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Label Review
Manual
Chapter 13: Storage and Disposal
Table of Contents
- Purpose of Manual
- What is a Pesticide?
- General Labeling Requirements
- Types of Label Reviews
- Ingredient Statement
- Use Classification
- Precautionary Labeling
- Environmental Hazards
- Physical or Chemical Hazards
- Worker Protection Labeling
- Directions for Use
- Labeling Claims
- Storage and Disposal
- Identification Numbers
- Company Name and Address
- Graphic & Symbols on Labels
- Content/Net Weight Statement
- Unique Product Labeling
- The Consumer Labeling Initiative and Pesticide Labels
PDF Version (31 pp, 209Kb, about PDF)
Current as of October 2008
On this page
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I. Introduction
Labels for pesticide products are required to bear instructions for the storage, residue removal, and disposal of pesticides and pesticide containers, per 40 CFR 156.10(i)(2)(ix). Storage and disposal instructions cover the appropriate storage of the pesticide product; removal of residues from the pesticide container; disposal of any unused pesticide product or any rinse liquids resulting from cleaning of pesticide application equipment or containers; and the disposal of the pesticide container.
II. Reviewing the Statements
A. Determining Storage and Disposal Labeling
When reviewing labels to determine whether the storage and disposal statements used are appropriate, refer to the information presented in this chapter along with PR Notices 83-3, 84-1, 84-5, 94-2, 2007-1, and 2007-4 and the regulations at 40 CFR 156.10(i)(2)(ix), 156.140, 156.144, 156.146, 156.156, and 156.159.
If a Reregistration Eligibility Decision (RED) Document exists or a Registration Review Decision has been made for the active ingredient(s) in the product for which labeling language is being reviewed, these decision documents may provide additional guidance. Please refer to the RED Document or the document that records the Registration Review Decision to determine if there are any additional required storage and disposal statements or if there is guidance on storage and disposal label language that should be considered in addition to or instead of the statements described in this chapter.
In addition, chemical-specific storage and disposal statements have been provided by the Agency for certain pesticides, as stated in PR Notice 84-1 (and an errata sheet dated April 12, 1984), and in PR Notice 84-5. These specific statements are described in more detail in the appropriate sections below.
B. Statement Location
The storage and disposal instructions must appear grouped together, preferably blocked, within the Directions for Use section and under the subheading “Storage and Disposal” (See 40 CFR 156.10(i)(2)(ix)).
The Agency prefers that storage and disposal instructions appear at the end of the Directions for Use section of the label. This placement eliminates the break between the heading "Directions for Use" and the body of the use directions. Where the Directions for Use are contained in a label booklet, the storage and disposal instructions can either appear at the end of the Directions for Use section in the booklet or on the label itself. If the storage and disposal instructions appear at the end of the Directions for Use section in the booklet, a reference to the storage and disposal instructions should be included in any referral statement on the label, e.g.;
“Refer to booklet for directions for use and storage and disposal instructions.”
In addition, some Storage and Disposal statements can appear durably marked on the container itself rather than on an attached paper or plastic label as long as the statements are referenced in the Storage and Disposal section of the attached label. (See 40 CFR 156.140)
C. Format
All products must bear the heading “STORAGE AND DISPOSAL.” These instructions must be set apart and clearly distinguishable from other directions for use. (See 40 CFR 156.10(i)(2)(ix)) Blocking these statements with a solid line (a box) is suggested as a means of increasing their prominence. For example:
STORAGE AND DISPOSAL Do not contaminate water, food, or feed by storage and disposal. Pesticide Storage . . . |
D. Type Size Requirements
The heading "STORAGE AND DISPOSAL" must be set in type of the same sizes as required for the child hazard warning. See 40 CFR 156.10(i)(2)(ix) and the table in 40 CFR 156.60(b).
III. General Storage and Disposal Statement
The Agency historically has required all products, except for residential/household use products, to bear the following statement for risk management purposes:
"Do not contaminate water, food, or feed by storage and disposal."
The Agency prefers that this statement appear immediately under the “Storage and Disposal” heading because it concerns both subjects; however, the statement may be placed elsewhere within the Storage and Disposal instructions.
