As the final August 16 implementation date of EPA’s Pesticide Container and Containment (PCC) rule nears, the member companies of CropLife America (CLA), Ag Container Recycling Council (ACRC), Agricultural Retailers Association (ARA), and National Agricultural Aviation Association (NAAA) reinforce their commitment to the safety and stewardship of crop protection products throughout their life-cycle, including safe storage and the reduction and recapture of packaging.
The primary objectives of EPA’s rule are to facilitate the disposal and recycling of pesticide containers and protect the environment from potential pesticide releases due to spills and leaks in storage, refilling containers, or dispensing of crop protection products. Industry organizations have played an active supporting role in the implementation of the new rule, and have led training, the development of retail center certification for compliance with storage requirements, and worked to ensure the smooth implementation of the rule so that the objectives are met and regulatory burden is minimized.
The CLA Stewardship Committee, consisting of CLA member companies, has developed guidance for safely cleaning refillable pesticide containers for reuse or rededication, and a description of acceptable containers that may be provided to refillers in order to meet requirements of the rule. This guidance should only be used if it is authorized by the registrant of the product in the container. Electronic versions of these and additional supporting documents are available on the CLA website at www.croplifeamerica.org/PCC-Rule.
Pesticides are most commonly sold in small (from 2.5 gallons up to 55 gallons) non-refillable containers and larger refillable containers. The distribution of pesticides in large, refillable containers reduces the volume of contaminated packaging that must be captured and managed. In 2010, approximately 25 percent of the volume of pesticides from CLA members was sold in refillable packages. This eliminated the equivalent of more than 10 million 2.5 gallon jugs. In addition, more than 8 million pounds of plastic were recovered from smaller non-refillable packaging.
The requirements of EPA’s PCC rule have been phased in since it was finalized in 2006. The final phase of implementation goes into effect on August 16, 2011. After this date, registrants will be required to incorporate new container management language on the labels of products released for shipment. Pesticide users will be required to follow the new container management instructions as soon as they appear on the labels; stationary tanks and portable refillable containers will also be required to be compliant with the PCC rule. The labels of non-refillable containers must have recycling or reconditioning instructions, and refillable container labels are required to list instructions for cleaning the container before it is recycled or disposed.
The registrants of crop protection products that are shipped in refillable containers are also affected by the PCC rule. Registrants must provide contracted refillers with a prescribed procedure to clean refillable containers, and develop and provide all refill locations with a description of acceptable containers that meet the requirements for stationary tanks and portable refillable containers. They are responsible for ensuring that portable refillable containers are marked with a serial number or other identifying code, have a one-way valve, tamper-evident device, or both on all openings, and must make certain that containers meet Department of Transportation’s design, construction and marking requirements.
Information regarding the rule can also be found through:
• ARA (www.aradc.org)
• American Agronomic Stewardship Alliance (www.aginspect.org)
• Ag Container Recycling Council (www.acrecycle.org)
Detailed information about the rule requirements can be found on the EPA website at www.epa.gov/region8/toxics/pests/ccr.html. For additional information please contact: Stephanie Lutz (CLA, 202-872-3867) or Carmen Haworth (ARA, 202-595-1706).