for Agrichemi-
cal Facilities;
• State of Minnesota, Department of Agri-
culture, Chapter 1505, Bulk Pesticide
Storage and the "Bulk Pesticide Storage
Facility Rule Summary" (October 9,1989
version); and
• Wisconsin Department of Agriculture,
Explanations and Interpretations of Ag.
163, Wisconsin Administrative Code, Pes-
ticide Bulk Storage.
9. State of Minnesota, Department of Agricul-
ture, "Bulk Pesticide Storage," Chapter
1505.3010, Subpart 2.
184
-------
Pesticide Containers - A Report to Congress
Chapter 13
Options
13.1 Introduction
This chapter outlines the options that were
developed to satisfy the mandates in section
19(g) of FIFRA. Specifically, the study is re-
quired to identify options to encourage or
require:
•The return, refill, and reuse of pesticide
containers;
•The development and use of pesticide
formulations that facilitate the removal
of pesticide residues from the contain-
ers; and
-The use of bulk storage facilities to re-
duce the number of pesticide containers
requiring disposal.
Additionally, the study is required to
assess the feasibility, costs, and environmental
benefits of encouraging or requiring various
measures or actions. These items are discussed
qualitatively for each option.
In terms of cost, a three-class categorization
scheme can be used to assess specific provisions
of the options. In general, the impacts of the
options might fall into one of the following three
categories:
• Low impacts: those for which the incre-
mental costs associated with the options
are negligible to small (e.g., minor adjust-
ments to current practices, containers, or
labels);
- Some impacts: those for which the incre-
mental costs associated with the options
are burdensome but manageable (e.g.,
substantial packaging adjustments, major
changes in current practices or procedures,
or limitations such as different (or reduced)
container types);
•Significant impacts: those for which the
incremental costs associated with the op-
tions are large and perhaps insurmount-
able (e.g., a whole new infrastructure must
be developed or a major adjustment of the
marketplace would be required).
185
-------
Chapter 13 Options
The impacts of the options on the potentially
affected parties, including the federal govern-
ment, state agencies, registrants, dealers, and
users are categorized according to this three-
class scheme.
The discussion in this chapter is split into
several sections which follow the directives from
Congress. The options are discussed in the
following categories:
•Options to encourage refillable contain-
ers;
• Options to facilitate residue removal; and
•Options to encourage the use of bulk
storage facilities to reduce the number of
containers requiring disposal.
A fourth section summarizes the results of a
1985 report studying options for managing
agricultural pesticide container disposal in
Manitoba. This discussion is included for the
purposes of completeness and comparison.
13.2 Options To Encourage Refillable Con-
tainers
13.2.1 General
This section describes options that would
encourage or require both the use and the devel-
opment of refillable containers. Some of the
options are not feasible for EPA to implement at
this time and may be subject to enactment of
additional legislative authority.
Currently, refillable containers are used most
often in the agricultural segment of the pesti-
cide industry, although they are becoming more
common in the industrial pesticide market. The
infrastructure necessary for refillable contain-
ers exists in the agricultural distribution chain.
Therefore, the options discussed in this section
were developed with the agricultural sector in
mind. However, the use of refillable containers
in the industrial, institutional, household, and
specialty markets is a possible option. Expand-
ing the use of refillable containers to the non-
agricultural sectors requires additional effort,
including:
• The development of the necessary infra-
structure;
•The development of the appropriate
container and equipment technology;
and
• Assessing the feasibility of using refil-
lable containers in terms of economics,
logistics, and participation by non-agri-
cultural pesticide users.
The potential applicability to non-agricul-
tural pesticide markets is discussed briefly for
each option.
Before discussing options, there is an under-
lying structure which is necessary to build be-
fore refillable containers can assume a signifi-
cant niche in the pesticide market in an environ-
mentally acceptable way. Specifically, certain
container standards and containment require-
ments may be necessary to minimize the possi-
bility of simply replacing one problem, i.e.,
container disposal, with another one, i.e., larger
spills or accidents.
The following best management practices
should be considered to allow for the safe tran-
sition toward the increased use of refillable
containers. Cross-references to the sections that
discuss potential and existing problems are
provided in parentheses. EPA should consider:
•Refillable containers to be properly se-
cured during transportation (9.2.3,9.3.2);
•Refillable containers to meet minimum
186
-------
Pesticide Containers - A Report to Congress
standards for container strength and du-
rability (9.2.4.1,9.3.3);
•Protection of hardware attached to ref il-
lable containers or the use of check valves
(9.2.4.2,9.3.3.1);
•Regular, mandatory inspection of refil-
lable containers (9.2.4.7);
•Refillable containers to have one-way
valves and tamper-evident devices to
reduce the dealer's uncertainty about the
container's contents (10.2,10.3);
•Containers to be refilled according to
acceptable refilling practices (10.2,10.3);
• Secondary containment structures around
stationary bulk storage containers (12.3,
12.4,12.5.2); and
• Containment pads at bulk storage facili-
ties (12.3,12.4,12.5.3).
13.2.2 Option 1-1: Bulk Enforcement Policy
One option that would immediately en-
courage the use of refillable containers and
bulk storage facilities is to modify the bulk pes-
ticide enforcement policy, commonly known as
the "56-gallon" policy. The policy could be
modified to allow repackaging pesticide into
"small" refillable containers (refillable contain-
ers less than 55 gallons) at all pesticide-produc-
ing establishments.
Allowing pesticides to be repackaged into
containers smaller than 55 gallons would en-
courage the use of refillable containers by open-
ing entirely new packaging options for existing
markets. As described in section 9.2.2, the
market for large minibulks (110 gallons and
greater) has been almost saturated. While there
is definitely a market for "small minibulks"
with capacities of 15 or 30 gallons, companies
are reluctant to design and develop these kinds
of containers under the current bulk policy.
Modifying the bulk policy could increase
the likelihood of expanding refillable contain-
ers to non-agricultural markets. In general,
users in these markets require smaller quanti-
ties of pesticide than agricultural users. There-
fore, small refillable containers (i.e., those less
than 55 gallons) could be developed for the non-
agricultural pesticide sectors of the industry.
This is definitely a low cost option and would
impact the EPA and the state agencies. The
minimal impact associated with modifying the
bulk enforcement policy would include EPA
rewriting the policy and distributing the infor-
mation to the states as well as the states distrib-
uting the information to dealers.
In summary, these modifications to the bulk
enforcement policy would create new markets
for refillable containers at a low cost.
13.2.3 Option 1-2: Fee System
A fee could be placed on each nonrefillable
container, with an exemption for water-soluble
packaging. FIFRA does not explicitly authorize
a fee system; therefore, legislative modifica-
tions might be necessary before this option could
be implemented.
This approach has several advantages:
• It would make refillable containers more
attractive economically. Currently, these
containers are more expensive to design,
produce, distribute, and maintain than non-
refillables. Decreasing the price differen-
tial could encourage the use of refillable
containers.
. The money collected from the fees could
be used to fund collection and recycling
programs for the nonrefillable containers.
Therefore, the funds could also help alle-
187
-------
Chapter 13 - Options
alleviate problems with disposal of non-re-
f illable containers. A fee could also be tiered
based on the pesticide's risk to health and
the environment.
The costs associated with this option are dif-
ficult- to assess without the details of a specific
program. However, most of the burden associ-
ated with this option would fall upon the EPA
and the registrants and would probably be clas-
sified as some impact. The costs to EPA would
be associated with developing the fee system,
collecting the fees, developing the grant mecha-
nism, reviewing the grants, and distributing the
money. The cost to the registrants would be
paying the fees. Additionally, there would be
an impact on the states, probably in the low or
some impact category, involved with applying
for the grants and implementing collection and
recycling programs. Finally, there is a potential
for a low impact on pesticide users if the costs of
the fee were passed down by the registrants.
Further study of the logistics of a fee system
is necessary before this option and the neces-
sary statutory changes can be recommended.
Option 1-2, the fee system, could be applied
to non-agricultural markets with the same ad-
vantages and disadvantages. The applicability
of option 1-2 to non-agricultural sectors of the
pesticide could be included in the additional
study of the logistics of a fee system.
13.2.4 Option 1-3: Deposit and Return Program
Another option that could require amend-
ments to FIFRA is a deposit/return program.
This would involve establishing a mandatory
deposit and return program that would require
users to place a deposit on every nonrefillable
pesticide container other than water-soluble
packaging. The deposit would be paid when
the pesticide is purchased, and the money would
be refunded to the end user when the container
is returned, properly rinsed, to a central collec-
tion point.
This option would encourage the use of refil-
lable containers by making these kinds of con-
tainers more attractive, both economically and
logistically. It is possible that registrants would
use refillable or water soluble containers when-
ever possible to avoid the additional paper-
work and financial burden associated with a
deposit/return program.
A deposit and return program has several
potential benefits, which include:
•The number of containers that are disposed
by open dumping, burial, open burning,
and landfilling could decrease because the
containers would be returned; and
•The containers would be returned to a lim-
ited number of collection sites, which could
increase the potential for recycling the con-
tainers in several ways. A deposit and re-
turn program could establish part of the in-
frastructure necessary for recycling. Pro-
viding a larger and consistent source of ma-
terial for pesticide container recyclers could
encourage recycling. Additionally, it is
known that the state deposit programs for
beverage containers are an excellent source
of recyclable material. Most of the alumi-
num and polyethylene terephthalate (PET)
and a significant amount of the glass that is
recycled come from beverage containers col-
lected as a result of state deposit programs.(l)
However, this option may not be feasible to
implement on a national basis. Maine is the
only state that presently has a pesticide con-
tainer deposit and return program, and that
program involves only rigid containers for
limited use and restricted use agricultural pes-
ticides. Larger states with more agriculture
188
-------
Pesticide Containers - A Report to Congress
than Maine have commented that a deposit/ Therefore, more study is necessary before a
refund system would be very complex in their deposit and return program and the necessary
states. statutory changes can be recommended.
Most of the burden of a container deposit
and return program, which would be classified
at least as some impact and possibly significant
impact, would be on the state agencies and the
dealers. The responsibilities of the states would
increase to include implementing the program
(i.e., providing stickers, enforcement, etc.) and
inspecting the containers when they were re-
turned. Inspecting the containers could be a
labor-intensive requirement. For example, Maine
found that five state staff members were neces-
sary for inspection at sites where 1,000 or more
containers were returned. (2)
The responsibilities of the dealers would
also expand and would include a substantial in-
crease in recordkeeping, managing the system,
and potentially serving as collection sites.
However, the impact on dealers may be less
than expected. When Maine officials met with
contractors and pesticide dealers after the first
year of the deposit and return program, all
parties agreed that the program was feasible
and valuable and some were surprised at how
well the program worked. (3)
Additionally, there could be a low or maybe
some impact on pesticide users that would be
associated with managing the containers (i.e.
filling out the paper work) as well as returning
the containers.
A deposit and return program would
probably be difficult to implement in markets
other than agriculture because of the complex-
ity of the distribution chain and the large num-
ber and variety of end users. It is feasible, how-
ever, as shown by the deposit programs for
beverage containers in a number of states.
13.2.5 Option 1-4: Require Use of Certain Con-
tainers
As another option, EPA could require that a
certain percent of a registrant's product line be
sold in either refill able containers or water-
soluble packaging. This percent could be based
on the total volume of pesticide sold by each
registrant. Additionally, the percent could be
increased over time, allowing a reasonable phase-
in period for registrants to develop and extend
the appropriate technology.
This option has the benefit of definitely in-
creasing the use of refillable containers and
water-soluble packaging because it involves re-
quirements rather than incentives.
Again, FIFRA does not explicitly authorize
the implementation of this option. The specifics
of this approach need to be developed in greater
detail. It is possible that the actual implementa-
tion would be very difficult due to current
technical limitations as well as logistical con-
straints.
Similar to the fee system, it is difficult to
assess the costs associated with this approach
without the specific details of the program.
However, most of the burden would fall upon
the EPA and the registrants. The impact on the
EPA would probably be categorized as some
impact, which would include developing fea-
sible requirements (i.e., researching and estab-
lishing the baseline), modifying the production
recordkeeping requirements to incorporate
container-type data, and enforcing the program.
The burden on registrants would probably be
classified as some impact due to increased
recordkeeping and the requirement to change
189
-------
Chapter 13 - Options
container-types. However, the impact could be
significant on small registrants or those with
minor use pesticides, particularly in those situ-
ations where ref illable containers or water-sol-
uble packaging may not be appropriate.
This option could be applied to non-agricul-
tural pesticides, although it is likely that differ-
ent standards (e.g., a lower percent) would be
necessary to account for the development of an
appropriate infrastructure. The possible im-
plementation of this approach requires further
study before this option and any necessary statu-
tory changes can be recommended.
13.3 Options To Facilitate Residue Removal
13.3.1 General
One of the specific mandates for the container
study in FTFRA section 19(g) is to study options
to encourage or require the development and
use of pesticide formulations that facilitate the
removal of pesticide residues from containers.
EPA has concluded that residue removal is a
function of more variables than simply the for-
mulation. As discussed in section 7.3, residue
removal depends on the procedure used to
remove residue, the timing of the procedure,
and the container (including factors such as the
material of construction, the shape, and the size
of the container) as well as the formulation.
Thus, the options considered for residue re-
moval are likewise broader. This section dis-
cusses options that address all of the variables.
The following options are designed to facili-
tate residue removal from nonrefillable con-
tainers in several different ways. The first two
options would obviate the need for residue
removal from nonrefillable containers. Thenext
three options address residue removal at the
level of the registrant and pesticide packager.
The final three options address residue removal
at the end user level. The options apply to all
segments of the pesticide industry unless other-
wise noted.
13.3.2 Option 2-1: Encourage Refillable Con-
tainers
One option that would eliminate the prob-
lems of removing residue from nonrefillable
containers is to encourage the use of refillable
containers. The feasibility, costs, and environ-
mental benefits of the options to encourage
refillable containers are discussed in section
13.2. This option applies mainly to the agricul-
tural market, although it could be expanded to
include other segments of the pesticide indus-
try as well. The use of refillable containers
would simply eliminate the need for end users
to perform residue removal procedures. The
refillable containers would be cleaned if neces-
sary by the refiller.
It can be argued that this option simply
switches the burden of residue removal from
the end user to the refilling establishment.
However, refilling establishments are generally
better equipped to perform the necessary resi-
due removal procedures. Refilling establish-
ments are more likely to clean refillable contain-
ers thoroughly because of potential financial
liability if an improperly cleaned container is
refilled and cross-contamination occurs. In
addition, the need for residue removal proce-
dures may be eliminated if the container is
refilled with the same pesticide.
13.3.3 Option 2-2: Encourage Water-Soluble
Packaging
A second option that would eliminate the
need for residue removal procedures for nonre-
fillable containers is to encourage the use of
water-soluble packaging. The water-soluble
package containing the pesticide is simply added
190
-------
Pesticide Containers - A Report to Congress
to the mixing tank, leaving only the outer con-
tainer that has not directly contacted the pesti-
cide. The outer containers could be disposed as
solid waste without additional cleaning proce-
dures because there should be no residue.