IV. Pesticide Storage Statement
In addition to the general statement above, the label of each pesticide product is required to bear instructions for the proper storage of the pesticide. See 40 CFR 156.10(i)(2)(ix). Review the information and guidance below along with the referenced source documents to determine the appropriate pesticide storage language for product labels.
A. Chemical-Specific Storage Statements
As mentioned above, chemical-specific guidance on pesticide storage statements has been provided by the Agency. For some of these chemicals, the chemical-specific pesticide storage guidance provided in the PR Notices, and presented in Table 1 below, also includes some container handling instructions. This language has been updated to comply with the regulations at 40 CFR 156.140, and is noted in bold. Labels should bear these container management statements in addition to any other container management statements identified as necessary.
| TABLE 1: Preferred Active-Ingredient Specific Pesticide Storage Statements | ||
| Active Ingredient | Pesticide Storage Statements |
Source of Statement |
| Liquid sodium hypochlorite
and Liquid calcium hypochlorite |
“Store this product in a cool dry area, away from direct sunlight and heat to avoid deterioration. In case of spill, flood areas with large quantities of water. Product or rinsates that cannot be used should be diluted with water before disposal in a sanitary sewer.
Nonrefillable container. Do not reuse or refill this container. Offer for recycling if available or place in trash collection. Do not contaminate food or feed by storage, disposal, or cleaning of equipment.” |
PR Notice 84-1 & errata sheet, 40 CFR 156.140, and PR Notice 2007-4 |
| Solid calcium hypochlorite | “Keep this product dry in a tightly closed container when not in use. Store in a cool, dry, well ventilated area away from heat or open flame. In case of decomposition, isolate container (if possible) and flood area with large amounts of water to dissolve all materials before discarding this container. Nonrefillable container. Do not reuse or refill this container. Offer for recycling if available or place in trash collection. Do not contaminate food or feed by storage, disposal, or cleaning of equipment.” | PR Notice 84-1 & errata sheet, 40 CFR 156.140, and PR Notice 2007-4 |
| Terrazole | According to the Terrazole Registration Standard, all manufacturing use products must contain the statement “This product is corrosive to steel and many other metals. Do not transport or store in unlined metal containers.” | PR Notice 84-1 |
| Zinc phosphide | According to the Zinc Phosphide Registration Standard, the following statement must be used in addition to the guidance in PR Notice 83-3 and in this Label Review Manual: "Store in a dry place. Do not store in or around the home." | PR Notice 84-1 |
| Methyl bromide
and Methyl bromide plus 2% or less chloropicrin> |
“Store in dry, cool, well-ventilated area under lock and key. Post as a pesticide storage area. Do not contaminate water, food, or feed by storage.
Store cylinders upright, secured to a rack or wall to prevent tipping. Cylinders should not be subjected to rough handling or mechanical shock such as dropping, bumping, dragging, or sliding. Do not use rope slings, hooks, tongs or similar devices to unload cylinders. Transport cylinders using hand truck, fork truck or other device to which the cylinder can be firmly secured.
