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A new rule from the U.S. Environmental Protection Agency (EPA) is putting more focus on pesticide container management in 2009. The EPA-mandated regulations, "Pesticide Management and Disposal; Standards for Pesticide Containers and Containment," were originally published in 2006. The EPA recently amended the regulations, which took effect Dec. 28, 2008.

Spotlight on Container Management

 A new rule from the U.S. Environmental Protection Agency (EPA) is putting more focus on pesticide container management in 2009. The EPA-mandated regulations, “Pesticide Management and Disposal; Standards for Pesticide Containers and Containment,” were originally published in 2006. The EPA recently amended the regulations, which took effect Dec. 28, 2008.


The most drastic change in requirements for vegetation managers are a set of new statements that will appear on herbicide labels regarding rinsing and disposal of empty containers. New label directions will require that emptied containers be filled to at least one-fourth of their volume with rinse water for each of the triple-rinse cycles. So, to properly triple-rinse a 2.5-gallon herbicide container will now require a minimum of 1.8 gallons of water.


New label directions also direct the pesticide user to offer containers for recycling if recycling is available in that area. Products labeled before the new regulations came into effect can be triple-rinsed and disposed of based on their label directions.


“The new regulations do not change the basics of industry practice,” said Dave Schoonover, president of Aqumix, a custom blend company based in Cloverdale, Va. “The industry has been doing triple-rinsing and recycling of containers for years. However, applicators will need to pay attention to the details of the regulations and label directions. For example, the regulations require that containers be rinsed ‘promptly,’ and that is a term that is open to some interpretation. What it means in terms of regulation is up to the state enforcement agency and probably the individual state agricultural inspector.”


Nancy Fitz, chemical engineer with the EPA, said the agency’s goal is to protect human health and the environment by ensuring that as much of the pesticide residue as possible in emptied containers has been removed before they are recycled. It is easiest to remove residues in containers if triple-rinsing is done as soon as possible after the container is emptied. For that reason, one early draft of the new regulations would have required that emptied containers be “immediately” triple-rinsed, she said, but the strict enforcement of that could have meant that each individual container would need to have been triple-rinsed before an applicator could open a second container when preparing a tank mix. Requiring that applicators promptly triple-rinse containers gives applicators some necessary leeway. The EPA is now working on guidelines on what “promptly” means.


The new label directions on triple-rinsing were written based on a design standard that can remove up to 99.99 percent of the pesticide residue left in the container after emptied, said Fitz.


Fred Whitford, an Extension specialist with Purdue University, said the new triple-rinse label directions only apply to one-way containers. Returnable containers, such as Continuum Prescription Control & Container Management System, do not require any rinsing by the applicator.


Whitford said returnable containers also can be incorporated to reduce the risk or severity of accidental spills due to poly tank failure. Returnable container totes can be mounted on the truck so the applicator pulls herbicide concentrate from the tote and water from the poly. This way, if the poly tank failed, the spill would be water only.


Nick Hoffman, sales manager of Eco-Pak, a custom blender based in Selma, Ind., said the returnable, refillable containers from the Continuum system his firm uses for herbicide concentrates have a five-year life cycle and then they are replaced and recycled. “Applicators should always look for application tanks with the highest rating regardless if they are being used for herbicide or water. When it comes to purchasing equipment, the customer usually gets what they pay for and should never purchase used tanks,” he said.


Failure of poly tanks used with a tank mix is the subject of a just-released Purdue Extension bulletin (“Poly Tanks for Farms and Businesses: Purdue Extension Service Bulletin PPP-77”), said Whitford. The new bulletin is designed to educate applicators about the potential for poly tank failures and the resulting accidental spills.


“The life span of poly tanks depends upon a number of variables, including what they were designed for and how they are used,” said Whitford. “Some tanks are designed for stationary use, and some for transportation. Tanks that are stored inside have a longer service life than tanks used outside because, over time, sunlight will break down the ultraviolet protection used in the tanks. When that happens, the tank gets brittle and can fail.”


An important factor is the tank rating: 1.0, 1.5 or 1.9. Tanks with the 1.0 rating are designed to hold water, which weighs 8 pounds per gallon. Tanks with the higher ratings provide a greater safety margin, but cost more.


“Vegetation management herbicides do not add significant weight and resulting pressure to poly tanks, but a potential spill due to tank failure makes it important to use a poly tank with a higher rating as an added margin of security,” said Whitford. “Poly tanks used on vehicles should have the 1.9 rating because vehicle movement causes the liquid in the tank to slosh back and forth, which puts more pressure on the tank.”


The new Purdue Extension bulletin also includes a suggested test Purdue has used to evaluate tank condition. A water-based black marker can be applied to a small section of the tank and wiped off to see if cracks are visible in the poly. If so, the ultraviolet protection in the poly is breaking down and the tank is becoming brittle and should be replaced. A bright light also can be used to visually inspect the inside of the tank for cracks.


Another aspect of container management is secure storage, said Randy Veatch, technical sales manager with Securall Products based in La Porte, Ind. As an OEM manufacturer of storage cabinets and outdoor storage buildings, Veatch said his company must manufacture steel storage containers that meet federal, state and local requirements, including mandated requirements from the EPA, OSHA and fire codes. Two of the newest aspects of pesticide storage security are containers and sheds that can withstand winds from hurricanes and tornados.


“We tell customers that stored pesticides are their responsibility no matter what the circumstances are,” Veatch said. “It’s smart to review the MSD sheets for the pesticides you have in storage, and the current laws in your area, to make sure you are in compliance. On the MSD sheet, if it says ‘must,’ then that is a requirement. That requirement can bring unwanted attention from local authorities.”


 


[Note: Continuum is a trademark of Dow AgroSciences LLC. Always read and follow label directions.]


 


Article provided by Dow AgroSciences.

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