AASA: Bulk Pesticide Repackaging Compliance Guide

Bulk Pesticide Repackaging Regulations

A Quick Guide to Compliance – Reprinted with permission from AASA – American Agronomic Stewardship Alliance

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Visit us at www.aginspect.org for more information and resources on bulk pesticide storage and repackaging regulations.

 

YOUR USEPA ESTABLISHMENT NUMBER (EPA Est. No.)

Any facility where a pesticide is produced (including repackaged for sale or distribution) must be registered with the USEPA. When you register, you must provide the name and address of your company, the type of ownership, and the name and address of each location where repackaging will occur. USEPA will then issue you an EPA Establishment Number (EPA Est. No.) which can only be used by that specific facility.
(see image #1)

 

For repackaging facilities, the EPA Est. No. will be formatted as a five digit code, the state abbreviation where the facility resides and a three digit facility location code. The EPA Est. No. must be placed on every portable refillable container (PRC) by a person at the repackaging facility. The EPA Registration Number (EPA Reg. No.) is the product specific registration number that belongs to registrant (the manufacturer of the product); that number must also appear on every pesticide label.
(see image #2)

 

AUTHORIZATION TO REPACKAGE

The repackaging facility must have a current, written authorization (a repackaging agreement) from the registrant (manufacturer) to repackage and use the manufacturer labels. The repackaging facility must keep a copy of the document on file and make it available upon request to an authorized EPA or State Representative. The repackaging facility must maintain the agreement for the period of me for which it is valid and for three years after that. If the repackaging facility is sold or transferred, a new authorization in the new company name must be obtained from the registrant (manufacturer).
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LABELING ON BULK STORAGE TANKS AND PRCs
The bulk pesticide storage tank must display the most current product label, the registrant’s (the manufacturer’s) EPA Est. No. and the net contents of the tank at the me it was filled. Before distributing or selling a pesticide product in a portable refillable container (PRC), you must ensure that the label for the pesticide is securely a&ached to the PRC so that it can be expected to remain affixed during foreseeable conditions and periods of use. You must ensure the net contents and EPA Est. No. for your facility also appears on the PRC label.
(see image #4)

 

ANNUAL PRODUCTION REPORT

Each repackaging facility must submit a report to USEPA by March 1 on the pesticides repackaged at that establishment the previous year, even if the amount repackaged is zero. The report must contain:

  • The name and address of the establishment;
  • Amount of each pesticide produced (repackaged for sale or distribution that year);
  • Amount of each pesticide sold or distributed the previous year, and the amount of each pesticide esmated to be repackaged during the current year.

The repackaging facility must keep a written log of the product name, EPA Reg. No., amounts per batch and batch identification of all pesticides repackaged.

 

APPROVED CONTAINERS AND CLEAN OUT PROCEDURES
Each repackaging facility must ensure they are only repackaging into portable refillable containers (PRCs) that are approved by the registrant (manufacturer). The Repackaging Agreement will list the types of approved containers. If the tamper evident devices and/or one way valves are not intact, or if you introduce a different product into the container, the container must be cleaned according to the manufacturer’s instructions prior to being refilled. You must also clean the containers before disposal or recycling.
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Qualification Statement

This project was undertaken in conjunction with the settlement of an enforcement action against Syngenta Crop Protection, LLC, taken by the US Environmental Protection Agency for alleged violations of FIFRA.