Do not remove valve protection bonnet and safety cap until immediately before use. Replace safety cap and valve protection bonnet when cylinder is not in use. When cylinder is empty, close valve, screw safety cap onto valve outlet, and replace protection bonnet before returning to shipper. Only the registrant is authorized to refill cylinders. Do not use cylinders for any other purpose. Follow registrant’s instructions for return of empty or partially empty cylinders.” |
PR Notice 84-5
|
Aluminum phosphide and Magnesium phosphide |
“Not for use or storage in or around inhabited areas. Protect from moisture, open flames, and heat. Store in a dry, cool, well-ventilated area under lock and key. Post as a pesticide storage area. Store container away from all liquids. Store so as to minimize hazards of tipping, spilling or accidental puncturing of the container. Keep container tightly closed when not in use. Do not contaminate water, food, or feed by storage or disposal.” |
PR Notices 84-5 and |
Chloropicrin |
“Store in dry, cool, well-ventilated area under lock and key. Post as a pesticide storage area. Do not contaminate water, food, or feed by storage or disposal. Persons moving or handling containers should wear protective clothing. Open container only in a well-ventilated area wearing protective clothing, and respiratory protection if necessary.” |
PR Notice 84-5 |
Sodium cyanide and Calcium cyanide |
“Store in dry, cool, well-ventilated area under lock and key. Post as a pesticide storage area. Store container away from all liquids. Store so as to minimize hazards of tipping, spilling or accidental puncturing of the container. Keep container tightly closed when not in use. Do not contaminate water, food, or feed by storage or disposal.” |
PR Notice 84-5 |
Ethylene oxide |
“Do not contaminate water, food, or feed by storage. Store in dry, cool, well-ventilated area under lock and key. Post as a pesticide storage area. Store cylinders upright, secured to a rack or wall to prevent tipping. Cylinders should not be subjected to rough handling or mechanical shock such as dropping, bumping, dragging, or sliding. Do not use rope slings, hooks, tongs or similar devices to unload cylinders. Transport cylinders using hand truck, fork truck or other device to which the cylinder can be firmly secured. Do not remove valve protection bonnet and safety cap until immediately before use. Replace safety cap and valve protection bonnet when cylinder is not in use. When cylinder is empty, close valve, screw safety cap onto valve outlet, and replace protection bonnet before returning to shipper. Only the registrant is authorized to refill cylinders. Do not use cylinders for any other purpose. Follow registrant’s instructions for return of empty or partially empty cylinders.” |
PR Notice 84-5 |
Sulfuryl fluoride |
“Store in dry, cool, well-ventilated area under lock and key. Post as a pesticide storage area. Do not contaminate water, food, or feed by storage. Store cylinders upright, secured to a rack or wall to prevent tipping. Cylinders should not be subjected to rough handling or mechanical shock such as dropping, bumping, dragging, or sliding. Do not use rope slings, hooks, tongs or similar devices to unload cylinders. Transport cylinders using hand truck, fork truck or other device to which the cylinder can be firmly secured. Do not remove valve protection bonnet and safety cap until immediately before use. Replace safety cap and valve protection bonnet when cylinder is not in use. When cylinder is empty, close valve, screw safety cap onto valve outlet, and replace protection bonnet before returning to shipper. Only the registrant is authorized to refill cylinders. Do not use cylinders for any other purpose. Follow registrant’s instructions for return of empty or partially empty cylinders.” |
PR Notice 84-5 |
Ethylene dichloride |
“Store in dry, cool, well-ventilated area under lock and key. Post as a pesticide storage area. Do not contaminate water, food, or feed by storage or disposal.” |
PR Notice 84-5 |
Carbon tetrachloride and Carbon tetrachloride and ethylene dichloride combined. |
“Store in dry, cool, well-ventilated area under lock and key. Post as a pesticide storage area. Do not contaminate water, food, or feed by storage.” |
PR Notice 84-5 |
Carbon disulfide and Carbon tetrachloride and carbon disulfide combined. |
“Keep container tightly closed and out of sunlight. Store in a dry, cool, well-ventilated area under lock and key. Post as a pesticide storage area. Do not contaminate water, food, or feed by storage.” |
PR Notice 84-5 |
B. Non-Chemical-Specific Storage Statements
For products containing active ingredients for which storage statements have not been specifically provided by PR Notices 84-1 or 84-5 or by an Agency decision document (e.g., a RED), registrants should develop storage instructions for each product using the general guidance provided below. Per PR Notice 83-3, the following factors should be considered in preparing storage statements. Label reviewers should consider these factors in determining whether the language used is appropriate.
- Conditions of storage that might alter the composition or usefulness of the pesticide. Examples could be temperature extremes, excessive moisture or humidity, heat, sunlight, friction, or contaminating substances or media
- Physical requirements of storage that might adversely affect the container of the product and its ability to continue to function properly. Requirements might include positioning of the container in storage, storage temperature, crushing or damage due to stacking, penetration by moisture, and ability to withstand shock or friction.
- Specifications for handling the pesticide container, including movement of the container within the storage area, proper opening and closing procedures (particularly for opened containers), and measures to minimize exposure while opening or closing the container.
