CropLife America: Safely Cleaning and Preparing Pesticide Containers > 55 gallons for Recycling

Safely Cleaning and Preparing Large* Pesticide Containers for Recycling
(* Greater than 55 gallons)

This guidance is intended for refillers, growers and others who have decided to recycle their large (> 55 gallon) pesticide containers. Cleaning instructions on the pesticide label must be followed before recycling or disposing of containers.

1. Complete an Environmental Health & Safety (EHS) Review

Review the product label and Safety Data Sheet (SDS) for each pesticide product, noting safety information. Find and review the section labeled “Storage and Disposal”. Also review state and local environmental rules and use these (together with the label and SDS) to identify any product that may be regulated under hazardous waste rules.

Worker Training. Workers cleaning containers may need to be certified applicators, trained as handlers under the Worker Protection Standard (40 CFR §170), or trained/certified to wear personal protective equipment, manage waste, operate equipment, and/or transport containers.

Personal Protective Equipment (PPE). Workers should wear the PPE required on the label for mixing, loading and application. If many different containers are to be cleaned, use the most protective PPE.

Containing Rinsates. Unless the applicator rinses in the field (preferred method), cleaning should be done on a mixing and loading pad, or other containment structure that ensures collection of rinse water.

Review Site Safety Procedures. Review the site/facility safety procedures and environmental policies.
If industrial equipment (pressure washers, forklifts, etc.) is used, be sure to review the manuals and safe operating procedures

Be prepared to contact, if necessary:

  • Pesticide Registrant
  • Container Manufacturer
  • Local Container Recycler
  • State or Local Waste Regulator

  • Waste Disposal Contractor
  • Local/State/Regional Trade Associations
  • State Pesticide Official

 

Last use of refillable container. When a refillable container has been used the last time and is going to be recycled, the refiller should authorize the grower or applicator to remove tamper evident devices and completely rinse the container, using the rinsate as part of the spray solution.

2. Clean and Prepare the Container

  • Inspect container. Inspect the container to determine cleaning needs and adjust cleaning appropriately.
  • Keep label and Identifier. Keep the EPA pesticide panel label and unique identifier e.g. serial number on the container.
  • Thoroughly clean both the interior and exterior of container. NO residues are acceptable.
    Follow label information for cleaning interior. Read information on the label that describes the cleaning instructions for the container. Thoroughly rinse the container using the cleaning instructions on the label.If no label. If there is no label on the container, or if there are no rinsing instructions on the label, thoroughly rinse the container using the residue removal procedure developed by the registrant; or other guidance, such as the following:
    Use a sprayer with water or a water hose with an adjustable jet nozzle to completely rinse the interior of the container. A pressure washer with a rinsing nozzle could provide a thorough rinse of the interior. Flush pump or recirculation system with water. Drain and collect rinsate from the container.
    If specifically recommended by the registrant, add a commercial tank-cleaning compound (soap or cleaner) to warm water. Spray and rinse thoroughly. Then flush the interior with water twice, draining and collecting the rinsate each time.
    Clean exterior. Thoroughly clean the exterior of the container to remove dirt and chemical residue. Wash until all visible residues are completely gone, using water and a scrub brush,or equivalent, if necessary.
    Not clean. The container is not clean if strong odors or visible residues are present. Some discoloration of the container is acceptable; residues are not.
  • Manage rinsate. Drain and collect rinsate into application equipment or a rinsate collection system. Where possible, segregate rinsate by product and manage rinsate appropriately. Record keeping for collected rinsate must follow state and federal guidelines for application or waste disposal.
    Best practice: Utilize rinsate as part of the spray solution at the time the container or tank is emptied.
  • Drain. Drain the container dry so no water remains.
  • Remove parts that cannot be recycled. Remove any item that will not be recycled, and further disassemble as required by the company recycling/disposing of the container. Cages on caged tanks or IBCs (Intermediate Bulk Containers) generally do not need to be removed and will be accepted for recycling or reuse as is.
  • Prepare container exterior. Mark and label container if required by the company recycling/disposing of the container, and complete any recordkeeping required for the container. Remove any DOT Hazmat labels or marks; keep pesticide panel label on container. Remove any tamper evident devices.
  • Maintain proper storage until recycled. Store cleaned container in secure, dry location until picked up for recycling. Limit access only to authorized people.
  • If a container cannot be cleaned, contact the registrant for disposal guidance. If the container has visible residue not removable via normal cleaning, then it is outside the scope of most recycling programs. Contact the product registrant for disposal guidance.

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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.