EPA Clarifies Rules For Monsanto Containers

The EPA has revised its Q&A’s explaining how Monsanto refillable containers can be used in compliance with the Pesticide Container and Containment regulations even though they do not have the Department of Transportation/ UN marking.  

Here is a summary of the Q&A revision:

Why do Monsanto’s 120‐, 150‐ and 250‐gallon Shuttle containers and 265-gallon CUBE containers comply with EPA’s refillable container regulations even though they do not have the DOT/UN marking?

Answer: Monsanto’s 120-, 150- and 250-gallon Shuttle containers and 265-gallon CUBE containers can be used under EPA’s refillable container regulations even though they do not have the DOT/UN marking because they are “non-DOT Specification portable tanks suitable for the transport of liquids.” The U.S. Department of Transportation (DOT) regulations in 49 CFR 173.241(c), which are incorporated into EPA’s refillable container regulations, authorize the use of non-DOT Specification portable tanks suitable for the transport of certain low-hazard liquids.

Do Monsanto’s 120-, 150- and 250-gallon Shuttle containers and 265-gallon CUBE containers (that do not have the DOT/UN marking) need to be leakproofness tested every 2.5 years? Do these Shuttle containers and CUBEs need to pass the DOT external inspection every 2.5 years or the DOT internal inspection every 5 years?

Answer: No, Monsanto’s 120-, 150- and 250‐gallon Shuttle containers do not need to be leakproofness tested or DOT inspected according to the requirements in 49 CFR 180.352 (which is referred to and adopted by EPA’s refillable pesticide container regulations.) Monsanto’s Shuttle containers and CUBE containers are “non-DOT Specification portable tanks” rather than IBCs and the “requirements for retest and inspection of IBCs” in 49 CFR 180.352 only apply to IBCs “constructed in accordance with a UN standard.”

Specifically, 49 CFR 180.352(a) states: “Each IBC constructed in accordance with a UN standard for which a test or inspection specified in paragraphs (b)(1), (b)(2) and (b)(3) of this section is required may not be filled and offered for transportation or transported until the test or inspection has been successfully completed.” Section 180.352(b) establishes test and inspection requirements for metal, rigid plastic and composite IBCs. Monsanto’s 120-, 150- and 250-gallon Shuttle containers and 265-gallon CUBE containers are not IBCs so the retest and inspection requirements in 49 CFR 180.352 do not apply to them.

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