- Instructions on what to do if the container is damaged in any way, or if the pesticide is leaking or has been spilled, and precautions to minimize exposure if damage occurs.
- General precautions concerning locked storage, storage in original container only, and separation of pesticides during storage to prevent cross-contamination of other pesticides, fertilizer, food, and feed.
- General storage instructions for household products should emphasize storage in the original container and placement in locked storage areas.
C. Additional Guidance on Storage Statements
Additional guidance on pesticide storage can be found on state extension Web sites, as well as state and federal agency and industry association Web sites. Safe storage is essential to protect against accidental exposure to children, bystanders and workers, environmental contamination due to leaks and spills, and intentional exposure due to vandalism or terrorism. Common features included in much of the storage guidance are the need for security (locks, restricted access, frequent inspection for tampering, signage in appropriate languages); recordkeeping (inventory, deliveries, employee licenses, contact and emergency numbers posted); spill prevention and cleanup (emergency response plan, cleanup and first aid supplies); and site integrity (ventilation, lighting, pallets and protection from weather and run on, secondary containment, etc.).
The type of storage instructions provided may include statements such as the following examples suggested by the Agency. Some of these may not be appropriate for all pesticide products. The Agency provided these suggested statements as a result of a recommendation from the State FIFRA Issues Research and Evaluation Group.
“Always store pesticides in the original container. If a leaky container must be contained within another, mark the outer container to identify the contents.”
“Storage areas must be locked and secure from vandalism, with precautionary signs posted.”
“The storage area must be dry, well-lit, and well-ventilated. Keep pesticide storage areas clean. Clean up any spills promptly.”
“Store pesticides away from food, pet food, feed, seed, fertilizers, and veterinary supplies.”
“Protect pesticide containers from extreme heat and cold.”
“Store herbicides, insecticides and fungicides in separate areas within the storage unit.”
“Place liquid formulations on lower shelves and dry formulations above.
“Maintaining a spill kit and fire extinguisher on hand and having emergency phone numbers posted will allow you to be prepared for emergencies.”
“If spill cleanup PPE is stored nearby, but outside the pesticide storage area, it will be accessible when needed.”
V. Pesticide Disposal and Container Handling Statements
In addition to the general statements for pesticide storage, pesticide labels are required to bear pesticide disposal and container handling instructions for users. (See 40 CFR 156.10(i)(2)(ix); 40 CFR Part 156, Subpart H; and 40 CFR Part 165). Pesticide disposal instructions include information on how to dispose of leftover pesticide products, and container handling instructions include information on how to remove residues from emptied pesticide containers and what to do with the pesticide container after it is emptied (recycle, disposal, e.g.).
Pesticide disposal and container handling statements are generally specific to the uses of the product contained (for example, household products have different pesticide disposal and container disposal instructions than agricultural products) and the type of container itself. Review the information and guidance below and the referenced source documents to determine the appropriate pesticide product disposal language for product labels. Language in quotation marks is actual label language that may be used verbatim and additional guidance is provided in brackets. Please note that only label language required by a final rule is required to be used verbatim.
A. Products Labeled for Household or Residential Uses Only
As set out in PR Notice 2007-1, the Agency considers a non-antimicrobial pesticide product to be a residential/household use pesticide product, regardless of the size of the container, if either of the following criteria are met:
- the intended end use of the product is in or around a household or residence by a resident; or,
- the product is regularly available to household consumers for purchase, and of a size and type practicable for household use, regardless of whether it is also marketed for agricultural use.
Please note that the terms “residential,” “household,” “household-use,” “homeowner,” and “domestic use” may have been used in other PR Notices and mean the same thing for the purposes of this chapter. For the purposes of storage and disposal guidance, antimicrobial products will be considered residential based on the same criteria.