The options for encouraging water-soluble
packaging are the same as the options for refil-
lable containers discussed in section 13.2. The
basic philosophy is to make water-soluble pack-
aging economically attractive. The potential
options are discussed in greater detail in section
13.4 and include charging a fee for every nonre-
fillable, non-water-soluble container, implement-
ing a deposit/return system, and requiring a
certain percent of a registrant's pesticides to be
sold in either refillable containers or water-
soluble packaging. However, these options re-
quire further study.
13.3.4 Option 2-3: Residue Standards
One option that is designed to address the
registrant's role in removing residue from non-
ref illable containers is to set a performance stan-
dard for the amount of residue retained in a
properly cleaned container. The performance
standard could be a maximum limit for the
amount of residue that remains in the container
after the residue removal procedure has been
performed. The registrant could be required to
show that the company's container/formula-
tion combinations could meet this standard. A
different level based on technical feasibility or
other relevant factors could be set for different
classes of nonref illable containers, such as bags,
aerosol cans, or rigid containers.
This option encompasses several of the resi-
due removal variables. Setting a performance
standard would indirectly encourage the use of
both formulations and containers that facilitate
residue removal. In addition, there would also
be flexibility in choosing a residue removal
procedure, which could include triple or pres-
sure rinsing, if appropriate for the containers.
The use of a performance standard for the
amount of residue remaining would give a
registrant the maximum amount of flexibility in
addressing residue removal. As a pesticide is
being formulated, a registrant could first try to
develop a formulation that is easily removed
from containers. This would allow the regis-
trant more flexibility in choosing a container.
However, if the development of an easily re-
movable formulation is not feasible due to chemi-
cal, physical, efficacy, or other constraints, the
registrant could instead choose a container that
is specifically designed to facilitate residue
removal. If necessary to meet the standard for
existing formulations, a registrant could change
the container used to package the pesticide.
In order to implement this option, EPA
could establish an allowable level of residue re-
moval through regulations. In addition, EPA
could require residue removal data as a condi-
tion of pesticide registration. Registrants could
be required to submit the data or to certify that
they meet the standards and maintain the docu-
mentation to support the certification. While
this is a relatively inexpensive test compared to
other registration testing, the total costs could
be large if data would be required for every
container/formulation combination. The costs
could be minimized through the implementa-
tion of the requirements. For example, con-
tainer/formulation combinations that have been
proven to meet the standard could be exempted
from the data requirement. Alternatively, data
could be required only for representative
container/ formulation combinations.
The impact on registrants depends on the
stringency of the standard. Combinations of
formulations and containers which could meet
the residue removal standard would involve
minimal costs for complying with this option.
191
-------
Chapter 13 - Options
Of much greater concern is the economic effect
on combinations of formulations and contain-
ers which could not meet the standard. If the
standard could be met by changing the con-
tainer, costs are likely to be manageable. If
meeting the standard would require changing
the formulation, some testing for registration
data would have to be redone. However, these
costs would likely be manageable because only
a subset of the data requirements would change.
EPA has gathered data regarding the extent
to which existing formulation/container com-
binations are cleaned by triple or pressure rins-
ing. These results, which are given in chapter 7,
suggest that many container/formulation com-
binations may already perform to an acceptable
level. There were 43 container/formulation
combinations studied by NACA and Formu-
logics. Of these, 30 meet a level of 99.9999
percent removal (or approximately 70 percent
of the formulation/container combinations
tested) and 37 (or about 86 percent) meet a level
of 99.999 percent removal.
Additionally, a number of formulations
could meet a standard by switching container
types. This is demonstrated by Table 7-15,
which includes data from triple rinsing a vari-
ety of containers holding the same formulation.
Three different 2.5-gallon plastic "F"-style jugs
were tested — each from a different container
manufacturer. Although the containers have
the same basic shape, they performed differ-
ently. The Penn Plastic container did not meet
a level of 99.9999 percent removal, while the
other two 2.5-gallon jugs did. Therefore, sim-
ply switching the container would be an option
for meeting the standard.
The cost of switching containers is expected
to be minimal. Thus, the overall impacts are
expected to be low for most of the container/
formulation combinations. Where reformula-
tion is necessary to meet the residue removal
requirements, the costs would be larger. The
cost would include the resubmission of some
registration data to EPA, EPA review of such
data, costs associated with reformulating the
product, and any costs associated with possible
performance differences between the old and
new formulations.
In conclusion, residue removal standards
would probably be classified as having some
impact, based on data developed for EPA.
13.3.5 Option 2-4: Formulation Standards
As discussed in section 7.3.3, the degree of
residue removal from nonrefillable containers
is related to certain characteristics of formula-
tions, such as viscosity and the solubility of the
formulation in the diluent. One option that is
directed toward registrants would be to require
the use of formulations that have been shown to
facilitate residue removal. EPA could address
formulations by alternatives such as:
- Prohibiting the use of certain types of formu-
lations that are difficult to remove from con-
tainers; or
• Requiring formulations to meet certain speci-
fications, such as establishing a maximum
allowable viscosity.
EPA would have to characterize the risks
and benefits of such formulations before taking
action under FIFRA.
This option has several drawbacks. It has
been shown that certain types of formulations
are more difficult to remove than others.
However, containers that are designed to facili-
tate residue removal could be used to package
192
-------
Pesticide Containers - A Report to Congress
the difficult-to-remove formulations. Address-
ing only the formulation is technically limiting.
In addition, more data would be necessary to
justify this approach. In order to focus only on
formulations, EPA would have to have infor-
mation on the specific formulations that are
difficult to remove. The Agency does not cur-
rently have sufficient information to make this
determination.
The impact of this option on the registrant
would probably be in the significant impact
category. If a formulation did not meet the
specifications or was prohibited, it would have
to be significantly reformulated. In this case,
the costs could be substantial. The cost would
involve research and development, the resub-
mission of registration data to EPA, EPA review
of such data, other costs associated with obtain-
ing a registration for the reformulated product,
and any costs associated with possible perform-
ance differences between the old and new for-
mulations. Additionally, the burden of this
option on the EPA would probably be classified
as some impact because of the amount of data
that would be necessary to implement this op-
tion as well as the review of increased amounts
of registration data.
13.3.6 Option 2-5: Container Design Standards
In another option that would affect regis-
trants, EPA could specifically require the use of
containers that facilitate residue removal. Di-
rect methods of addressing containers include:
• Requiring the use of a limited number of
approved containers, i.e., establishing
container specifications;
•Prohibiting certain design features that
have been shown to retain residue, such
as hollow handles in jugs, spouts that are
relatively far from the side of pails and
drums, and folded or sewn corners in bags;
or bags; or
• Prohibiting certain container designs.
All of these options are technically limiting
to a degree. Specifying a limited number of ap-
proved containers would be difficult for EPA at
this time. Additional study and research would
be necessary to show that the approved contain-
ers would result in acceptable levels of residue
removal for a variety of formulations. Also, the
specifications would have to take into account
other potentially applicable regulations such as
the DOT Hazardous Materials Regulations for
packaging. Currently, DOT is moving away
from the design specification approach toward
performance standards like the U.N. Transport
of Dangerous Goods Recommendations.
A prohibition of either specific design fea-
tures or certain overall designs may be too
limiting. EPA would have to show that these
features or container designs affect residue
removal. Additionally, some of the features
that are problematic for residue removal are
beneficial for other purposes. For example,
hollow handles in plastic jugs allow pesticide to
be poured easily from the jug while reducing
glugging.
The largest burden of this option would be
on the EPA and would probably fall into the
some or significant impacts category, depend-
ing on the course of action. In any case, a large
amount of testing on a variety of containers
•would be necessary. Even more extensive test-
ing would be required if EPA would choose to
specify a limited number of container designs,
which could cause the impacts to be significant.
The actual costs to the registrants would
most likely be low. It is likely that a move
towards increased standardization of contain-
ers would result in a preliminary transition
193
-------
Chapter 13 - Options
period, followed by a period of stable supply, as
container manufacturers adapt to the new re-
quirements. New molds might be required to
produce plastic containers, but these can be
amortized over many years, resulting in only a
small difference in the cost of such containers.
However, since containers represent only a very
small fraction of the price of delivered pesti-
cides, the economic effects would probably be
low.
13.3.7 Option 2-6: Timing of the Procedure
One option that would affect residue re-
moval from nonrefillable containers at the end
user level would be to address the timing of the
procedure. As discussed in sections 7.3.2 and
7.4.2, it is important that the residue removal
procedure be performed immediately upon
emptying the pesticide from the container. EPA
could require the procedure to be performed
immediately upon emptying the container
through regulations and/or through appropri-
ate label language.
Requiring immediate residue removal
through regulations would have insignificant
direct cost implications to registrants, although
informing and educating end users might be
difficult.
EPA could require pesticide labels to con-
tain a statement such as "The residue removal
procedure shall be performed immediately upon
emptying the contents from the container." This
approach would involve direct costs for the
registrants, because they would have to revise
pesticide labels. If this requirement were phased
in over several years, registrants probably would
be revising their labels for other reasons; there-
fore, the costs could be in the low impact cate-
gory.
For either implementation method (regula-
tions or label changes), the direct cost of requir-
ing residue removal immediately upon empty-
ing the container would be minimal for end
users. It would, however, force some pesticide
applicators to change their container manage-
ment practices. Some large pesticide users,
such as aerial applicators, load the pesticide
into their application equipment, reseal the
containers, apply the pesticide, and clean the
containers at a later time. This may be the most
efficient way for them to operate, because there
is a limited time period to perform the applica-
tion. Requiring immediate residue removal
would force these applicators to change their
procedures. This could result in a greater cost of
doing business, i.e., in greater costs for labor.
However, the overall burden on end users would
be in the low impact category, because no large
capital investment or new equipment would be
required.
13.3.8 Option 2-7: Standard Residue Removal
Procedures
One option that could encourage the use of
residue removal procedures is to standardize
the definition of certain procedures, mainly triple
rinsing and pressure rinsing. As Tables 7-1 and
7-4 show, many definitions for these rinsing
procedures currently exist. Some confusion in
the user community could be eliminated by
standardizing these definitions. This would be
a relatively low impact option, and would in-
volve the EPA defining standard residue re-
moval procedures and the states revising their
regulations or Extension bulletins.
13.3.9 Option 2-8: Educational Programs
One option designed directly for end
users would be to develop and implement a
wide-ranging education program. The impor-
tance of educating users about proper residue
194
-------
Pesticide Containers - A Report to Congress
removal procedures can be seen in the design
and implementation of existing pesticide con-
tainer collection programs. As discussed in
section 8.9, the education of growers has been a
major part of these programs. For example,
Minnesota ran a year-long "Rinse and Win"
campaign in 1989 to educate users before con-
tainer collection programs were initiated in 1990.
The Minnesota Department of Agriculture dis-
tributed flyers on rinsing and held rinsing dem-
onstrations at farm shows and field days through-
out the state. State representatives at a NACA-
sponsored meeting on pesticide container recy-
cling said that educating users about the impor-
tance of rinsing containers was crucial to a
successful collection program. (4)
One approach could be to incorporate cur-
rent information on the importance of residue
removal as well as the proper techniques into
the certification and training program. This
would be a low cost option because the certifica-
tion and training program already exists. EPA
could develop guidance documents and pro-
vide this material to the states. Therefore, the
costs on both the EPA and the states would be in
the low impact category. Only minor modifica-
tions would be necessary to incorporate the new
material.
One drawback is that only those who use re-
stricted use pesticides are required to be certi-
fied. Therefore, another part of the educational
program would need to be developed to ad-
dress agricultural users who are not certified as
well as non-agricultural users. The implemen-
tation of this part of the educational program
would be more difficult, although it could still
be done at low cost with the cooperation and
distribution of information through appropri-
ate trade associations, farm co-ops, and local
dealers.
13.4 Options To Encourage the Use of Bulk
Storage Facilities To Reduce the Number of
Containers Requiring Disposal
13.4.1 General
As discussed in Chapter 12, the use of refil-
lable containers and bulk storage facilities are
very closely related. Bulk storage facilities re-
package pesticides from bulk containers to mini-
bulks, both of which are refillable. Because of
the connection between bulk storage facilities
and refillable containers, the options to encour-
age or require the use of bulk facilities are the
same as the options discussed in section 13.2 for
encouraging refillable containers. The precau-
tionary standards that are discussed for refil-
lable containers apply as well.
However, part of the goal of this option is
"to reduce the number of pesticide containers
requiring disposal." In addition to the use of
refillable containers and bulk storage facilities,
there are several ways to reduce the number of
containers requiring disposal. These other
methods include the use of "water-soluble pack-
aging and recycling the containers.
Water-soluble packaging reduces the num-
ber of containers requiring disposal because the
package in direct contact with the pesticide
dissolves in the tank mix. The outer container
still requires disposal, although in most cases it
does not contain pesticide residue.
Additionally, recycling would reduce the
number of containers requiring final disposal.
In other words, an increase in recycling would
reduce the number of containers disposed in
ways such as open burning, burial, open dump-
ing, and landfUling. Several crucial areas must
be addressed in order to increase the recycling
of pesticide containers nationwide.
195
-------
Chapter 13 - Options
• An infrastructure for recycling is neces-
sary, including established methods for
collecting, inspecting, and transporting
the containers;
- An important part of the infrastructure is
the availability of funds to run the collec-
tion programs;
- Several technical questions, such as the
amount of pesticide retained in the resin,
need to be answered; and
- Until a market for the recycled material
exists, recycling will not be economically
feasible. Several of the issues include de-
termining appropriate end uses for the
recycled material from pesticide contain-
ers and ensuring that the material goes to
those markets.
Similar to refillable containers, a greater
move toward recycling containers exists within
the agricultural segment than with other mar-
kets in the pesticide industry. However, the
number of containers used in the other pesticide
markets is much larger than the number of
agricultural containers, as discussed in section
4.4. Therefore, the potential for recycling non-
agricultural pesticide containers should be in-
vestigated.
Additional study of the recycling issues
is necessary before effective collection and recy-
cling programs can be realized.
This section discusses the options included
in section 13.2 to encourage or require the use of
refillable containers. The feasibility, costs, and
environmental benefits associated with each
option are addressed in section 13.2. However,
this section focuses on how each option will
reduce the number of containers requiring dis-
posal by encouraging bulk storage facilities,
water-soluble packaging, and recycling. Also,
these options reduce the need for end users to
perform residue removal procedures on nonre-
fillable containers in the field.
13.4.2 Option 3-1: Bulk Enforcement Policy
Modifying the bulk enforcement policy would
increase both the development and use of refil-
lable containers. This increase would be associ-
ated with a corresponding increase in the use of
bulk storage facilities. The development and
use of smaller refillable containers on a large
scale would open new markets and probably
lead to an increase in the number of bulk storage
facilities.
