Minibulk Information

EPA Pesticide Container and Containment Rule: Refillable Container Requirements
U. S. EPA published the final Pesticide Container and Containment (PCC) Rule in August 2006. The Rule seeks to provide sound stewardship practices and national consistency for pesticide labeling, container design, repackaging and storage. These requirements became effective August 16, 2011.
Download a fact sheet and checklist (from CLA), which discusses critical aspects of the Rule that affect selection, maintenance and use of refillable containers for pesticides.
Download the CLA poster which gives details on the new container requirements.
Inspecting Refillable Pesticide Container Video

Diagrams for Minibulk Compliance
Three flow charts were recently developed to help explain the refillable container and repackaging regulations.
EPA Pesticide Container and Repackaging Regulations - Flow Chart 1.
EPA Pesticide Container and Repackaging Regulations - Flow Chart 2.
EPA Pesticide Container and Repackaging Regulations - Flow Chart 3.

The Mid America CropLife Association (MACA) recently held a mini-bulk summit to help clarify the new regulations that are required as of August 16, 2011. Click the links below to view the presentations and handouts from the summit.
US EPA Update on Container Rules & Regulations presented by Nancy Fitz, Chemical Engineer, US EPA Office of Pesticide Programs, U.S. Environmental Agency.
CLA Description of Refillable Containers for Liquid Pesticides
CLA Guidance for Safely Cleaning Refillable Pesticide Containers for Refilling or Re-dedication.
CLA, US EPA, ACRC Safely Cleaning Refillable Pesticide Containers for Recycling
US EPA Refillable Container and Repackaging Fact Sheet

Container Refilling Q&As - filling at end user locations per Nancy Fitz, U.S. EPA.
Click the question to get the detailed answer document
Question: Can a retailer or distributor fill a refillable container on a farm and, if so, what are the applicable requirements?
Sub-question 1: In this situation, what standards would the refillable container at the farm have to meet?
Sub-question 2: In this situation, would the repackaging have to be done on a containment structure?

EPA Clarifies Monsanto Refillable Containers with a Q and A, October 2011.
After a lot of research about DOT's regulations and a number of discussions with Monsanto, here are two Q&As to provide some clarity about why Monsanto's refillable containers (with capacities of 120 gallons or larger) can be used in compliance with EPA's pesticide container regulations even though they do not have the DOT/UN marking and why they do not need to be leakproofness tested. These Q&As have been reviewed by Monsanto, EPA, and DOT.
Q & A document

Aginfodata has come up with a "Good Practice Labeling Guide" for the new Pesticide Container and Containment (PCC) Rules that became effective August 16, 2011.
Good Practice Labeling Guide

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