Labels of household or residential products for which pesticide disposal and container handling statements have not been specifically identified by the Agency should bear the pesticide disposal and container handling statements provided in Table 2 below. For non-antimicrobial household or residential products, pesticide disposal and container handling instructions were originally provided in PR Notice 2001-6 (superseded by PR Notice 2007-1),have been updated to reflect the container and containment regulations published in August 2006 and described in PR Notice 2007-4, and are presented in Table 2. For antimicrobial products, the pesticide disposal and container handling instructions provided in PR Notices 83-3 and 84-1 are still valid, have been updated to reflect the container and containment regulations, and are presented in Table 2. Statements in quotation marks may be used verbatim; additional guidance is provided in brackets. Please note that only label language required by a final rule is required to be used verbatim, this required language in indicated in bold in Table 2 below.
The Agency allows alternative versions of portions of these statements, based on the container and containment regulations in 40 CFR part 156.140 (and as presented in PR Notice 2007-4) and PR Notice 2007-1. These alternative statements and the circumstances under which the alternative statements may be used are presented in Table 2a below. As in Table 2, regulatory language is provided in bold.
TABLE 2: Recommended Pesticide Disposal and Container Handling Statements for Household or Residential Use Products. |
|||
Container Type |
Product Type |
Pesticide Disposal and Container Handling Statements |
Source |
Pressurized Container |
Any |
“Do Not Puncture or Incinerate! or “Do Not Puncture or Incinerate! |
PR Notices 94-2, 2007-1, and 2007-4 40 CFR 156.140(a) |
Non-Pressurized Container |
Any |
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type statement in Table 2a] |
PR Notices 2007-1 and 2007-4 40 CFR 156.140(a) |
Pressurized or Non-Pressurized Container |
Anti-microbial |
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type statement in Table 2a]
or “Nonrefillable container. Do not reuse or refill this container.” [or alternative container type statement in Table 2a] |
PR Notices 83-3, 40 CFR 156.140(a) |
TABLE 2a: Optional Alternative Pesticide Disposal and Container Handling Statements for Household or Residential Use Products. |
|||
Applicable Products |
Statement From Table 2 |
Optional Alternative Statement(s) |
Source |
All products |
“Call your local solid waste agency for disposal instructions.” |
“Call your local solid waste agency or” [insert toll free number or web site] “for disposal instructions.” |
PR Notice 2007-1 |
All products |
“Offer for recycling, if available.” |
“Offer for reconditioning, if appropriate.” or [A recycling statement approved by EPA and published in an EPA document, such as a PR Notice.] or [An alternative recycling statement that has been reviewed and approved by EPA. For example, registrants have the option of using more specific recycling statements if they meet the Federal Trade Commission guidelines, per PR Notice 2007-1.] |
PR Notice 2007-4 40 CFR 156.140(a)(3) |
“Ready-to-use” products with directions allowing a concentrate to be poured into the container and diluted by the end user |
“Nonrefillable container. Do not reuse or refill this container.” |
“Nonrefillable container. Do not reuse or refill this container unless the directions for use allow a different (concentrated) product to be diluted in the container.” |
PR Notice 2007-4 40 CFR 156.140(a)(1) and (2) |
All products in pressurized containers |
“If recycling option is not available, wrap the container and discard in the trash.” |
“If recycling option is not available, discard in the trash.” |
PR Notices 94-2 and 2007-1 |
As presented above, registrants may include an alternate information source in the directions for partly filled containers, such as a toll-free number or a website, in addition to the phrase “local solid waste agency.” The Agency’s intent in allowing the use of an additional information source in addition to or instead of referring consumers to the “local solid waste agency” is that consumers have convenient, immediate access to locally accurate disposal information. (See PR Notice 2007-1). EPA considers several toll-free information numbers or websites, including 1-800-CLEANUP and its associated website earth911.org and the toll-free numbers or websites that some individual companies often provide on their product labels, to be likely to meet these criteria. EPA does not expect registrants to create a new toll-free number or website since the use of a toll-free number or website is optional.
If a registrant chooses to include an alternate information source, that telephone number, website, or other source should meet the criteria described below:
- the source must provide 18-24 hours service to users;
- the source must be free of cost to the caller;
- the source must be nationally viable; i.e., have the same phone number available in all states;
- the source must provide disposal instructions that reflect the advice of the local solid waste authority for the user’s location, and/or provide a direct phone number for the user’s appropriate local or state authority; and
- the source must be reasonably assured of reliable, long-term funding to ensure the source’s continued existence at an operating level sufficient to meet user demand.