13.4.3 Option 3-2: Fee System
This option involves placing a fee on each
nonrefillable pesticide container except for water-
soluble packaging. This would encourage refil-
lable containers by making them more attrac-
tive economically. This option would also:
•Increase the use of bulk storage facilities,
which would be associated with an increase
in the use of refillable containers and a cor-
responding decrease in the number of con-
tainers disposed as waste;
Increase the use of water-soluble packaging
by making it more attractive eco-nomically;
and
•Potentially provide a means for funding
container collection and recycling pro-grams.
The money collected from the fees could be
used to develop and support collection and
recycling programs. An increase in the
number of collection and recycling programs
could provide a larger and consistent source
of material for pesticide container recyclers.
This could further encourage recycling be-
cause the recyclers could justify significant
investments in equipment and facilities.
196
-------
Pesticide Containers - A Report to Congress
As discussed earlier, this option could re-
quire statutory changes. Additional study of
fee systems is necessary.
13.4.4 Option 3-3: Deposit and Return System
Establishing a deposit and return system for
nonrefillable, non-water-soluble pesticide con-
tainers would encourage the use of refillable
containers by making them more attractive, both
economically and logistically. A deposit and
return system also could reduce the number of
containers requiring disposal by:
•Encouraging the use of bulk storage facili-
ties that would be associated with the in-
crease in refillable container use. This trend
would be led by dealers who would rather
handle refillable containers than accept the
returned nonrefillable containers;
•Encouraging the use of water-soluble pack-
aging by making it more attractive, both
economically and logistically;
• Changing the disposal methods for the re-
turned containers. Specifically, a deposit/
return system probably would decrease the
number of containers disposed as waste.
Such a program could encourage recycling
by providing the means to collect pesticide
containers at a limited number of locations.
This could establish part of the necessary in-
frastructure; and
.Increasing the potential for recycling the
containers in several other ways, as dis-
cussed in Section 13.2.4.
Again, amendments to FIFRA could be nec-
essary to implement this option. Additional
study is necessary before a deposit/return pro-
gram can be recommended.
13.4.5 Option 3-4: Require Use of Certain
Containers
This option would involve requiring that a
certain percent of each registrant's product line
be sold in either refillable containers or water-
soluble packaging. This option would decrease
the number of nonrefillable containers by re-
quiring (rather than indirectly encouraging)
either:
•An increase in the use of refillable containers,
•which would be associated with an increase
in the use of bulk storage facilities; and/or
•An increase in the use of water soluble pack-
aging.
This option also may require changes to
FIFRA. Further study is necessary before the
implementation of this option is recommended.
13.4.6 Option 3-5: Recyclable Material
Another option that could reduce the num-
ber of containers needing disposal is for EPA to
require through regulations that containers be
constructed of recyclable material. This option
is intended to encourage the recycling of pesti-
cide containers. EPA is currently debating and
discussing definitions for recycling and recy-
clable.
This option would not impose much burden
on containers made of metal, glass, or plastic, as
technologies exist to recycle these materials.
Technologies for recycling glass and metal have
long been established. Technologies for recy-
cling plastic are less mature and vary by resin,
but are clearly feasible in many cases.
Less clear is how the recyclable material re-
quirement could be interpreted regarding bags,
197
-------
Chapter 13 - Options
especially paper bags with plastic or foil liners.
Though the recycling of paper is feasible, the
recycling of paper potentially contaminated with
pesticide residue is another matter. Paper bags
lined with foil or plastic are even less likely to be
considered recyclable. If such bags were not
considered recyclable, and were not eligible for
an exemption, then such bags would need to be
redesigned or risk being displaced by plastic
containers. For example, alternative designs
might include a plastic bag within a paper bag.
However, the use of this design may result in
increased worker exposure during refilling, as
refilling operations which are now automated
may require manual labor to insert the bag
within a bag.
The potential for compliance costs and eco-
nomic impacts depends on the definition and
interpretation of recyclable material. For most
nonrefillable containers, it is likely that this
option would be in the low impact category.
Should bags be disproportionately affected by
this option, it could be classified in the some
impact category.
Further study is necessary before this option
can be recommended. More information is
needed to define recyclable and to determine
the implications of requiring containers to be
constructed of recyclable materials.
13.5 Summary of 1985 University of Manitoba
Report on Disposal Options
This section summarizes the results of a 1985
report studying options for managing agricul-
tural pesticide container disposal in Manitoba.
The report includes an economic analysis done
by the Department of Agricultural Economics
and Farm Management at the University of
Manitoba. (6) This study examines the eco-
mic tradeoffs of various disposal options in-
cluding the ones discussed in this report. This
summary is included for purposes of complete-
ness as well as comparison.
The University of Manitoba, Department of
Agricultural Economics and Farm Management,
conducted a study on pesticide container dis-
posal, which can be used as a basis for consider-
ing policy alternatives for controlling pollution
by nonrefillable pesticide containers. In this
study, Strain and Freshwater explored the
magnitude of pollution caused by pesticide
containers in Manitoba and various options for
addressing the container disposal problem. The
options considered by this research team were
placed into four categories: moral suasion, gov-
ernment investment, direct regulation, and
market processes.
The authors defined criteria in order to evalu-
ate the options for controlling pesticide con-
tainer disposal. TheBaumol-Oates criteria used
set forth eight measures with which to analyze
the policy options. These criteria were de-
pendability, permanence, adaptability to eco-
nomic growth, incentives for maximum effort,
equity, efficiency, political attractiveness and
minimal interference with private decisions.
Strain and Freshwater then added a ninth crite-
rion for the container disposal problem, mini-
mal risk to health and the environment. The
rest of this section summarizes the conclusions
the authors reached by applying these criteria
to the options that were considered.
Moral suasion is an attempt to persuade
users to not pollute with used pesticide contain-
ers. Methods to implement this include conven-
ing public meetings, issuing statements or pro-
nouncements, and making appeals. This option
relies heavily on public pressure, and its goal is
to change the users' attitudes. As a policy
alternative, moral suasion lacks permanence,
198
-------
Pesticide Containers - A Report to Congress
dependability, and incentives for maximum
effort. Therefore, it is not considered a mainstay
of a pesticide container control policy.
Government investment could be in the form
of building and maintaining a facility or estab-
lishing an educational program, with the goal of
leading the public to adopt desirable behavior.
A facility could be a government-run disposal
facility or a collection station. An education
program could attempt to increase public aware-
ness regarding the pollution problem, safe
handling of pesticides, and proper container
disposal. Because it depends upon interest
generated within the target population, govern-
ment investment lacks permanence and incen-
tives for maximum effort.
Direct controls are defined as regulations or
standards, and the study evaluates both of these
for their effectiveness to address the container
disposal problem. This could include a variety
of forms of implementation, depending on what
community is to be regulated (Le., the farmer or
the producer). Direct controls, while politically
effective, rely on enforcement and are, there-
fore, subject to randomness. Given the size and
dispersion of the target population, it is unrea-
sonable to expect adequate enforcement of a
standard or regulation.
Market processes include three potential op-
tions for changing behavior to achieve pollution
control of pesticide containers; subsidization,
taxation, and a deposit-refund system. The
market processes all have weaknesses which
could prevent such a policy mechanism from
providing an effective pesticide container dis-
posal policy.
A subsidy can act to discourage one behav-
ior by pulling a person toward a more favorable
behavior. A subsidy could be provided by gov-
ernment to help farmers pay for pressure rin-
sers on spray equipment or to compensate farm-
ers who use collection facilities by helping pay
for the time and effort involved in taking con-
tainers to the facility. Producers who accept
used containers could be subsidized for their
handling and storage costs, or municipal gov-
ernments could receive subsidies to help pro-
vide and maintain landfill sites. Subsidies re-
ceived negative rankings for most of the de-
fined criteria. They lack efficiency and equity
and do not necessarily motivate a change in
behavior. In addition, subsidization must be
financed by the government, which may be
difficult, especially in light of federal budget
constraints.
Taxation is a policy tool that pushes one
away from a specific behavior. A tax could be
levied on pesticides, and revenues collected
could be targeted to pay for the clean up of
containers. Taxation, however, may simply be
viewed by the users as an additional cost of
operation. It will not ensure a reduction in risks
to health and the environment. Taxation is also
not politically attractive.
The deposit-refund system is a policy in-
strument that pushes one away from certain be-
havior, as a tax does, and pulls one toward
another, more favorable behavior, as a subsidy
does. If the consumer pays a deposit at the time
of purchase and then returns the empty pesti-
cide container, the user will have the deposit re-
turned. However, if the person does not return
a used container, that person is, in effect, being
charged for improper disposal. A deposit-re-
fund system, while not flawless, avoids many
of the pitfalls associated with the other policy
mechanisms. The policy is dependable, perma-
nent, adaptable, and provides incentives for
maximum effort. It does not sacrifice the envi-
ronment or public health and it ensures equity
and efficiency.
199
-------
Chapter 13 - Options
The Manitoba University study concludes
with a recommendation to implement a de-
posit-refund system. This was the option that
ranked highest against the nine criteria estab-
lished for evaluating the various options. The
deposit-refund system was then further exam-
ined and an integrated policy to implement
such a program was outlined.
The study suggests certain conditions under
which a deposit-refund system should be de-
veloped. First, the disposal system must allow
for either landfill disposal or container recy-
cling, in order to provide flexibility. Second, the
policy must mandate triple rinsing or pressure
rinsing procedures to ensure safe handling and
disposal. Third, the responsibility of container
disposal is on the end users of the pesticides, not
the dealers or registrants.
Additional implementation decisions would
have to be considered before establishing a
pesticide container deposit-refund system. For
example, an appropriate deposit amount would
have to be set. The deposit would have to be
high enough to ensure return of containers while
low enough so as to not cause unreasonable
financial burden. The cycle for container return
would have to be established and guidelines for
rinsing containers before their return would
need to be set. Testing for proper rinsing would
have to be included in the policy design and
penalties for improper rinsing would have to be
set.
Also, start-up costs for this program could
be substantial. Costs would be incurred for
initial deposits, storage and collection sites, es-
tablishment of disposal facilities for nonrefil-
lable containers, and the development of proce-
dures for handling deposits, refunds, and re-
turned containers. An outreach program would
be necessary to inform the users and producers
of the new deposit-refund system, as well as
other aspects of safe use of pesticides.
This discussion is included in the report to
serve as a reference for the Manitoba study as
well as to present the variety of available op-
tions and the economic analysis of these op-
tions.
200
-------
Pesticide Containers A Report to Congress
Endnotes
1. Selke, S., and C. Lai, "Considerations in
Packaging Design - Recyclability Aspects,"
presented at the Fourth Annual Conference
on Solid Waste Management, New York,
New York, January 1988.
2. Denny, R. and D. McLaughlin, Maine
Board of Pesticide Control, Report on
Maine Pesticide Containers Program, 1985.
3. Ibid.
4. National Agricultural Chemicals Associa-
tion/American Association of Pesticide
Control Officials, meeting summary, U.S.
EPA., Office of Pesticide Programs, March
7,1990.
5. Selke, S., and C. Lai, "Considerations in
Packaging Design - Recyclability Aspects,"
presented at the Fourth Annual Conference
on Solid Waste Management, New York,
New York, January 1988.
6. Strain, G., and D. Freshwater, "Options for
Managing Pesticide Container Disposal in
Agriculture," Extension Bulletin No. 85-2,
Department of Agricultural Economics and
Farm Management, University of Manitoba,
Winnipeg, Manitoba, July 1985.
201
-------
Pesticide Containers A Report to Congress
Chapter 14
Conclusion
14.1 Introduction
Congress directed the Agency to conduct a
study of options to encourage or require:
. The return, refill and reuse of pesticide
containers;
• The development and use of pesticide
formulations that facilitate the removal
of pesticide residues from containers; and
• The use of bulk storage facilities to re-
duce the number of pesticide containers
requiring disposal.
The options are outlined in Chapter 13 in
these three general categories. The body of this
report is also organized around these three cate-
gories. For both nonrefillable and refillable
containers, information is presented regarding
the use of containers, residue removal, and
disposal. Additionally, these three issues ad-
dress the specific mandates of Congress regard-
ing the container design regulations that EPA is
currently drafting. The requirements for these
regulations are described in section 5.4.1. This
chapter is a summary of the recommendations
and possibilities for further study within these
three bf oad areas.
14.2 General Conclusions
Emerging from this study, and beyond the
specific mandates of Congress, are several gen-
eral conclusions relating to the development of
a pesticide container management strategy. Part
of this strategy includes promulgating the con-
tainer design and residue removal regulations
discussed in section 5.4.1 as well as developing
and implementing the options in Chapter 13.
Additionally, the pesticide container manage-
ment strategy includes long-term goals, which
can be divided into several main categories.
14.2.1 Formulation and Container as a Unit
The first long-term goal is to have the pesti-
cide industry consider the pesticide formula-
tion and its container as a single entity. This
would require a significant change in philoso-
phy. Generally, formulating and packaging a
pesticide are separate projects done by different
groups within a company or by different com-
panies altogether. The change in perception
from considering a container simply as a vessel
to transport a pesticide to seeing the relation-
ship between the container and the pesticide is
an integral step in the long-term improvement
203
-------
Chapter 14 - Conclusion
of containers. The relationship between the
container and the pesticide is important in all
stages of the pesticide/container life cycle, in-
cluding use of the container (transportation,
storage, transferring pesticide from the con-
tainer, etc.), residue removal, and disposal of
the container.
14.2.2 Provide Leadership
The second long-term container management
goal is to provide leadership in the area of
pesticide containers. This container study in-
volved a great deal of cooperation between
EPA, other federal agencies, state agencies,
industry groups, environmental organizations,
and many individuals involved with pesticide
containers. EPA would like to continue this
dialogue and cooperation in the future.
14.2.3 Move toward Environmentally Prefer-
able Containers
Any efforts, both public and private, to ad-
dress pesticide containers should strive for:
•Protection of the integrity of the pesticide
product and the environment through
which the container passes; and
•The safe and easy transfer of pesticide from
the container to the application equipment.
14.3 Specific Options
This section summarizes the specific options
and recommendations that are discussed
throughout the report. These conclusions are
presented in the categories prescribed by Con-
gress — containers, residue removal, and dis-
posal — for both nonref illable and ref illable con-
tainers. Cross-references to the sections of the
report that discuss the problems or issues in
greater detail are included in parentheses.
14.3.1 Containers
Containers are the first category in the frame-
work supplied by Congress. The specific op-
tions and recommendations involve both con-
tainer design and use of the containers.
14.3.1.1 Nonrefillable Containers
One of the characteristics of an optimal con-
tainer is the ability to allow for the safe and easy
transfer of pesticide from the container to the
application equipment. Pesticide can be trans-
ferred from the container either by hand or with
mechanical transfer systems. Several issues are
involved with pouring pesticide from the con-
tainer by hand:
•The user should be able to easily open the
container while wearing gloves (6.2.3,6.2.4,
6.4.2, 7.4.2); and
•The container should pour without "glug-
ging" and dripping (6.2.4,6.2.5,6.3.10,7.4.2).
The study showed that it is possible to meas-
ure glugging and to graphically depict glug-
ging to correspond to observations of the ability
of a container to pour (6.3.9).
