Mobile, Alabama February 5-7, 2013 Pesticide Stewardship Conference

Reusable Industrial Packaging Association RIPA is the U.S.-based trade association for firms that recondition, recycle, and/or manufacture industrial containers such as drums and IBCs. The membership is comprised of approximately 75 U.S firms operating over 100 facilities. Members are also located in Canada, Mexico and other nations. RIPA’s Mission: Promoting Safe and Sustainable Design, Manufacturing, Remanufacturing and Reuse for the Industrial Packaging Industry.

Pesticide Stewardship Conference Composite IBCs in “AgChem” Service Pesticides: Herbicides and Insecticides

Pesticide Stewardship Conference Glossary of Terms

Pesticide Stewardship Conference Registrant – Pesticide manufacturer Ag Retailer – Co-ops; farm supply outlets; pesticide distributors Hazmat Mark – DOT mark indicating the container’s UN certification and performance rating FIFRA Label – EPA; “FIFRA” is federal pesticide law; label includes registrant’s instructions on product use and container management EPA Container and Containment Rule - Into effect August 16, 2011

Pesticide Stewardship Conference Intermediate Bulk Container (IBC) – a DOT hazmat container term Composite IBC - HDPE plastic bottle-in-a-cage design; typically 275 and 330 gallons, blow-molded bottle. Mini Bulk – AgChem industry term for similarly sized containers – but generally all “heavy” plastic, “roto-molded” Refillable Container - An EPA term; a narrower construct than the term “reusable” or “reconditioned” as found in DOT hazmat rules; typically refilled with the same or very similar product for distribution to application site(s) by coops and ag’ retailers; may be refilled by registrants only when triple rinsed.

Pesticide Stewardship Conference Recycling - General term; conversion of a used product into another type of product. See ACRC list of approved products. Reconditioning – DOT hazmat term; re-certified for reuse in hazmat service; marked as recertified (i.e., leakproofness tested). IBC Reprocessing – DOT hazmat term for reconditioning & re-certifying IBCs; Includes: Routine Maintenance (washing) – requires visual verification of “leaktightness” Repair (includes re-bottling) – requires leakproofness test Remanufacturing (conversion to new hazmat design type; also, “cross bottling”; full certification tests required) 2 ½-Year & 5-Year Tests and Inspections – For IBC packaging; part of the Qualification and Maintenance rules

Pesticide Stewardship Conference Refillers must repackage into “refillable containers” that:  Comply with at least DOT Packing Group III standards that EPA has adopted by reference;  Are durably marked with a serial number or “bar code”;  Have a tamper-evident device, one-way valve or both on each opening (other than a vent); and  Are on the registrant’s description of acceptable containers.

Pesticide Stewardship Conference The following requirements apply each time a container is refilled. The refiller must: Identify the pesticide previously in the container (by looking at the label); Visually inspect the container to ensure that it is in good shape; Clean the container if necessary – The refillable container must be cleaned between uses unless all tamper-evident devices and one-way valves are intact and it is filled with the same or a very similar product.

Pesticide Stewardship Conference Some things to consider: Pesticide companies have been moving to composite IBCs in recent years due to their lower cost compared to traditional “mini bulks”. The industry’s Ag Container Recycling Council funds collection of smaller containers (e.g., 2 ½-gallon jugs and 5-gallon pails). By conducting a “pilot” IBC collection program in Iowa, the Council determined that “infrastructure” (e.g. reconditioners) exists such that ACRC will not fund IBC collection. ACRC and its members generally direct that emptied plastic containers be recycled into a set of “approved” products (e.g., tire stops, agricultural drain pipes, industrial pallets). This historically has been the preference of registrants, as opposed to reusing something like a plastic packaging.

Pesticide Stewardship Conference Things to consider (cont’) - Some pesticide products are DOT hazmats and some are not. Some are EPA-designated haz wastes (P-List) and some are not. All containers should be triple rinsed by the end user before taken out of service. IBC cages that are clean are reusable by reconditioners. RIPA has advised EPA on this issue and EPA has indicated that it would proclaim clean cages reusable. The EPA / FIFRA label instructions (written by the chemical company) include instructions on container disposal. These instructions carry the force of law.

Pesticide Stewardship Conference Need clear EPA statement that IBC cages are reusable. Need agrochemical recognition that professional container management has benefits: energy, carbon- footprint, and landfill savings. Infrastructure exists to help clear the field.