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Operational Area Containment & Pads for Bulk Pesticides - page 1 / 4

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This brochure is sponsored by the American Agronomic Stewardship Alliance (AASA) in cooperation with the Illinois Fertilizer & Chemical Association (IFCA)

© 2009 American Agronomic Stewardship Alliance

Operational Area Containment & Pads for Bulk Pesticides

Purpose

This document is intended as a general aid to agricultural bulk pesticide dealers and distributors who must install or upgrade their containment pads and operational area containment to meet federal and state requirements.

State Requirements

Site owners or operators should check with appropriate regulatory groups, such as the state Environmental Protection Agency (EPA), department of environmental quality, department of agriculture, or state chemist office before implementing a solution.

Many states have requirements for containment pads that exceed federal rules.  For instance, some states require 1000 gallon capacity; others require capacity exceeding the largest container—even if the container is a truck.  Comply with whichever requirements are most strict.

Federal  Requirements

Federal EPA regulations require containment pads at most sites where bulk transfers of liquid pesticides are performed by August 16, 2009.  The 2006 EPA Container & Containment Rule includes storage containment, operational area containment, shut-off valves, inspection documentation, and more.  See http://www.epa.gov/pesticides/regulating/containers.htm.

The specific regulations are in Code of Federal Regulations Title 40 Subpart E—Standards for Pesticide Containment Structures.  This includes 40 CFR 165.80 through 165.97.

An overview prepared by the American Agronomic Stewardship Alliance (AASA) is available at:  www.aginspect.org .

Manufacturer / Registrant Requirements

Most registrants list their storage requirements in bulk handling guides or other published literature; however, the primary motivation for containment structures is regulatory compliance.  The registrants have no authority to grant exception to the August 2009 EPA requirements.

Who Must Comply

The applicability of the EPA rules effective in August 2009 is spelled out in 40 CFR 165.80(b).  The majority of retail bulk pesticide dealers and custom applicators are affected.  In general, containment is needed for dealers or applicators transferring or dispensing pesticide product to or from a stationary bulk pesticide container and delivery vehicles, nurse trucks, refillable packaging, service containers, application equipment.  Containment is also needed where refillable containers are emptied, cleaned, or rinsed.  It also includes transferring from one portable container to another if for sale or distribution.

Specific EPA Requirements

Some specific examples of the federal EPA containment requirements are below.  The rule is structured into two parts:  existing structures and new structures.  There are other requirements, such as mandatory self inspection and records.

Rev. 2, 5/22/09

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