Another way to allow for the safe and easy
transfer of pesticide from the container to the
application equipment is to use closed transfer
systems. EPA could encourage the use of closed
transfer systems by standardizing the closures
on nonrefillable containers (6.6.1.2, 6.6.1.3).
Having stated what the objectives are, EPA
should consider the following:
• Establish performance standards dealing with
opening containers while wearing gloves
and minimizing glugging (6.2.4); and
204
-------
Pesticide Containers A Report to Congress
• Prescribe standard closures on nonref illable
containers to facilitate the use of closed sys-
tems (6.6.1.2).
14.3.1.2 Refillable Containers
As discussed in section 13.2.1, several stan-
dards may allow for the safe transition to more
refillable containers and bulk storage facilities.
EPA should consider:
• Refillable containers to be properly secured
during transportation (9.2.3,9.3.2);
•Refillable containers to meet minimum stan-
dards for container strength and durability
(9.2.4.1,9.3.3);
•Protection of hardware attached to ref illable
containers or the use of check valves (9.2.4.2,
9.3.3.1);
•Regular, mandatory inspection of ref illable
containers (9.2.4.7);
•Refillable containers to have one-way valves
and tamper-evident devices to reduce the
dealer's uncertainty about the container's
contents (10.2,10.3);
•Secondary containment structures around
stationary bulk storage containers (12.3,12.4,
12.5.2); and
•Containment pads at bulk storage facilities
(12.3,12.4,12.5.3).
EPA should also encourage the pesticide in-
dustry to:
• Develop and improve the hardware associ-
ated withrefillable containers (9.2.5.2,9.3.4);
and
•Standardize ref illable containers after addi-
tional study of the issues and problems in-
volved with standardization (9.2.6, 9.3.5).
14.3.2 Residue Removal
Residue removal is the second category in the
Congressionally-supplied framework.
14.3.2.1 Nonrefillable Containers
In studying the issue of residue removal from
nonrefillable containers, EPA came to the fol-
lowing conclusions:
•A substantial percent of pesticide users do
not triple or pressure rinse their containers
(7.2.2.4);
•The variables that affect the degree of resi-
due removal are the procedure used to clean
the container, the timing of the procedure,
the formulation, and the container itself (in-
cluding factors such as the material of con-
struction, the shape, and the size) (7.3);
• It should be possible to effectively reseal any
container that is intended to be triple rinsed
to prevent possible exposure during the rins-
ing procedure (7.4.2.2).
• The existing data present inconclusive evi-
dence about the relative efficiency of triple
and pressure rinsing (7.4.3).
EPA has developed the following options re-
garding residue removal:
•Encouraging the types of containers (e.g., re-
fillable systems and water-soluble packag-
ing) which eliminate the need for end users
to be concerned about residue removal (13.3.1,
13.3.2,13.3.3);
• Considering performance standards for resi-
due removal. These standards would be a
requirement for registrants (13.3.1,13.3.4,);
• Providing flexibility to registrants to deter-
mine how to meet the performance stan-
dards and requiring registrants to submit
data or certify that they have met the stan-
dards as part of the registration process (13.3.4);
205
-------
Chapter 14 Conclusion
•Requiring that nonrefillable containers be
cleaned immediately after the pesticide has
been transferred from the container (13.3.7,);
and
•Developing an educational program about
the importance of residue removal and
proper rinsing methods. As part of this
process, educational material could be in-
corporated into the certification and
training program (13.3.9).
14.3.2.2 Refillable Containers
The main issue with removal of residues
from refillable containers is preventing cross-
contamination. EPA has come to the following
conclusions.
•Refillable containers should empty and drain
easily to minimize the amount of liquid
retained in the container after draining or
cleaning (9.2.4.3,9.2.4.4,10.2); and
•Clarification of allowable refilling practices
may be needed. For example, a pesticide
could be repackaged into a refillable con-
tainer if the container previously held the
same pesticide or if the container is prop-
erly cleaned (10.3.1).
Another area of concern is the management
of the rinsate produced when refillable con-
tainers are cleaned (10.5). EPA should work
with repackagers (producing establishments)
and others in the pesticide industry to develop
feasible, low-cost options to manage the rin-
sate.
14.3.3 Disposal
Disposal of containers is the third category
in the outline provided by Congress.
14.3.3.1 Nonrefillable Containers
The following conclusions were made about
nonrefillable pesticide container disposal based
on the information collected during the study.
• Nonrefillable container disposal is a serious
concern with pesticide users (8.2);
. Landfilling and open burning are by far the
two most common disposal methods for
agricultural pesticide containers; disposal
through the municipal solid waste stream is
the most common disposal method for other
types of containers (8.2);
• An increasing number of landfills are refus-
ing to accept empty pesticide containers (8.5);
• It is technically feasible to recycle steel and
plastic pesticide containers and the number
of pilot container collection and recycling
programs for agricultural pesticide contain-
ers is growing (8.8.2,8.9); and
•There are two common characteristics of
these pilot container collection and recy-
cling programs: (1) proper rinsing of con-
tainers is essential for a successful program;
and (2) inspection of the containers is neces-
sary to ensure proper rinsing (8.9.1).
Based on these conclusions, EPA has devel-
oped the following options to reduce the num-
ber of containers requiring disposal, as dis-
cussed in Chapter 13. The options include:
• Creating incentives for refillable containers
and water soluble packaging. This would
help reduce the solid waste contributions to
landfills (13.2,13.4);
• Encouraging the use of minibulks (and other
refillable containers) and bulk storage facili-
ties (13.2,13.4);
. Promoting the safety of refillable containers
and bulk storage facilities (13.2.1,14.3.1.2);
and
• Encouraging the recycling of pesticide con-
tainers (13.4,14.2.4).
14.3.3.2 Refillable Containers
Refillable containers reduce the number of
containers requiring disposal. However, the
refillable containers themselves must be dis-
206
-------
Pesticide Containers - A Report to Congress
posed at the end of their lifetime. Although it is
not currently a serious problem, feasible op-
tions for the disposal of refillable containers
need to be developed (11.1).
14.4 Areas for Further Study
In preparing this report, the Agency has col-
lected the most up-to-date, available informa-
tion on container design and disposal issues.
EPA recognizes that this is not the final answer,
but rather an interim step in creating a life cycle
system that reduces hazard and waste from pes-
ticide products and their containers in a cost-
effective manner. The areas that could benefit
from further study are summarized in this sec-
tion.
14.4.1 Containers
Further study would be beneficial in the fol-
lowing areas of pesticide container use and
design:
.Pouring studies (6.3.9, 6.3.10) — Research
done for this report shows that the meth-
odology used to quantify the phenomenon
of glugging is technically feasible and suc-
cessful. Additional effort is re-quired to
further quantify the data and permit the full
utility of this methodology. Also, variables
such as viscosity and temperature could be
incorporated into the data; and
.Standardization of refillable containers (9.2.6,
9.3.5) - The issues involved with standard-
izing refillable containers need to be clearly
identified by all affected parties including
EPA, registrants, dealers, equipment and
container manufacturers, and users. A clear
definition of the issues would include:
(1) The current problems;
(2) The different areas for potential
standardization and how each op
tion would address the problems;
(3) The costs and benefits of any stan-
dardization option;
(4) The potential implementation strate-
gies (Le., voluntary industry stan-
dards vs. regulations); and
(5) The potential impacts of "no ac-
tion."
14.4.2 Residue Removal
Section 7.6 describes the potential areas for
further research for residue removal from non-
ref illable containers. More data would be bene-
ficial in the following areas:
• The amount of pesticide adsorbed to and
absorbed into plastic containers (7.6.1);
•The effectiveness of triple rinsing for more
container/formulation combinations for all
pesticides in rigid containers (7.6.2);
. The effectiveness of pressure rinsing for rigid
agricultural pesticide containers
(7.6.2);
•The residue remaining in bags, including
analyzing the effect of variables such as bag
type, bag size, barrier material, and formu-
lation type (7.6.2);
.The residue remaining in aerosol cans (7.6.2);
• The amount of residue retained when ready-
to-use formulations are removed from con-
tainers, (7.6.2);
• The design and potential improvements in
pressure rinsing nozzles (7.6.2);
• The amount of pesticide removed from plas-
tic container resin during the recycling proc-
ess. This is currently being studied by recy-
cling companies (7.6.3); and
• The development of practical analytical field
testing techniques for determining the level
of residue removal (7.6.4).
207
-------
Chapter 14 - Conclusion
14.4.3 Disposal
Further study may be beneficial in the follow-
ing areas of container disposal:
• Open Burning (8.6) — Several studies are
being done on the open burning of pesticide
bags. Based on the results of these studies,
further research may be necessary; and
• Recycling (8.8, 8.9) — Increased recycling
would reduce the number of containers
requiring disposal. In order to facilitate re-
cycling, a study of recycling specifically could
include:
(1) An analysis of the current pilot col-
lection programs;
(2) The development of pilot programs
for different container types, such
as aerosol cans and minibulk con-
tainers;
(3) Determining the major motivations
and impediments for safe residue
removal and return of the container
by the user;
(4) Comparing potential methods for
funding the initiation of recycling
programs; and
(5) Determining the necessary degree
of compliance supervision.
14.4.4 Other Options
In addition, the following areas may warrant
further study to explore whether changes in the
federal or state authorities under FIFRA should
be changed:
• Implementation of a fee system for cer-
tain types of containers (13.2,13.4);
• Development of a deposit and return
program for nonrefillable containers (13.2,
13.4);
• Implementation of requirements that a
percent of each registrant's pesticide
products be packaged in refillable or water-
soluble packaging (13.2,13.4); and
• The need for federal regulations on sec-
ondary containment structures and op-
erational pads at bulk storage facilities
(12.4,12.5)
14.5 Conclusion
In section 19(g) of FIFRA, Congress asked the
Environmental Protection Agency to study: (1)
ways to encourage or require the return, refill,
and reuse of pesticide containers; (2) the rela-
tionship between formulations and pesticide
containers; and (3) methods to reduce the number
of containers requiring disposal. Using the
information available at the time, this "Con-
tainer Study" was designed. The knowledge
gained by the Agency during the course of this
study has been extremely useful in pointing the
way toward new regulations, policies, and goals.
Indeed, the EPA Container Study has uncov-
ered some questions along with many answers.
In one form or another, portions of this study
will continue to be researched by EPA and
others. Nevertheless, the Agency has made
progress in understanding the forces affecting
pesticide container design, safe use, residue
removal, and ultimate disposition. The 1988
amendments to FIFRA have put the Agency, the
affected industry and user community, and the
general public on the road to an improved,
more comprehensive, and environmentally
protective system of dealing with the pesticide
container issues in this country.
208
-------
Pesticide Containers - A Report to Congress
Appendix A
Triple and Pressure Rinse
Procedures
Bottles, Jugs, Cans, Pails, Drums
Archer, 1975.
T.E. Archer, "Removal of 2,4-Dichlorophe-
noxyacetic Acid (2,4-D) Formulations from Non-
combustible Pesticide Containers." Bulletin of
Environmental Contamination and Toxicology.
Vol. 13, Number 1, (January 1975): pp. 44-51.
This laboratory study began by determining
the net retention volume or weight of active in-
gredient (a.L) for each formulation/container
combination according to the following proce-
dure.
a. The clean, dry container was weighed.
b. Excess formulation was added to the con-
tainer, which was then closed, shaken, and
swirled to wet the inner surface.
c. The container was drained into a graduated
cylinder until dripping stopped (at least
five minutes).
d. The container was reweighed and the re-
tained formulation was expressed as the
net retention volume or weight of a.L
e. The mean retention volume for each con-
tainer/formulation combination was cal-
culated from three runs.
The container was then rinsed with at least
four water rinses and then three organic solvent
rinses as described by the following protocol.
a. The mean retention volume was added to
the container.
b. A volume of washing solvent was added to
the container:
• 250 ml for a 5-gallon container;
• 750 ml for a 30-gallon container; and
• 1,000 ml for a 55-gallon container.
c.The container was "closed,..., shaken,
swirled, and tumbled repeatedly."
209
-------
Appendix A - Triple and Pressure Rinse Procedures
d.The rinsate was drained into a graduated
cylinder until the dripping stopped (at least
five minutes).
e. Each container was rinsed with four to eight
water rinses followed by three rinses with
an organic solvent.
Braun, et alv 1983.
H.E. Braun, et al., "Efficiency of Water Rins-
ing for the Decontamination of Used Pesticide
Containers," Archives of Environmental Con-
tamination and Toxicology, Vol. 12, (1983): pp.
257-264.
This was a field study and its purpose was to
determine the effectiveness of rinsing pesticide
containers with water on site.
In 1979, the following procedure was used
for glass, plastic, and metal containers.
The container was emptied "as usual" by
applicators.
A quantity of solvent equivalent to 10% of
the container volume was added to the con-
tainer.
a. The container was shaken for 10 seconds.
b. The rinsate was collected while the con-
tainer drained until spasmodic dripping
was observed.
c. Each container was rinsed five times.
d. Where possible, a total of three series of
rinses was done for each formulation.
A similar procedure was followed in 1980
and 1981, except another step was added be-
tween 'a1 and 'b1. After the initial emptying op-
eration, the containers were inverted and drained
for 60 seconds. This volume of formulation was
collected and measured. The rest of the proce-
dure was then followed.
Formulogics, 1990.
A. D. Lindsay, Formulogics, "Protocol: Rins-
ing Procedures for Containers Holding Liquid
Crop Protection Chemicals," September 6,1990.
This is the protocol that was developed for
the container study and report to Congress. It
was used to develop the Formulogics and Na-
tional Agricultural Chemicals Association
(NACA) data.
The triple rinsing procedure is:
a. Empty the container and allow it to drain
for 30 seconds after the flow of liquid can
no longer be described as a continuous
stream.
b. Recap the container and rinse within 30
minutes of emptying.
c. Add an amount of water to the container
equivalent to 25 percent of the volume of
the container.
d. Place the cap back on the container and
"vigorously shake it in a side to side and
up and down motion for thirty seconds."
The protocol describes the motion in
greater detail.
e. Invert the container and allow it to drain
for 30 seconds after the flow of liquid can
no longer be described as a continuous
stream.
210
-------
Pesticide Containers - A Report to Congress
f. Repeat steps 'c - e1 for a total of at least
four rinses.
The pressure rinsing procedure is:
a. Empty the container and allow it to drain
for 30 seconds after the flow of liquid can
no longer be described as a continuous
stream.
b. Recap the container and rinse within 30
minutes of emptying.
c- The water pressure should be 40 ± 2 psL
d. Remove cap and invert the container over
a receiving vessel.
e. Insert the pressure rinse device at a point
in the uppermost surface that will maxi-
mize the rinsing of the internal surfaces
of the container.
f. The pressure rinse device can be moved
and twisted to ensure more thorough
rinsing once the water is turned on.
g- Rinse the container for at least 30 sec-
onds.
Frank, et al., 1987.
R. Frank, et al., "A System for Rinsing Herbi-
cide Residues from Drums During Highway
Right-of-Way Spray Operations," Bulletin of
Environmental Contamination and Toxicology,
Vol. 39, (1987): pp. 680-687.
