EPA’S NEW CONTAINER/CONTAINMENT REQUIREMENTS WHAT GROWERS NEED TO KNOW
Standards for stationary bulk tanks* Secondary containment already law in Indiana Operational and record keeping requirements regarding repackaging* For Dealers only *Pesticide only IN EFFECT AUGUST 17, 2011
Standards for portable refillable containers (minibulks, shuttles, totes etc…)* *Pesticide only SPECIFIC TO GROWERS EFFECTIVE AUGUST 17, 2011
To insure that minibulks withstand road and field use. To insure minibulks are not contaminated with other products. To protect you, the grower! WHY THE NEW RULES FOR REFILLING MINIBULKS?
NO IMPACT TO YOU IF RECEIVING PRE-FILLED MINIS FROM DEALER
SEALS SHOULD NOT BE BROKEN BY GROWERS UNLESS IT IS THE ONLY WAY TO REMOVE PRODUCT
IF I BRING MY OLD MINI TO MY DEALER, WILL IT BE REFILLED?
Your dealer is bound by federal law to refill only those containers that meet the new standard. They have been instructed by OISC and their management NOT to fill non-compliant containers. Work with your dealer to determine whether your minibulks meet the new standard and can be refilled. ANSWER—MAYBE
Does your mini meet manufacturer’s specifications for refilling? Do all openings on your mini have one-way valves or tamper evident seals? Does your mini have a unique serial number or ID code? Does the dealer want the liability for refilling an old mini? Expect that your old minis will NOT be refilled. ALL REFILLABLE CONTAINERS MUST MEET THE FOLLOWING REQUIREMENTS
Y ou as the end-user, may continue to use the mini as long as it does not leak and is structurally sound. You can transfer material from the Dealer’s mini into your old mini as long as it’s for your own use! How safe are your old minis? You may want to consider upgrading to the new minis. What Can I Do With Old Minis?
A list of recyclers is available at the OISC website Look for the list of News Alerts on the pesticide page. How Can I Dispose Of Non-compliant Containers?
Yes, if the mini is used for permanent storage. OR If the mini (whether on a truck, trailer or the ground) is used for more than 30 days it must have secondary containment. Do Minis Need Containment?
What Is An Example Of Secondary Containment For A Minibulk? Any sloped or curbed impervious surface, such as concrete, that can hold the entire contents of the minibulk. A typical mix/load pad that is 10 X 20 ft and can hold 750 gallons meets the secondary containment requirement A flat uncurbed slab of concrete DOES NOT
Recycling questions to Kevin Neal Containment questions to Trish Waller OR Matt Pearson All others to Joe Becovitz IMPORTANT CONTACTS