Pesticide container containment regulation update
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Pesticide Container-Containment Regulation Update. U.S. EPA Office of Enforcement and Compliance Assurance Western Regions/States/Tribes Pesticide Meeting May 18-20, 2010. Outline. Review of Container-Containment Rule Pesticide Containment Requirements Implementation New information

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Pesticide Container-Containment Regulation Update

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Pesticide container containment regulation update

Pesticide Container-Containment Regulation Update

U.S. EPA Office of Enforcement and Compliance Assurance

Western Regions/States/Tribes Pesticide Meeting

May 18-20, 2010



  • Review of Container-Containment Rule

  • Pesticide Containment Requirements

    • Implementation

    • New information

  • Refillable Container & Repackaging Requirements

  • Outreach Material

  • Inspection Checklist

Overview purpose of the rule

Overview: Purpose of the Rule


Minimize human exposure during container handling

Facilitate container disposal and recycling

Encourage use of refillable containers


Overview purpose of the rule1

Overview: Purpose of the Rule


  • Protect human health and the environment from:

    • Releases at bulk storage sites

    • Spills and leaks where pesticides are transferred for repackaging


Overview who must comply now

Overview: Who must comply NOW?

Overview who must comply later

Overview: Who must comply LATER?


Implementing the pesticide containment regulations

Implementing the Pesticide Containment Regulations












Implementing the pesticide containment regulations1

Implementing the Pesticide Containment Regulations

  • EPA authorized 21 States to continue implementing their State pesticide containment regulations (that were in place by August 2006); determined that they provide equivalent environmental protection.

  • In Indian country and other 29 states:

    • Compliance is required with federal containment regulations beginning August 17, 2009, but EPA is allowing States and Tribes to conduct compliance assistance for containment for 2009 and 2010, at the State’s or Tribe’s discretion.

    • Region & State/Tribe negotiate expectations for inspections.

    • Options: Implement Federal regs; issue Tribal code to adopt Federal regs by reference; issue Tribal code with different (e.g., more stringent) standards

Pesticide containment requirements

Pesticide Containment Requirements

  • Key requirements for secondary containment and containment pads

    • Materials

    • Protect transfer equipment

    • No outlets/drains (or seal them for existing structures)

    • Prevent stormwater run on and run off

    • Capacity

    • Tanks anchored or elevated

  • Key operational requirements

    • Collect & recover spills & leaks

    • Lock tank or facility

    • Attend transfers

    • Inspect

    • Maintenance

    • Records

Pesticide containment new info

Pesticide Containment: New Info

  • See FAQs on web site:

  • How high do tanks need to be elevated?

    • This is performance standard. Tanks must be anchored or elevated (or anchored and elevated) so the tank does not float if the secondary contain fills with liquid.

  • Would a tank be considered anchored if it always holds enough pesticide so it would not float if the containment filled with liquid?

    • Yes. See web site for info on calculating the required amount in tank.

  • Can a facility use a portable structure to comply with the containment requirements?

    • Yes, as long as the structure meets all of the requirements (rigid, able to hold contents if full, compatible, leakproof, capacity, etc.)

Possible portable containment structures

Possible Portable Containment Structures

Upcoming 2011 refillable containers

Upcoming (2011): Refillable Containers

  • Portable Refillable Containers

    • DOT packing group III standards

    • Serial number/code

    • Tamper-evident device or one-way valve on each opening

  • Stationary Refillable Containers

    • Serial number/code

    • Integrity

    • Vent

    • Shutoff valve capable of being locked

    • No external sight gauge

Upcoming 2011 repackaging

Upcoming (2011): Repackaging

  • Based on current Bulk Enforcement Policy


  • Authorize refillers to repackage their product;

  • Develop and provide certain information


  • Obtain and follow registrant info

  • Inspect, clean, and label containers

Outreach material epa

Outreach Material: EPA

  • Web site


    • At-A-Glance Tables

    • Frequently Asked Questions

    • More to come: containment equivalency, FAQs

  • 2-page brochure

  • Containment scope table

  • State inspector training (PIRT)

    • All of the modules and other material is available on line (Penn State’s site)


Outreach material industry

Outreach Material: Industry

  • American Agronomic Stewardship Alliance (AASA), CropLife America, Ag Safety School

  • Minibulk poster and inspection checklist

    • AASA web site:

  • Container inspection video

    • Available on DVDs and on the Pesticide Stewardship web site under “Container Handling”:


Outreach material industry1

Outreach Material: Industry

Inspection checklist

Inspection Checklist

  • EPA has developed an Inspection Checklist that Tribes and States can use during container-containment rule inspections.

  • Was test driven at PREP and PIRT courses in 2009 and was revised based on comments.

  • Most recent draft: December 2009.

For more information

For More Information

  • Allie Fields, OPP/FEAD: 703-305-5391

  • Nancy Fitz, OPP/FEAD: 703-305-7385

  • Jeanne Kasai, OPP/FEAD: 703-308-3240

  • Gibbs Moore, OPP/FEAD: 703-605-0195

  • David Stangel, OECA: 202-564-4162

  • E-mail addresses:


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