This was a field study whose purpose was to
determine the efficiency of a drum-rinsing sys-
tem developed by the Ontario Ministry of Trans-
portation and Communications.
The following procedure was used to rinse
the drums.
a. A 100-ml sample of the pesticide concen-
trate was taken.
b. The drum was emptied (via suction) using
the loading hose from the sprayer. The
hose was inserted to the lowest point of
the drum which was tilted at a 45 degree
angle.
c. The volume of pesticide formulation re-
maining in the drum was measured.
d. The drum washing nozzle (similar to a
pressure rinsing nozzle) was inserted into
the drum through the large bung hole.
e. For a 205-liter drum, the nozzle was op-
erated for 20-30 seconds, which produced
20-25 liters of rinsate. For a 115-liter
drum, the nozzle was operated for 10-15
seconds, which produced 12-15 liters of
rinsate.
f . A 100-ml sample of rinsate was collected
for analysis.
g- The rinsate was removed using the same
technique as removing the pesticide (step
h. The drum was rinsed (steps 'd-g') two or
three more times.
Hsieh, et al., 1972.
D.P.H. Hsieh, et al., "Decontamination of
Noncombustible Agricultural Pesticide Contain-
ers by Removal of Emulsif iable Parathion," En-
vironmental Science and Toxicology, Vol. 6,
Number 9, (September 1972): pp. 826-829.
211
-------
Appendix A - Triple and Pressure Rinse Procedures
The following procedure was used to deter-
mine the residual formulation in the container.
a. An empty container was weighed.
b. Enough parathion was added to the con-
tainer to completely wet the inner sur-
face.
c. The container was closed, shaken, and
swirled to completely cover the inner
walls.
d. The container was drained until drip-
ping stopped (at least 5 minutes).
e. The container was reweighed or the for-
mulation net volume retention was de-
termined.
f. The residual formulation in the container
was calculated by the difference in weight
or volume or both.
The container was then rinsed according to
the following procedure.
a. The measured retention volume was
added to the container.
Leasure,1978.
J.K. Leasure, Southern Illinois University,
"Triple Rinsed — or Equivalent," Unpublished
report, 1978.
Although this field study was not dated, it
appears to be included in the scope of the South-
ern Illinois University study and is assumed to
have been done in 1978.
The triple rinsing procedure was not speci-
fied, but is assumed to be the same procedure
used in the Southern Illinois report which is:
a. Empty the container and drain for one min-
ute.
b. Fill the container with a volume of water
equivalent to 25% the capacity of the con-
tainer and shake the container.
c. Empty the container and drain it for one
minute.
d. Rinse the container two more times.
e. Collect the rinsate from the first, second, and
third rinses separately and analyze for the
a.i.
b. A volume of washing solvent was added
to the container:
•25 ml for a 125-ml glass bottle;
•75 ml for a 1-gallon jug; and
•150 ml for a 1-gallon flathead steel
drum.
c. Each container was rinsed at least six
times.
The procedure used for the pressure rinsing
is described below.
a. Empty the can into the sprayer tank.
b. As the container empties, insert the jet-spray
nozzle (E-Z Rinse nozzle) into the container
to provide a vent.
212
-------
Pesticide Containers A Report to Congress
c. When the container is empty, activate the
water stream.
d. Rinse the container for 60 seconds, slowly
rotating the nozzle back and forth through
an arc of about 90 degrees.
Peck, 1985.
D. Peck, "The Determination of Residue of
Certain Pesticides after Triple Rinsing," August
1985.
fied. It was estimated that the container
was shaken about 6-12 times. (3)
d.The rinsate was collected and the con-
tainer was drained for 30 seconds after a
steady flow had ceased and after indi-
vidual drops were evident.
e. The rinsing procedure (b-d) was performed
2 more times.
Southern Illinois University, 1978.
Southern Illinois University, Draft of unpub-
The purpose of this lab study was to deter- lished report on pesticide container disposal in
mine the residue of active ingredient following Illinois, August 24,1978.
the use of a triple rinse procedure. The procedure
that was followed was pieced together through
several documents.
The specific residue removal procedure is de-
scribed below.
The study itself does not describe the triple
rinse procedure or protocol followed. The stan-
dard triple rinse procedure at that time was fol-
lowed^!) The standard procedure is defined in
the 1985 Report on the Maine Pesticide Container
Program. (2)
The following is assumed to define the proce-
dure used.
a. Empty the container and drain for one
minute.
b. Fill the container with a volume of water
equivalent to 25% of the capacity of the
container and shake the container.
c. Empty the container and drain it for one
minute.
d. Rinse container two more times.
a. The container was emptied and drained
for 30 seconds after the steady flow of
pesticide formulation had ceased and
after individual drops were evident.
b. A quantity of solvent equal to 10% of the
volume of the container was added.
c. The container was shaken, -agitated, or
rolled vigorously. (No time was speci-
e. Collect the rinsate from the first, second,
and third rinses separately and analyze
for the a.i.
Tiernan, Wright State University, 1990.
T.O. Tiernan, Wright State University, "As-
sessment of Rinsing Procedures for Removing
Pesticides from Containers Used by Agricultural
Applicators," Quarterly Progress Report subrnit-
213
-------
Appendix A - Triple and Pressure Rinse Procedures
submitted to U.S. EPA, Risk Reduction Engi-
neering Laboratory, February 1,1990.
The laboratory triple rinse procedure is de-
scribed below.
a. "Empty the contents of the container
into the receiving spray tank and then
allow the container to drain into the
tank for an additional 30 seconds (if
container has a hollow handle, ensure
that liquid has been drained from this
cavity.)
b. Add a volume of rinse liquid to the
container so that the volume of rinse
liquid equals 1/10 of the capacity of the
container (the rinse liquid is the same
as the liquid which is normally used to
dilute the pesticide.)
c.
Tightly seal the container and agitate it
to force the liquid along the bottom of
the container. (Do this three times.)
d. Tip the sealed container onto its side,
and agitate the container to rinse the
container wall completely. (Do this
three times.)
e. Continue rotating the container until it
is completely inverted, agitate the con-
tainer to rinse the lid and any recesses
in the lid of the top of the container, and
then return the container to an upright
position.
f. Repeat this inverting procedure two
more times.
g. Rotate the container 1/4 of a turn and
repeat the inverting procedure three
times to rinse the next section of the
container wall.
h. Repeat the inverting procedure after ad-
ditional 1/4 rotations to complete the rins-
ing of each quarter of the container side
wall as well as the top and bottom.
i. Empty the rinsate from the container into
the spray tank and then allow the con-
tainer to drain into the tank for an addi-
tional 30 seconds (if container has a hol-
low handle, ensure that liquid has been
drained from this cavity.)
j. Rinse the container two more times using
the procedures described in steps b through
i and add each rinse to the spray tank."
Bags
Braun, et al., 1983.
H.E. Braun, et al., "Efficiency of Water Rins-
ing for the Decontamination of Used Pesticide
Containers," Archives of Environmental Con-
tamination and Toxicology. Vol. 12, (1983): pp.
257-264.
In 1979, three paper bags were included in
the study to determine the efficiency of water
rinsing. The following procedure was used.
a. The bag was emptied by normal field
dispensing practices.
b. The bag was rinsed with one liter of wa-
ter.
c. The bag was rinsed a maximum of five
times.
214
-------
Pesticide Containers - A Report to Congress
Stone Container Corporation, 1990
E. Tytke, Stone Container Corporation, let-
ter to B. Omilinsky, Formulogics, August 7,
1990.
Stone Container Corporation did some pre-
liminary testing on the residue in multiwall
paper bags to provide data to EPA. The proce-
dure used is described below.
d. Drop the bag twice on its bottom end
from a height of 18 inches.
e. Empty the bag and shake it twice while
the bag is inverted.
f. Re-weigh the bag and calculate the net
residue.
a. Fill the bag with the material to be tested.
b. Drop the bag on its end from a height of
18 inches.
c. Lay the bag flat on a pallet.
d. Empty the bag and shake it twice.
e. Collect the product retained in the bag
end (by scraping and scooping).
f. Weigh the retained material.
Union Camp Corporation, 1990
T.T. Allen, Union Camp Corporation, letter
to N. Fitz, U.S. EPA, Office of Pesticide Pro-
grams, October 18,1990.
Union Camp Corporation also did some pre-
liminary testing on the residue in multiwall
paper bags. The following procedure was used.
a. Weigh the empty bag.
b. Fill the bag with the appropriate test ma-
terial (to the designated bag capacity).
c. Clamp the top of the bag closed.
215
-------
Appendix A - Triple and Pressure Rinse Procedures
Endnotes
1. Trask, H., Consultant, personal communica-
tion with U.S. EPA, Office of Pesticide Pro-
grams, March 29,1990.
2. Denny, R., D. McLaughlin, Maine Board of
Pesticide Control, Report on Maine Pesticide
Container Program, 1985.
3. Trask, H., Consultant, personal communica-
tion with U.S. EPA, Office of Pesticide Pro-
grams, March 29,1990.
216
-------
Pesticide Containers - A Report to Congress
Appendix B
Acronyms and Abbreviations
a.i. Active ingredient
AAPCO Association of American Pesticide
Control Officials
ANPRM Ad vance Notice of Proposed Rule-
making
CAAA California Agricultural Aircraft As-
sociation
CDFA California Department of Food and
Agriculture
CPDA Chemical Producers and Distribu-
tors Association
CPSC Consumer Product Safety Commis-
sion
CRP Child-Resistant Packaging
CSMA Chemical Specialties Manufactur-
ers Association
DER Department of Environmental
Regulation
DOT Department of Transportation
ECE Economic Commission for Europe
EMI Equipment Manufacturers Institute
EPA Environmental Protection Agency
FIBC Flexible intermediate bulk con-
tainer
FIFRA Federal Insecticide, Fungicide, and
RodenticideAct
GIF AP Groupement International des As-
sociations Nationales de Fabricants
de Produits Agrochemiques
HDPE High density polyethylene
HMR Hazardous Materials Regulations
I&I Institutional and industrial
IBC Intermediate bulk container
1C AO International Civil Aviation Organ-
zation
IDALS Iowa Department of Agriculture
and Land Stewardship
IFCA Iowa Fertilizer and Chemical As-
sociation
IMDG International Maritime Dangerous
Goods
IMO International Maritime Organiza-
tion
ISSA International Sanitary Supply As-
sociation
LDPE Low density polyethylene
LIP Label improvement program
MACA Midwest Agricultural Chemical
Association
MDA Minnesota Department of Agricul-
ture
MSWLF Municipal solid waste landfill
217
-------
Appendix B - Acronyms and Abbreviations
NACA National Agricultural Chemicals
Association
N ARA National AgriChemical Retailers
Association
NPRM Notice of Proposed Rulemaking
NPT National Pipe Thread
NRC National Response Center
OACA Oregon Agricultural Chemicals
Association
OCM Office of Compliance Monitor-
ing
PR Notice Pesticide Registration Notice
PSSMA Paper Shipping Sack Manufac-
turers Association
RCRA Resource Conservation and Re-
covery Act
RIBCA Rigid Intermediate Bulk Con-
tainer Association
RSPA Research and Special Programs
Administration
SARA Superfund Amendments and
Reauthorization Act
SFIREG State - FIFRA Issues Research and
Evaluation Group
SLA State lead agency
SVR Small volume returnable
UAP United Agri Products
218
-------
Pesticide Containers A Report to Congress
Bibliography
"A New Wave of Plastics Recycling," Chemi-
calweek, May 10,1989, pp. 9-10.
Adachi, D., California Department of Food
and Agriculture, letter to M. Deerhake, Re-
search Triangle Institute, September 6,1989.
Aeroquip Corporation/U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide Pro-
grams, July 12,1990.
"Aerosol Market Keeps Expanding," Chemical-
week, May 10,1989, p. 13.
Agricultural Research Institute, "Improving
On-Target Placement of Pesticides," confer-
ence June 13-15,1988.
Ainsworth, S., CAEN, "Aerosol Product
Innovation Fueled by Public Attitudes, Regu-
lations," April 23,1990.
Allen, T., Union Camp Corp., letter to N. Fitz,
U.S. EPA, Office of Pesticide Programs, Octo-
ber 18,1990.
Allison, S., Monsanto, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, October
25,1990.
Allison, S., Monsanto, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, October
30,1990.
Allison, S., Monsanto, memorandum to T.
Gilding, National Agricultural Chemical
Association, November 26,1990.
American Cyanamid Company, advertise-
ment for Counter Container, 'TSTew Packaging
Eliminates Bags," 1989.
American Cyanamid Company, advertise-
ment for Pursuit herbicide.
American Cyanamid Company, AgriCenter,
Repackage Agreement for Chemicals, Septem-
ber 1,1990.
American Cyanamid Company/Brayton
Chemicals/U.S. EPA, meeting summary, U.S.
EPA, Office of Pesticide Programs, February
28,1990.
219
-------
Bibliography
American Cyanamid Company, brochure for
Counter containers, 1989.
American Packaging Corporation, advertise-
ment for Rotoseal.
American Society for Testing and Materials,
notes on symposium, November 5-6,1986.
American Society for Testing Materials, "Stan-
dard Method of Testing Aerosol Products for
Delivered Mass," 1981.
American Society for Testing Materials, Tenth
Symposium on Pesticide Formulations and
Application Systems, Abstract Booklet, Den-
ver, Colorado, October 25-26,1989.
Anderson, L., Ecolab, facsimile to W.
Holtzman, U.S. EPA, Office of Pesticide Pro-
grams, November 1,1990.
Anderson, L., Ecolab, letter to N. Fitz, U.S.
EPA, Office of Pesticide Programs, September
10,1990.
Archer, T., "Removal of 2,4-Dichlorophe-
noxyacetic Acid (2,4-D) Formulations from
Noncombustible Pesticide Containers," Bulle-
tin of Environmental Contamination and
Toxicology, Vol. 13, No. 1, January 1975, pp.
44-51.
Association of American Pesticide Control
Officials, (Draft) "Model Bulk Pesticide
Rules," 1989.
Bachman, P., Department of Agriculture,
Office of Agronomy Services, letter to P.
Flaherty, U.S. EPA, Office of Compliance
Monitoring, October 12,1990.
Bailey, J., The Dow Chemical Company, letter
to N. Fitz, U.S. EPA, Office of Pesticide Pro-
grams, January 15,1990.
Balek, W., International Sanitary Supply
Association, letter to B. Sterman, Mitchell
Systems Corp., September 7,1990.
Balek, W., International Sanitary Supply
Association, letter to C. O'Connor, Chemical
Producers and Distributors Association, Au-
gust 25,1989.
Balek, W., International Sanitary Supply
Association, letter to R. Denny, U.S. EPA,
Office of Pesticide Programs, August 9,1990.
Balek, W., International Sanitary Supply
Association, letter to S. Kulkarni, Research
Triangle Institute, August 1,1989.
Balek, W., International Sanitary Supply As-
sociation, letter to W. Holtzman, U.S. EPA,
Office of Pesticide Programs, October 25,
1990.
