Repackaging (cont.)
• When repackaging, a refiller must:
o Identify the previous pesticide
o Visually inspect to see if container is safe to use
and has the required markings and openings
o Clean the container unless the tamper evident
device and/or one-way valve are intact and the
container is being refilled with the same product
(or the new product meets other very limited
circumstances)
o Repackage into a container identified in the
registrant's description of acceptable containers
o Ensure that the product is properly labeled and
includes the EPA establishment number and net
contents
o Keep records on the product, date and container
for each refill
3. Key Labeling Requirements
** Comply by August 16, 2010 **
Who must comply
• Registrants must incorporate the new language
onto their labels for pesticides that are released for
shipment after August 16, 2010.
• Pesticide users must follow the new container
management instructions as soon as they are on
the labels.
New Label Statements
• Labels (or containers) of non-refillable containers
will have:
o "Non-Refillable Container"
o A "Do Not Reuse" statement
o Recycling or reconditioning instructions
o A lot number identifying the batch
o More detailed rinsing instructions for dilutable
products in rigid containers, except for
household products
• Labels (or containers) of refillable containers will
have:
o A "Refillable Container" statement
o Instructions for cleaning the container before
it is recycled or disposed of (not before it is
refilled)
4. Key Non-Refillable
Container Requirements
** Comply by August 16, 2009 **
Who must comply
Registrants are responsible for ensuring that their
non-refillable containers meet the standards.
Non-Refillable Containers
• For products that are in Toxicity Categories III
and IV (and that are not restricted use products),
the containers must meet only the basic DOT
requirements in 49 CFR 173.24.
• All other products (restricted use products and
those in Toxicity Categories I or II) are subject
to the non-refillable container requirements.
Consult the regulations to determine which of the
requirements your specific product and container
must comply with. Non-refillable containers must:
o Meet certain DOT design, construction, and
marking requirements
o Have standard closures
o Allow the contents to pour in a continuous
stream (no "glugging") and with a minimum
amount of dripping down the outside of the
container
o Meet a "cleanability" standard
o Keep records showing compliance
For More Information
Although the regulations (including the amendments)
are final, EPA will be posting updated guidance and
additional information to the PCC web site.
For the Complete Rule or for
Additional Information go to:
www.epa.gov/pesticides/regulating/containers.htm
Or call:
EPA Region 10 Pesticide Program
(206) 553-0505, (206) 553-4627
Or toll-free at 1-800-424-4372
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Purpose of the Rule
EPA published a final rule called the Pesticide
Container and Containment (PCC) rule in August
2006 and made minor amendments to the rule in
October 2008. The rule seeks to:
• Minimize human exposure to pesticides while
handling containers
• Facilitate disposal & recycling of pesticide
containers
• Protect the environment from pesticide releases
at bulk storage sites and from spills or leaks when
refilling and dispensing pesticides
Who Must Comply
The five parts of the PCC rule apply to different kinds
of businesses. The PCC rule may affect you if you
are a pesticide:
• Registrant
• Retailer
• Distributor
• Commercial applicator
• Custom blender
• User
Below are key elements of the PCC rule but this
pamphlet does not cover every aspect and detail.
Refer to the final regulations for full details.
1. Key Containment Requirements
** Comply by August 16, 2009 **
Who must comply
You may only have to comply with state pesticide
containment regulations, not the federal regulations,
if your state had regulations in place by August 2006.
Consult your state or tribal pesticide agency or the
PCC web site to determine whether your facility
is subject to state, tribal, or federal containment
regulations. In Washington State, the Washington
State Department of Agriculture (WSDA) will be
implementing state containment regulations. The
federal containment regulations will apply everywhere
else in Region 10.
You must comply with the federal pesticide
containment requirements if you handle agricultural
pesticides and you are a:
• Retailer who repackages
• Commercial applicator
• Custom blender
Secondary Containment Units
• Tanks with capacities of 500 gallons (liquids)
or 4,000 pounds (dry) or greater and that are
stationary (fixed or in place > 30 days) must be in
secondary containment.
• Tanks for liquids must be anchored or elevated to
prevent flotation.
• Containment must have a capacity of 100% of
largest tank if protected from precipitation or if it
existed before Nov. 2006 or a capacity of 110% if
not protected from precipitation and built after Nov.
2006.
Containment Pads
• Containment pads are required for:
o Emptying, cleaning, or rinsing refillable
containers
o Dispensing pesticides from a stationary
container with a capacity of 500 gallons or 4,000
pounds or greater
o Dispensing pesticides from a transport vehicle
to fill a refillable container
o Dispensing pesticides from any other container
to fill a refillable container for sale or distribution
• Pads must have a capacity of at least 750 gallons
or 100% of the volume of the largest container
(including transport vehicles) used on the pad,
whichever is less.
Both Secondary Containment & Pads
• Must be liquid-tight and constructed of impervious,
rigid materials compatible with agricultural
pesticides stored.
• Must have sufficient freeboard to contain
precipitation & prevent liquids from entering.
• Must be inspected monthly by the facility and
repaired when necessary.
• Facilities must keep records on maintenance &
monthly inspections.
2. Key Refillable Container and
Repackaging Requirements
** Comply by August 16, 2011 **
Who must comply
• If you are an Independent Refiller (repackage a
pesticide and are not the registrant), you must
comply with the requirements for stationary
tanks and repackaging. Also, you are indirectly
subject to the requirements for portable refillable
containers.
• If you are a Pesticide Registrant, you must comply
with the requirements for stationary tanks, portable
refillable containers, and repackaging.
Stationary Tanks
The following requirements apply to tanks with
capacities of 500 gallons (liquids) or 4,000 pounds
(dry) or greater and that are stationary (fixed or
in place > 30 days) and that are at the facilities of
independent refillers (who repackage a pesticide and
are not the registrant). These tanks must:
• Be marked with a serial number or other identifying
code
Have sufficient strength and durability
Have vents that limit evaporation
Have a lockable inlet/outlet valve
Not have external sight gauges
Be in secondary containment (if it holds an
agricultural pesticide)
• Be anchored or elevated to prevent flotation (if it
holds an agricultural pesticide)
Portable Refillable Containers
Registrants are responsible for ensuring that portable
refillable containers (minibulks, totes, shuttles, IBCs,
etc.):
• Meet certain Department of Transportation (DOT)
design, construction, and marking requirements
• Are marked with a serial number or other
identifying code
• Have a one-way valve or tamper-evident device or
both on all openings (other than the vent)
Repackaging
Any registrant and refiller (who could be a retailer,
distributor, or registrant) are subject to the
repackaging requirements, which include:
• Must have a written contract between the registrant
and an independent refiller
• Both the registrant and refiller are responsible for
product integrity
• There are no regulatory limits on the size of
refillable containers (registrants might establish
size limits in their contracts)
• Registrants must develop and provide refillers with:
(1) A procedure to clean refillable containers
(2) A description of acceptable containers (that
meet the requirements for stationary tanks and
portable refillable containers)
• Refillers must maintain these documents at their
establishment
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