On Aug. 16, the EPA will require all portable and refillable pesticide containers to meet the following requirements:
- One way valves or tamper evident device on openings (other than vents) is required. Standard zip-ties are not acceptable for a tamper evident device.
- Containers must have a unique method of identification such as serial number or ID code.
- Must meet DOT design, construction and marking at a minimum of PG III.
- Must be cleaned between uses unless tamper evident and/or one-way valves are intact and filled with same product.
- Containers must be on an approved list from the registrant. Containers with the product name molded into the container should remain dedicated to that product.
- Must have registrant’s cleaning instructions and repackaging authorization on hand.
- EPA Establishment number and net contents must be on the product label affixed to the tank.
- Container integrity is the responsibility of both the re-filler and registrant.
- Records must be kept for each inspection and fill that includes the pesticide, amount, EPA establishment number and tank serial number or code.
- All DOT tanks must be pressure tested every 2 1/2 years according to DOT re-testing procedures. There is a month/year date stamped near the UN Marking that indicates the original certification date.
The person who owns the pesticide refillable container must comply with these regulations, whether they are the manufacturer, distributor, retailer or farmer. After Aug. 16, many existing portable refillable containers will be obsolete. If the refillable container cannot meet these requirements it is not to be refilled.
The Illinois Fertilizer & Chemical Association has a number of documents on its Web site — www.ifca.com — that help explain the requirements of the 2011 U.S. EPA Regulations for Minibulks and Container/Containment Requirements.
(Sources: South Dakota Ag Connection, Illinois Fertilizer & Chemical Association)