Barbeito, M. and G. Gremillion, "Microbio-
logical Safety Evaluation of an Industrial
Refuse Incinerator," Applied Microbiology, Vol.
16, No. 2, February 1968, pp. 291-295.
Barber, D., NABADA, Association of Con-
tainer Reconditioners, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, June 22,
1989.
Barber, D., NABADA, Association of Con-
tainer Reconditioners, Steel Drums.
Barrie, D., Aeroquip, letter to J. Turner, Re-
search Triangle Institute, August 7,1989.
Barrows, P., FMC, personal communication
with U.S. EPA, Office of Pesticide Programs,
September 13,1990.
Bartenhagen, C., Monsanto, personal commu-
nication with Research Triangle Institute, July
17,1989.
220
-------
Pesticide Containers - A Report to Congress
Bartenhagen, C, Monsanto, personal commu-
nication with U.S. EPA, Office of Pesticide
Programs, March 30,1990.
Bates, J., ""Hazards from the Inadequate/
Improper Labelling and Packaging of
Pesticides," FAO Plant Protection Bulletin, Vol.
26, No. 3,1978, pp. 123-128.
Baxter, R., Bancroft Bag, Inc., letter to N. Fitz,
U.S. EPA, Office of Pesticide Programs, Sep-
tember 4,1990.
Bellinger, R. and J. Christenbury, "Hazardous
Household Chemicals," Pesticide Information
Program, June 1990.
Bellinger, R. and P. Horton, "Properly Rinse
Pesticide Containers," Pesticide Information
Program, August 1990.
Bellinger, R. and P. Horton, 'The South Caro-
lina Pesticide Information Program," Pesticide
Information Program, March 1990.
Bingaman, W., Rohm and Haas Company,
letter to N. Fitz, U.S. EPA, Office of Pesticide
Programs, September 11,1990.
Bingaman, W., Rohm and Haas Company,
letter to N. Fitz, U.S. EPA, Office of Pesticide
Programs, October 23,1990.
Boiling, R., "Multiwall Shipping Sacks: An
Overview and Update," Union Camp A-29
Corporation, undated.
Brandt, E., U.S. EPA, Office of Pesticide Pro-
grams memorandum to R. Kreuger, U.S. EPA,
Office of Pesticide Programs, March 18,1986.
Braun, H., et al., "Efficiency of Water Rinsing
for the Decontamination of Used Pesticide
Containers," Environmental Contamination and
Toxicology, Vol. 12,1983, pp. 257-264.
Brazelton, R. and N. Akesson, American
Society for Testing and Materials, "Principles
of Closed Systems for Handling of Agricul-
tural Pesticides," Pesticide Formulations and
Application Systems, Seventh Vol., ASTM STP
968, G. B. Beestman and D. I. B. Vander
Hooven, (eds.), Philadelphia, 1987, pp. 15-27.
Buckeye International, Inc., "5 Gallon Bag-in-
Box Package," meeting with U.S. EPA, Office
of Pesticide Programs and Formulogics,
October 4,1990.
"Bulk Innovations," Agrichemical Age, August
9,1990.
Buzicky, G., et al., (Draft) "Evaluation of
Improperly Disposed of Pesticide Containers
on Minnesota Farms," FIFRA Enforcement
Special Project prepared for the U.S. EPA,
Region V, October 1990.
Calaba, G., Oregon Department of Environ-
mental Quality, personal communication with
U.S. EPA, Office of Pesticide Programs, Sep-
tember 20,1990.
Calderoni, P., "Pesticide Industry Overview,"
Chemical Economics Handbook Marketing
Research Report, No. 573.1000 A, June 1988.
Chase, L., Paper Systems, Inc., informational
memorandum, October 18,1990.
Chase, L., Paper Systems, Inc., letter to R.
Denny, U.S. EPA, Office of Pesticide Pro-
grams, August 24,1990.
Chase, W., Jr., Chevron Chemical Company,
personal communication with U.S. EPA,
Office of Pesticide Programs, November 16,
1990.
Chemical Packaging Committee/U.S. EPA,
meeting summary, U.S. EPA, Office of Pesti-
cide Programs, March 14,1990.
221
-------
Bibliography
Chemical Packaging Committee/Ecolab/
Rieke Corporation/U.S. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Programs,
"Chemical Shippers Get Ready for New
Rules," Chemical-week, July 25,1990, pp. 28-29.
Chemical Specialties Manufacturers Associa-
tion, "Aerosol Pressurized Products Survey
United States 1988."
Chemical Specialties Manufacturers Associa-
tion, "Checking Pre-packaged Commodities
(Aerosols) for Delivered Weight of Contents,"
April 1981.
Chemical Specialties Manufacturers Associa-
tion, 38th Annual Aerosol Pressurized Prod-
ucts Survey - United States, 1988.
Ciba-Geigy/Research Triangle Institute,
meeting summary, Research Triangle Insti-
tute, July 28,1989.
Ciba-Geigy/Research Triangle Institute,
meeting summary, Research Triangle Insti-
tute, June 28,1989.
Ciba-Geigy, "Study of Exposure Using Farm-
Pak System," 1988.
Ciba-Geigy/U.S. EPA, meeting summary,
U.S. EPA, Office of Pesticide Programs,
August 10,1990.
Cin-Made Corporation, advertisement for
child resistant closures.
Cin-Made Corporation, advertisement for
packaging.
Clegern, R., DOD, letter to C Northeim,
Research Triangle Institute, October 24,1989.
Container Management Task Group, National
Agricultural Chemical Association, meeting
with U.S. EPA, Office of Pesticide Programs,
October 16,1990.
"Convenience and Safety Create Prepack Pref-
erence - Iowa Applicators Find Old Friends in
New Packages," Custom Applicator, February
1988, pp. 48-49.
Cowell, J., et al., American Chemical Society,
"Ways to Reduce Applicator Exposure to Pes-
ticides," 1989.
Crawford, G., Steel Can Recycling Institute,
letter to S. Kulkarni, Research Triangle Insti-
tute, July 21,1989.
Dana Duxbury and Associates, "National List-
ing of Household Hazardous Waste Collec-
tion Programs 1981-1988," prepared for Tufts
University, October 20,1988.
Dana Duxbury and Associates, "Summary of
the Third National Conference on Household
Hazardous Waste," Boston, Massachusetts,
November 2-4,1988.
"Dealers Can Build Low-cost Rinse Pad,"
Custom Applicator, p. 31, December 1990.
Deignan, P., Rieke Corporation, letter to N.
Fitz, U.S. EPA, Office of Pesticide Programs,
June 13,1990.
Denny, R. and D. McLaughlin, Maine Board
of Pesticide Control, Report on Maine Pesti-
cide Container Program, 1985.
Denton, Trip Report to local farmer's ex-
change and Ronnie Harrison's farm, May 17,
1989.
DiFazio, J., Chemical Specialties Manufactur-
ers Association, facsimile transmission to U.S.
EPA, Office of Pesticide Programs, November
30,1990.
Difazio, J., Chemical Specialties Manufactur-
ers Association, personal communication with
U.S. EPA, Office of Pesticide Programs, May
23,1990.
222
-------
Pesticide Containers A Report to Congress
Donaldson, G., Wilbur-Ellis Company, letter
to J. Jensen, U.S. EPA, Office of Pesticide Pro-
grams, October 29,1990.
Drapala, P., "Disposal Project Gets High
Marks," Farm Chemicals, November 1989, pp.
40-43.
"Drum Reconditioners," Environmental Infor-
mation Digest, December 1989.
Dull, L., Ciba-Geigy, letter to C. Northeim,
Research Triangle Institute, undated.
Dwinell, S., Florida Department of Environ-
mental Regulations, letter to R. Denny, U.S.
EPA, Office of Pesticide Programs, August 8,
1990.
Dysart, J., "As Maine Goes...Container Pro-
gram Not Perfect," Custom Applicator, Febru-
ary 1988, pp. 124-125.
Famili, A., Air Products and Chemicals, Inc.,
letter to T. Bone, U.S. EPA, Office of Pesticide
Programs, November 14,1990.
Farm Chemicals Committee, Wheat Grower,
Vol. 10, No. 3, March 1987, pp. 39-40.
Farrell, R., Wilbur-Ellis Company, letter to W.
Holtzman, U.S. EPA, Office of Pesticide Pro-
grams, October 26,1990.
Finck, C., "At Last! A Safe System for Han-
dling Insecticides," Farm Journal, November
1989.
"First Steps Toward End of Disposal Chemi-
cal Jugs," Successful Farming, November 1988,
p. 18.
Fitz, N., U.S. EPA, Office of Pesticide Pro-
grams, letter to M. Gindling, The Davies-
Young Company, January 25,1990.
Fitz, N., U.S. EPA, Office of Pesticide Pro-
grams, memorandum to R. Denny, U.S. EPA,
Office of Pesticide Programs, November 30,
1989.
Flaherty, P., U.S. EPA, Office of Compliance
Monitoring, memorandum to L. Alderman,
U.S. EPA, Region VII, May 10,1990.
Formulogics, facsimile to U.S. EPA, Office of
Pesticide Programs, June 12,1990.
Formulogics, facsimile to W. Holtzman, U.S.
EPA, Office of Pesticide Programs, November
9,1990.
Frank, R., et al., "A System for Rinsing Herbi-
cide Residues from Drums During Highway
Right-of-Way Spray Operations," Bulletin of
Environmental Contamination Toxicology, Vol.
39,1987, pp. 680-687.
Freese, B., "Better than Disposables," Success-
ful Farming, p. 34, February 1988.
Frieberg, D., et al., Proposal for an EPA Pilot
Project on the "56 Gallon" Rule, April 30,
1990.
Frieberg, D., Iowa Fertilizer and Chemical
Association, "Interim Report on Iowa Pesti-
cide Container Recycling Project," 1990.
Gaddy, K., Swedish Packaging Institute, letter
to J. Turner, Research Triangle Institute,
August 15,1989.
Garnett, R., Wisdom Agricultural Ltd., letter
to J. Turner, Research Triangle Institute, May
25,1989.
Garnett, R., Wisdom Agricultural Ltd., letter
to N. Fitz, U.S. EPA, Office of Pesticide Pro-
grams, January 14,1991.
223
-------
Bibliography
Gehlbach, S. and W. Williams, "Pesticide
Containers: Their Contribution to Poisoning,"
Environmental Health, Vol. 30, January 1975,
pp. 44-51.
Geiger, B., "Direct Injection: Applying Pesti-
cides with Precision," Crops and Soils
Magazine, Vol. 5, No. 5, February 1987.
Gilding, T., National Agricultural Chemical
Association, facsimile to U.S. EPA, Office of
Pesticide Programs, November 15,1990.
Gilding, T., National Agricultural Chemical
Association, letter to C. Northeim, Research
Triangle Institute, July 27,1989.
Gilding, T., National Agricultural Chemical
Association, letter to C. Northeim, Research
Triangle Institute, August 18,1989.
Gilding, T., National Agricultural Chemical
Association, letter to R. Denny, U.S. EPA,
Office of Pesticide Programs, April 18,1989.
Gilding, T., National Agricultural Chemical
Association, letter to R. Denny, U.S. EPA,
Office of Pesticide Programs, October 12,1989.
Gilding, T., National Agricultural Chemical
Association, letter to R. Denny and N. Fitz,
U.S. EPA, Office of Pesticide Programs, No-
vember 26,1990.
Gilding, T., National Agricultural Chemical
Association, letter to principal contacts of
member companies, August 17,1988.
Gilding, T., National Agricultural Chemical
Association, Survey of Pesticide Applicators
on Container Issues, Improving on Target
Placement of Pesticide, ISBN No. 0-944919-02-
2, Conference Sponsored by the Agricultural
Research Institute, Bethesda, MD, June 13-15,
1988.
Goodall, D., Goodall Design PTY, Ltd., letter
to N. Fitz, U.S. EPA, Office of Pesticide Pro-
grams, January 10,1991.
Goodman, S., et al., Guide to Hazardous Prod-
ucts Around the Home, 2nd ed., Missouri
Household Hazardous Waste Project, 1989.
Gould, D., Union Carbide Corporation, letter
to N. Fitz, U.S. EPA, Office of Pesticide Pro-
grams, July 6,1990.
Groupement International des Associations
Nationales de Fabricants de Produits Agro-
chemques, "Packaging Pesticide Label and
Container Design Panel, Guidelines for the
Design of Containers for Liquid Pesticide,"
1990.
Groupement International des Associations
Nationales de Fabricants de Produits Agro-
chemques, Packaging Task Force, "Require-
ments Profile/Design Criteria for Plastic Con-
tainers of Liquid Agrochemicals," September
14,1990.
"Guidelines for the Packaging and Storage of
Pesticides," FAO Plant Protection Bulletin, Vol.
31, No. 2,1983, pp. 63-69.
Hanson, R., Minnesota Department of Agri-
culture, Container Collection Forms, to N.
Fitz, U.S. EPA, Office of Pesticide Programs,
August 10,1990.
Hanson, R., Minnesota Department of Agri-
culture, facsimile to N. Fitz, U.S. EPA, Office
of Pesticide Programs, January 9,1991.
Hanson, R., Minnesota Department of Agri-
culture, letter to T. Bone, U.S. EPA, Office of
Pesticide Programs, October 4,1990.
Hanson, R., Minnesota Department of Agri-
culture, letter to T. Bone, U.S. EPA, Office of
Pesticide Programs, November 1,1990.
224
-------
Pesticide Containers - A Report to Congress
Hartley, G., Evaporation of Pesticides, Pesti-
cidal Formulations Research, Symposium co-
sponsored by Division of Agricultural and
Food Chemistry and the Division of Colloid
and Surface Chemistry at the 153rd National
Meeting, Miami Beach, Florida, April 13-14,
1967, Advances in Chemistry 86, American
Chemical Society, 1969.
Hawley, G., The Condensed Chemical Dictionary,
Tenth Edition.
Hester, J. and R. Farrell, estimated number of
bulk sites, letter to M. Deerhake, Research
Triangle Institute, October 19,1989.
"Household Hazardous Waste: When A Little
Bit Means A Lot," Health and Environment
Digest, Vol. 2, No. 8, September 1988.
Houtsma, J., "Low-Cost Mixing Pad Reduces
Spill Danger," The Farmer, January 20,1990.
"How Hazardous is Household Trash,"
Chemecology, undated.
Hsieh, D., et al., "Decontamination of Non-
combustible Agricultural Pesticide Containers
by Removal of Emulsifiable Parathion," Envi-
ronmental Science and Toxicology, Vol. 6, No. 9,
September 1972, pp. 826-829.
Illinois Department of Agriculture, Division
of Plant Industries and Consumer Services,
"Containment Rules for Agrichemical Facili-
ties," 1989.
Illinois Institute of Technology Research Insti-
tute, "Determination of Residual Product in
Pesticide Aerosol Spray Cans."
"Industrial and Hazardous Waste Manage-
ment," Environmental Information Digest,
December 1989.
"Inerts Must Meet One-in-a-Million Test
Under Substitute Pesticide Bill," Pesticide and
Toxic Chemical News, p. 13, July 11,1990.
Institute of Packaging Professionals, Survey of
Container Closures, June 22,1990.
Institute of Scrap Recycling Industries, Inc.,
"What is Recycling? Why Do Community
Recycling Programs Sometimes Fail?"
International Sanitary Supply Association/
Research Triangle Institute/U.S. EPA, meet-
ing summary, Research Triangle Institute,
July 24,1989.
Jacobs, W., Agricultural Research Institute,
"Government Views of Container/Closed
System Issues, Improving On-Target Place-
ment of Pesticides," 1989, pp. 89-103.
Jacobs, W., American Society for Testing and
Materials, "Risk Reduction Through the Use
of Closed Systems: An Attainable Goal?"
Pesticide Formulations and Application Systems,
Seventh Vol., ASTM STP 968, G. B. Beestman
and D. I. B. Vander Hooven, (eds.), Philadel-
phia, 1987, pp. 47-55.
Jacobs, W., "Closed Systems for Mixing and
Loading, Determination and Assessment of
Pesticide Exposure," Proceedings of a Work-
ing Conference, Hershey, PA, October 29-31,
1980, M. Siewierski (ed.), Elsevier Publishing,
1984.
Johnson, H., Rhone-Poulenc, letter to M. Deer-
hake, Research Triangle Institute, June 28,
1989.
Johnson, K., "Getting A Handle on Container
Disposal," Farm Industry News, February 1990.
225
-------
Bibliography
Johnson, Mv "DOT Shipping Regulations for
Aerosols," Aerosol Age, pp.28-34, July 1990.
Johnson, M., "DOT Shipping Regulations for
Aerosols," Aerosol Age, pp. 38-45, September
1990.
Jones, P., "Pesticide Packaging: The Manufac-
turers Respond," Golf Course Management,
April 1989.
Justmann, T., American Cyanamid, personal
communication with U.S. EPA, Office of Pesti-
cide Programs, September 24,1990.
Kanaak, J., et al., "Safety Effectiveness of
Closed-Transfer, Mixing, Loading, and
Application Equipment in Preventing Expo-
sure to Pesticides," Environmental Contamina-
tion and Toxicology, July 8,1980.
Kelleher, K., Houston County Recycling Coor-
dinator, letter to T. Bone, U.S. EPA, Office of
Pesticide Programs, October 24,1990.
Kennedy, M., et al., "Chemical and Thermal
Aspects of Pesticide Disposal," Journal of Envi-
ronmental Quality, Vol. 1,1972, pp. 63-65.
Kennedy, M., Summary of a research paper,
"Chemical and Thermal Means of Disposal of
Waste Pesticides and Pesticide Containers,"
presented before the President's Cabinet
Committee on the Environment; working
group on pesticides, July 7,1971.
Kleenpour International, advertisement for
Kleenpour.
Korzun, E. et al., "The Impact of Increased
Recycle Rates on Markets in Florida," JAPCA,
Vol. 39, No. 12, December 1989, pp. 1,544-
1,548.
Krause, R., The Dow Chemical Company,
letter to C. Richie, The Dow Chemical Com-
pany, April 7,1989.
Krygsman, A., Troy Chemical Corporation,
personal communication to U.S. EPA, Office
of Pesticide Programs, November 17,1990.
Kulkarni, S., Research Triangle Institute, letter
to D. Oberacker, U.S. EPA, Risk Reduction
Engineering Laboratory, October 10,1989.
Kulkarni, S., Research Triangle Institute, letter
to J. Tommen, First Trust Bank Farm Manage-
ment Department, July 19,1989.
Lamberton, J., et al., "Pesticide Container
Decontamination by Aqueous Wash
Procedures," Bulletin of Environmental Con-
tamination and Toxicology, Vol. 16, No. 3,1976,
pp. 528-535.
Lanners, B., Wilbur-Ellis Company, letter to J.
Hester, Brayton Chemical, July 24,1990.
Leasure, J., 'Triple Rinsed — or Equivalent,"
Southern Illinois University, Unpublished
Report, 1978.
Leaversuch, R., "HOPE Recycling: It's a Big-
Volume Opportunity Waiting to Happen,"
Modern Plastics, August 1986, pp. 44-47.
Lester, M., International Group of National
Associations of Agrichemical Products, letter
to J. Jensen, U.S. EPA, Office of Pesticide
Programs, February 8,1989.
Liebert, R., "Household Hazardous Materials
and Waste: Public Education, Participation in
Collection Drives, and Amounts in Homes,"
University of Illinois, Survey Research Labo-
ratory, prepared for Hazardous Waste Re-
search and Information Center, Illinois State
Water Survey Division, September 1988.
Linak, W., et al., "Chemical and Biological
Characterization of Products of Incomplete
Combustion from the Simulated Field Burn-
ing of Agricultural Plastic," JAPCA, Vol. 39,
No. 6,1989, p. 836.
226
-------
Pesticide Containers - A Report to Congress
Lindsay, Dv Formulogics, letter to N. Fitz,
U.S. EPA, Office of Pesticide Programs, May
22,1990.
Lindsay, D., Formulogics, "Rinsing Proce-
dures," September 7,1990.
Loughnan, J., Kleenpour, letter to J. Turner,
Research Triangle Institute, August 10,1989.
Loughnan, J., Kleenpour, letter to J. Turner,
Research Triangle Institute, August 21,1989.
Lounsbury, B., Consultant, (Draft) "State of
the States: Pesticide Containers," October 29,
1990.
Lounsbury, B., Consultant, (Draft) State of the
States: Pesticide Containers, November 29,
1990.
Lounsbury, B., Consultant, personal commu-
nication with U.S. EPA, Office of Pesticide
Programs, November 26,1990.
Lynch, K., Wilbur-Ellis, personal communica-
tion with U.S. EPA, Office of Pesticide Pro-
grams, November 1,1990.
Maritz, J., Maritz Marketing Research Inc.,
facsimile to P. Overby, February 9,1990.
Marketing Research, Inc., to obtain data on
pesticide containers, February 3,1990.
McCarty, R., Mississippi Department of Agri-
culture and Commerce, personal communi-
cation with U.S. EPA, Office of Pesticide
Programs, October 23,1990.
McClelland, W., North Carolina Department
of Agriculture, "A Study of Pesticide Con-
tainer Sites in North Carolina (1981-1983),"
July 18,1983.
McCormick, E., GSX, letter to C. Northeim,
Research Triangle Institute, June 2,1989.
McGreevy, J., American Society for Testing
and Materials, "Package Development from
the Pesticide Industry Viewpoint," Pesticide
Formulations and Application Systems: Sec-
ond Conference, ASTM STP 795,1983, pp. 3-6.
McKinley, J., "Alberta Pesticide Container
Collection Program," Pollution Technology
Review, Vol. 148,1988, pp. 112-113.
Megargle, W., FMC, personal communication
with Research Triangle Institute, June 9,1989.
Mergen, J., 'The Illinois Farm Bureau Pesti-
cide Can Recycling Project 1979 - 1982," June
3,1983.
Micromatic/DowElanco/U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide Pro-
grams, September 25,1990.
Micromatic, informational brochure "Closed
System Technology."
Midwest Agricultural Chemicals Association,
"Manufacturer Specification and User Guide-
lines for Portable Agri-Chemical Tanks,"
December 1986.
Midwest Agricultural Chemicals Association,
"Pesticide Container Management Reduction
of Residues: An Agricultural Community's
View."
Miles, J., et al., "Assessment of Hazards Asso-
ciated with Pesticide Container Disposal and
of Rinsing Procedures as a Means of Enabling
Disposal of Pesticide Containers in Sanitary
Landfills," Journal of Environmental Science and
Health, Vol. B18(3), 1983, pp. 305-315.
227
-------
Bibliography
Mills, T., California Agricultural Aircraft
Association, "Reusable Containers Are 'One
Way Out'," On the Deck, November 1987, pp.
12-15.
"Minibulk: Small Tanks, Big Benefits," Custom
Applicator, pp. 86-88, March 1990.
Minnesota Department of Agriculture, "Bulk
Agrichemical Storage Facility Permit
Application(s)," 1989.
Minnesota Department of Agriculture, "Bulk
Pesticide Storage," Chapter 1505.3010, Sub-
part 2.
Minnesota Department of Agriculture, "Min-
nesota Empty Container Disposal Report,"
March 1988.
Minnesota Department of Agriculture/U.S.
EPA, meeting summary, U.S. EPA, Office of
Pesticide Programs, August 3,1990.
Mississippi Collection Program, "Rinsing,
Collection, and Disposal of Empty Pesticide
Containers," 1990.
Mississippi Department of Agriculture and
Commerce, "Pesticide Container Rinsing,
Collection and Recycling Demonstration
Project."
Molvig, D., "Hazardous Waste: Don't Keep It
Down on the Farm," University of Wisconsin,
Agricultural Bulletin Building, Madison,
Wisconsin, 1982.
Monsanto Agricultural Company, "Shuttle
Annual Maintenance and Storage," video, 1988.
Morelli, G., Central Can Corporation, per-
sonal communication with U.S. EPA, Office of
Pesticide Programs, January 24,1991.
Munn, A., North American Packaging Corpora-
tion, letter to N. Fitz, U.S. EPA, Office of Pesti-
cide Programs, October 9,1990.
Myrick, C, National AgriChemical Retailers
Association, letter to U.S. EPA, Office of
Pesticide Programs, October 18,1989.
Myrick, C., National AgriChemical Retailers
Association, letter to National Agricultural
Chemical Association Container Committee,
January 11,1990.
Nadaskay, R., International Paper Company,
letter to N. Fitz, U.S. EPA, Office of Pesticide
Programs, September 24,1990.
National Agricultural Chemicals Association/
American Association of Pesticide Control
Officials, meeting summary, U.S. EPA., Office
of Pesticide Programs, March 7,1990.
National Agricultural Chemical Association,
Board of Directors, Container Management
Goals, February 21,1989.
National Agricultural Chemical Association,
"Empty Container Disposal: Safe Practices for
Agricultural Chemical Users," 1986,1990
reprint.
National Agricultural Chemicals Association/
U.S. EPA, meeting summary, U.S. EPA,
Office of Pesticide Programs, October 16,
1990.
National Fertilizer Solutions Association, On-
Site Product Containment Guidelines for Fluid
Fertilizers and Agrichemicals, 2nd ed., Decem-
ber 1988.
National Response Center data, U.S. Coast
Guard, 1985-1989.
Nickell, L., "Plant Growth Regulators: Con-
trolling Biological Behavior with Chemicals,"
Chemical and Engineering News, October 9,
1978, pp. 18-34.
228
-------
Pesticide Containers A Report to Congress
Nixon, G., "Container Recycling: Mississippi
Program is Industry First," Custom
Applicator, Vol. 20, No. 9, December 1990,
pp. 14-22.
Nixon, G., "Illinois Dealer Modifies to Protect
Environment," Customer Applicator, December
1990, pp. 6-10.
Nixon, G., "Recycling Pesticide Containers
Catches On in Other States," Custom
Applicator, Vol. 20, No. 9, December 1990, pp.
18-22.
Noyes, Rv "Modular Concrete Chemcial Han-
dling Pad Facility," Paper No. AA88-004, Pre-
sented at 1988 NAAA/ASAE Joint Technical
Session, Las Vegas, Nevada, December 5,1988.
Ogg, N., R. Bellinger, and H. Seabrook, "Pes-
ticide Disposal," Pesticide Information Program,
September 1989.
Omilinsky, B., and D. Lindsay, Formulogics,
Report to U.S. EPA, Office of Pesticide Pro-
grams, May 15,1990.
Omilinsky, B., Formulogics, letter to N. Fitz,
U.S. EPA, Office of Pesticide Programs, May
1990.
Omilinsky, B., Formulogics, letter to N. Fitz,
U.S. EPA, Office of Pesticide Programs, July
26,1990.
"On-the-Spot Studies Lead to Safe Packaging
of Pesticides," Packaging, July 1985, pp.64-66.
Overby, P., Research Triangle Institute, letter
to various state, industry, and research con-
tacts, February 3-23,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with A. Spalt, Agricul-
tural Resources Center, to obtain information
on the use of pesticide containers, February
16,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with A. Vogt, Ciba-
Giegy, to obtain information on the use of
pesticide containers, February 7,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with B. McMullen,
North Carolina Department of Agriculture, to
obtain information on the use of pesticide
containers, February 5,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with D. Martin, to
obtain information on the use of pesticide
containers, February 7,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with D. Paulson, Mar-
keting and Associates, to obtain information
on the use of pesticide containers, February
23,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with E. Umstead, Agri-
cultural Resources Center, to obtain informa-
tion on the use of pesticide containers, Febru-
ary 9,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with G. Hatcher and
Doan, to obtain information on the use of
pesticide containers, February 7,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with J. Fieldman, Na-
tional Coalition Against the Misuse of Pesti-
cides, to obtain information on the use of
pesticide containers, February 9,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with J. King, Maritz
Marketing Research, Inc., to obtain data on
pesticide containers, February 3,1990.
229
-------
Bibliography
Overby, P., Research Triangle Institute, per-
sonal communication with J. Wilkin, Market-
ing and Associates, to obtain information on
the use of pesticide containers, February 9,
1990.
Overby, P., Research Triangle Institute, per-
sonal communication with K. Machem, Rock-
wood, to obtain information on the use of
pesticide containers, February 7,1990.
Overby, P., Research Triangle Institute, per-
sonal communication with M. Diener, Diener
and Associates, Inc., to obtain information on
the use of pesticide containers, February 7,
1990.
Owen, G., 'Tut Pesticide Containers in Their
Place," Soybean Digest, February 1988.
Packaging Institute International, Inc., Glos-
sary of Packaging Terms, 6th edition, 1988.
Packaging Research International, Inc., The
Chemical Packaging Review, May/June 1990.
Packaging Research International, Inc., The
Chemical Packaging Review, July/August 1990.
Packaging Research International, Inc., The
Chemical Packaging Review, September/Octo-
ber 1990.
Paper Shipping Sack Manufacturers Associa-
tion/Formulogics/U.S. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Pro-
grams, August 29,1990.
Paper Shipping Sack Manufacturers Associa-
tion/Formulogics/U.S. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Programs,
August 28,1990.
Parker, C, "Appropriate Herbicide Formula-
tion and Packaging for Smallholder Tropical
Farmers Practicing No-tillage," proceedings
of symposium held in Monrovia, Liberia,
sponsored by the West African Weed Science
Society and the International Weed Science
Society, August 6-7,1981.
Paulson, D., Jr. and F. May, National Agricul-
tural Chemical Association Container Man-
agement Task Group, "Empty Plastic Pesti-
cide Container Residue Study."
Peck, D., "The Determination of Residue of
Certain Pesticides After Triple Rinsing,"
August 1985.
Peckham, J., State of Minnesota, Department
of Agriculture, Agronomy Services Division,
letter to N. Fitz, U.S. EPA, Office of Pesticide
Programs, February 8,1990.
"Pesticide Tax Urged to Pay for Regulation
Program," Durham Morning Herald, February
7,1990.
PolyProcessing Company, "Innovative Solu-
tions to Chemical Storage and Handling
Needs."
PolyProcessing Company, "Standards of
Manufacture of High Density Crosslinked
Polyethylene Upright Storage Tanks."
PolyProcessing Company, 'Tank Installation
and Use Instructions."
PolyProcessing Company, "Transtore Tanks,"
June 1989.
PolyProcessing Company/U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide Pro-
grams, November 13,1990.
230
-------
Pesticide Containers A Report to Congress
Rathje, Wv et al., "A Characterization of
Hazardous Material in Household Solid
Waste," The Garbage Project, University of
Arizona, September 5,1986.
Rathje, W., et al., "Characterization of House-
hold Hazardous Waste from Marin County,
California, and New Orleans, Louisiana,"
prepared for U.S. EPA, Environmental Moni-
toring Systems Laboratory, Cooperative
Agreement No. CR-813151-01-0, August 1987.
Reike, E., Reike Corporation, letter to N. Fitz,
U.S EPA, Office of Pesticide Programs, Octo-
ber 4,1990.
Research Triangle Institute, 1989, Draft Pesti-
cide Container Design Impact Analysis; Stan-
dards for Pesticide Bulk Storage and Transfer,
September 1989.
Research Triangle Institute, 1989, Trip Report
to Ahoskie, North Carolina, June 7,1989.
Research Triangle Institute, 1989, Trip Report
to Aulander, North Carolina, June 7,1989.
Research Triangle Institute, 1989, Trip Report
to Corcoran, California, July 17,1989.
Research Triangle Institute, 1989, Trip Report
to Iowa, May 17,1989.
Research Triangle Institute, 1989, Trip Report
to Portland and Umatilla, Oregon, July 11-14,
1989.
Research Triangle Institute, 1989, Trip Report
to Rosemead, North Carolina, June 7,1989.
Research Triangle Institute, 1989, Trip Report
to Tennessee, Arkansas, Mississippi, July 6-7,
1989.
Research Triangle Institute, 1989, Trip Report
to Windsor, North Carolina, June 8,1989.
Rhodiagri-Littorale, advertisement for Sumis-
tar, "Plastic Packaging for Liquids/'
Ricks, T., Service and Supply Co-op, personal
communication with the U.S. EPA, Office of
Pesticide Programs, November 1, 1990.
Rigid Intermediate Bulk Container Associa-
tion/U.S. EPA, meeting summary, U.S. EPA,
Office of Pesticide Programs, May 18,1990.
Ritter, J., "Pesticide Packaging: New Trends
for the '90s," The Farmer, January 20,1990.
Rohm and Haas, KATHON WT, "Cooling
Tower, Air Washer and Papermill Slimicide,"
October 1986.
Rohm and Haas, KATHON 893MW, "Metal-
working Fluid Fungicide," March 1988.work-
ing Fluid Fungicide," March 1988.
Rousseau, G., The Association for Manufac-
turers of Rigid Intermediate Bulk Containers,
letter to R. Denny, U.S. EPA, Office of Pesti-
cide Programs, April 12,1990.
Rousseau, G., The Association for Manufac-
turers of Rigid Intermediate Bulk Containers,
personal communication with U.S. EPA,
Office of Pesticide Programs, January 5,1990.
Rutz, R., California Department of Food and
Agriculture, "Closed Systems: Pesticide Safety
Information Series A-3," November 7,1988.
Rutz, R., California Department of Food and
Agriculture, "Pesticide Storage, Transporta-
tion and Disposal: Pesticide Information Se-
ries A-2," November 16,1988.
Sansburn, J., PolyProcessing Company, per-
sonal communication with U.S. EPA, Office of
Pesticide Programs, September 10,1990.
231
-------
Bibliography
Schwalbe, K., "Farm Chemical Packaging:
What the Future Holds," The Wheat Grower,
December 1986 - January 1987, pp. 12-13.
Science Products/U.S. EPA, meeting sum-
mary, U.S. EPA, Office of Pesticide Programs,
September 25,1990.
SIFREG meeting, October 4,1989, "Draft:
AAPCO Model Bulk Pesticide Rules."
Singh, S., et al., "Vibration Simulation of
Portable Insecticide Tanks," Paper No. 87-
6528, American Society of Agricultural Engi-
neers, 1987.
Skolnick, H., "New Definitions: The Steel
Drum in the 1990s," Hazardous Waste
Management, November/December 1988.
Snyder Industries, Inc. U.S. EPA, meeting
summary, U.S. EPA, Office of Pesticide Pro-
grams, October 1,1990.
Soilserv,Inc./Wilbur-Ellis/Formulogics/U.S.
EPA, meeting summary, U.S. EPA, Office of
Pesticide Programs, September 18,1990.
Sommers, C, "Easy to Use, Hard to Defuse —
Plastic Jugs," Successful Farming Weed and
Insect Control Issue, January 1986, p. 22-R.
South Dakota Department of Agriculture,
South Dakota Farm Survey, 1988.
Southern Illinois University, Draft of unpub-
lished report on pesticide container disposal
in Illinois, August 24,1978.
Steel Can Recycling Institute, "Recyclable
Steel Cans: An Integral Part of Your Curbside
Recycling Program," 1990.
Stephens, J., "Expect New and Tougher Pesti-
cide Application Rules," Successful Farming
Planting Issue, March 1986, p. 10-L.
Stickle, W., Chemical Producers and Distribu-
tors Association, letter to J. Turner, Research
Triangle Institute, (Attachment: Chemical
Specialties Manufacturers Association Master
Response Form), September 1,1989.
Stickle, W., Chemical Producers and Distribu-
tors Association, letter to P. Flaherty, U.S.
EPA, Policy and Grants Division, April 10,
1990.
Stojanovic, B., et al., "Edaphic Aspects of the
Disposal of Unused Pesticides, Pesticide
Wastes, and Pesticide Containers," Environ-
mental Science and Technology, Vol. 6,1972, pp.
826-829.
Stone Container Corporation, The Bag Packag-
ing Workshop, 1990, pp. 126-127.
Strain, G. and D. Freshwater, "Options for
Managing Pesticide Container Disposal in Ag-
riculture," Research Bulletin No. 85-2, Depart-
ment of Agricultural Economics and Farm
Management, University of Manitoba, Win-
nipeg, Manitoba, July 1985.
Tapas, J., Sandoz, personal communication
with U.S. EPA, Office of Pesticide Programs,
August 17,1990.
Taylor, A., "Post-Application Volatilization of
Pesticides Under Field Conditions," JAPCA,
Vol. 28, No. 9, September 1978.
Taylor, A., Illinois Environmental Protection
Agency, letter to R. Denny, U.S. EPA, Office
of Pesticide Programs, June 12,1990.
Taylor, K., Western Agricultural Chemicals
Association, letter to K. Daum, Research Tri-
angle Institute, July 12,1989.
Taylor, A., Illinois Environmental Protection
Agency, personal communication with U.S.
EPA, Office of Pesticide Programs, December
3,1990.
232
-------
Pesticide Containers A Report to Congress
Taylor, O., "New Life for Old Jugs," Soybean
Digest, December 1989.
'Test Run on Agtabs," Farm Chemical, 1990.
The Davies-Young Company, "Another Buck-
eye Breakthrough," informational brochure,
1990.
Thomas, T., "Agricultural Chemicals: An
Industry of Change," Farm Chemicals, Vol. 152,
No. 1, January 1989.
Tiernan, T., Wright State University, "Assess-
ment of Rinsing Procedures for Removing
Pesticides from Containers Used by Agricul-
tural Applicators," Quarterly Progress Report
submitted to U.S. EPA, Risk Reduction Engi-
neering Laboratory, February 1,1990.
Tonneson, L., "Low Risk Rate Cutting," The
Farmer, January 20,1990.
Trask, H., "Are Incinerators the Answer?,"
Farm Chemicals, July 1987.
Trask, H. "Container Management a Year
Later," Farm Chemicals, May 1987.
Trask, H., "Handling Pesticide Waste," Farm
Chemicals, August 1987.
Trask, H., memorandum to N. Fitz, U.S. EPA,
Office of Pesticide Programs, June 4,1990.
Trask, H., "Our Waste Management Record
Needs Upgraded," Farm Chemicals, October
1987.
Trask, H., 'The Pesticide Waste Workshops,"
Farm Chemicals, June 1987.
Trask, H. "What is EPA Up to Nowadays?,"
Farm Chemicals, September 1987.
TRW Inc., Pesticide Manufacturing Overview,
Prepared for U.S. EPA: IERL, EPA Contract
No. 68-02-3174, undated.
Turner, ]., Research Triangle Institute, memo-
randum to J. Jensen, U.S. EPA, Office of
Pesticides Program, March 15,1990.
Turner, J., Research Triangle Institute, sum-
mary of meeting with R. Kramer, Armed
Forces Pesticide Management Board, Septem-
ber 13,1990.
Tytke, E., Stone Container Corporation, letter
to B. Omilinsky, Formulogics, August 7,1990.
Tytke, E., Stone Container Corporation, letter
to N. Fitz, U.S. EPA, Office of Pesticide Pro-
grams, October 9,1990.
United Nations, Recommendations on the Trans-
port of Dangerous Goods, sixth revised edition,
New York, 1989, p. 366.
Urbain, C, "No-touch Chemical Handling
System," Farm Journal, mid-February 1985,
p. 16D.
U.S. EPA and MITRE Corporation, Metric
Division, "The Supply and Use Patterns of
Disinfectants and Sanitizers at Selected Sites,"
January 1983.
U.S. EPA, "Methods to Manage and Control
Plastic Wastes: A report to Congress," Febru-
ary 1990.
U.S. EPA, National Enforcement Investiga-
tions Center, "Contaminant Screening Guide-
lines," 1990.
U.S. EPA, Office of Pesticide Programs,
Fourth Open Container Meeting (August 2,
1990), meeting summary and minutes, Au-
gust 29,1990.
233
-------
Bibliography
U.S. EPA, Office of Compliance Monitoring,
"Bulk Pesticide Enforcement Policy," 1977.
U.S. EPA, Office of Compliance Monitoring,
"Questions and Answers on the Bulk Pesticide
Enforcement Policy," 1985.
U.S. EPA, Office of Pesticide Programs,
Fourth Open Container Meeting (August 2,
1990), meeting summary and minutes, Au-
gust 29,1990.
U.S. EPA, Scientific Support Branch, Pesticide
and Toxic Substances Enforcement Division,
"Contaminant Screening Guidelines," Febru-
ary 1977.
U.S. EPA, 1989, Trip Report to California,
Oregon, Washington, September 16-22,1990,
U.S. EPA, Office of Pesticide Programs, Octo-
ber 1990.
U.S. EPA, 1990, Trip Report to Chicago, July
18-20,1990, U.S. EPA, Office of Pesticide Pro-
grams, July 1990.
U.S. EPA, 1990, Trip Report to Missouri, May
25,1990, U.S. EPA, Office of Pesticide Pro-
grams, 1990.
Victaulic Company of America/U.S. EPA,
meeting summary, U.S. EPA, Office of Pesti-
cide Programs, March 30,1990.
Voss, D., "Plastics Recycling: New Bottles for
Old," Chemical Engineering Progress, October
1989, pp. 67-72.
Walker, J., 'The Amateur Scientist," Scientific
American, Inc., October 1984, pp. 144-152.
Ward, J., U.S. EPA, Region 5, memorandum
to P. Flaherty, U.S. EPA Office of Compliance
Monitoring Policy Branch, December 15,1989.
Ware, G., The Pesticide Book, W.H. Freeman
Company, 1978.
"Weed TSJ Feed in a New Light," Agrichemical
Age, May 1990, pp. 29-31.
Wegner, D., 'Testicide Container Drive Set,"
Crookston Daily Times, Crookston, Minnesota,
October 12,1990.
Wells, J., California Department of Food and
Agriculture, letter to P. Flaherty, U.S. EPA,
Office of Compliance Monitoring, January 17,
1990.
Wells, J., California Department of Food and
Agriculture, letter to SFIREG Working Com-
mittee, December 4,1989.
"Will Premixed Herbicide Beat Cost of
Tankmixing," Wallaces Farmer, May 17,1988,
pp. 30-31.
Wisconsin Department of Agriculture, Trade
and Consumer Protection, Agricultural Re-
source Management Division, "Explanations
and Interpretations of AG 163, Wis. Adm.
Code, Pesticide Bulk Storage," 1989.
Wolfe, H., et al, "Health Hazards of Dis-
carded Pesticide Containers," Arch. Environ-
mental Health, Vol. 3,1961, pp. 531-537.
Yarwood, M., British Agrochemicals Associa-
tion Limited, "Guidelines for Liquid Contain-
ers," July 18,1990.
Yates-Parker, N., Monsanto, letter to C. Myr-
ick, National AgriChemical Retailers Associa-
tion, November 6,1989.
Yates-Parker, N., Monsanto, letter to P.
Flaherty, U.S. EPA, Office of Compliance
Monitoring, October 13,1989.
234
-------
Pesticide Containers - A Report to Congress
Younos, T. and Weigman, D., "Pesticides: A
Continuing Dilemma," Journal WPCF, Vol. 60,
No. 7, July 1988, pp. 1,199-1,205.
Zahos, S., Envirecycle, letter to M. Branscome,
Research Triangle Institute, December 11,
1989.
Zahos, S., Envirecycle, letter to U.S. EPA,
Office of Pesticide Programs, April 1990.
49 CFR Part 107, "Hazardous Materials Pro-
gram Procedures," September 25,1978.
49 CFR 171.8, "Hazardous Materials Regula-
tions," October 1,1989.
49 CFR 173.115(a) Flammable Liquids.
49 CFR 173.115(b) Combustible Liquids.
49 CFR 173.343 Class B Poisons.
49 CFR 178.253-4, "Hazardous Materials
Regulations," October 1,1989.
45 Federal Register 33016, "Hazardous Waste
and Consolidation Permit Regulations," May
19,1980.
47 Federal Register 36093, "Hazardous Waste
Management System; Identifying and Listing
of Hazardous Waste," August 18,1982.
49 Federal Register 212, "Closed System Pack-
aging; Industry Plan for Standardization of
Containers and Closures," October 31,1984.
51 Federal Register 21276, "Pesticide Pro-
grams; Child Resistant Packaging," June 11,
1986.
52 Federal Register 16482, "Performance-
Oriented Packaging Standards; Miscellaneous
Proposals;;1 May 5,1987.
52 Federal Register 16482, "Performance-Ori-
ented Packaging Standards; Proposed Rule-
making," November 6,1987.
53 Fed. Reg. 33314, "Solid Waste Disposal
Facility Criteria," August 30,1988.
55 Fed. Reg. 52402, "Performance-Oriented
Packaging Standards; Changes to Classifica-
tion, Hazard Communication, Packaging and
Handling Requirements Based on U.N. Stan-
dards and Agency Initiative," December 21,
1990.
235
------- |