B. Hazardous Waste or Highly Toxic Products
Pesticide products that meet any of the following criteria should bear one of the pesticide product disposal statements as well as the appropriate container handling statements.noted in sub-sections 1 and 2, respectively, below :
- contain active ingredients that, when discarded, are hazardous wastes under the Resource Conservation and Recovery Act (RCRA), 40 CFR 261.33(e) and (f);
- when discarded, meet the criteria in 40 CFR 261, Subpart C for a characteristic hazardous waste under RCRA;
- are assigned to Toxicity Category I on the basis of oral or dermal toxicity, skin or eye irritation potential; or,
- are assigned Toxicity Category I or II on the basis of acute inhalation toxicity.
1. Pesticide Product Disposal Statements. The Agency developed the following statement to provide one disposal statement that is appropriate for all pesticide products that meet the above criteria and to correct some confusion between pesticide toxicity categories and RCRA hazardous wastes in PR Notice 83-3:
“Pesticide wastes may be hazardous. Improper disposal of excess pesticide, spray mixture or rinsate is a violation of Federal Law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance.”
In addition, the statements from PR Notice 83-3 are provided as alternative statements, but with additional information on when each statement would be appropriate to use. The following disposal statement may be used for pesticide products that are not intended solely for residential/household use and that contain an active ingredient that is an acute hazardous waste as specified in 40 CFR 261.33(e):
"Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of Federal Law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance."
The following disposal statement may be used for pesticide products that 1) are not intended solely for residential/household use and that contain an active ingredient that is a toxic hazardous waste as specified in 40 CFR 261.33(f) (see PR Notice 83-3 for list) or that 2) meet any of the criteria in 40 CFR 261, Subpart C, for a characteristic hazardous waste:
"Pesticide wastes are toxic. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of Federal Law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste representative at the nearest EPA Regional Office for guidance."
2. Container Handling Statements. For pesticide products that meet any of the four above-mentioned criteria, registrants should use one of the container handling statements noted below. Alternately, the container handling statements presented in Table 3 below may be used on the labels of pesticide products that contain active ingredients that, when discarded, are hazardous wastes under the RCRA, 40 CFR 261.33(e). These statements were originally developed for Furadan 3G and Furadan 4F, but are also appropriate for any pesticide products that are acute hazardous wastes when discarded. These statements have been updated to comply with the container and containment regulations (see language in bold).
PR Notice 83-3 also specified this statement for products that contain inert ingredients that are a toxic hazardous waste or products that meet any of the criteria in 40 CFR Part 261 Subpart C for a characteristic waste. However, such products may not be toxic hazardous wastes when disposed of, so the statement is misleading for these products.
TABLE 3: Recommended Container Handling Statements for Pesticide Products that are Acute Hazardous Waste When Discarded |
||
Container/ Formulation |
Pesticide Disposal and Container Handling Statements |
Source |
For nonrefillable bags of granular or dry formulation |
Container Handling Statements: |
|
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type statement from Table 6] |
PR Notice 2007-4, and 40 CFR 156.140(a)(1) and (2) |
|
“Completely empty bag into application equipment by shaking and tapping sides and bottom to loosen clinging particles. If not emptied in this manner, the bag may be considered an acute hazardous waste and must be disposed in accordance with local, state and federal regulations. |
40 CFR 156.144 and 2003 Label Review Manual |
|
When completely empty, offer for recycling if available,” [or alternative recycling statement from Table 6] “…or dispose of bag in a sanitary landfill or by incineration, or, if allowed by state and local authorities, by burning. If burned, stay out of smoke.” [or alternative burning statement from Table 6] |
40 CFR 156.140(a)(3), PR Notice 2007-4, and PR Notice 83-3 |
|
For nonrefillable plastic or metal containers with dry flowable or liquid formulation |
Container Handling Statements: |
|
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type statement from Table 6] |
40 CFR 156.140(a)(1) and (2) and PR Notice 2007-4 |
|
[Insert appropriate residue removal instructions by formulation and container type, as described in Table 5 below] |
40 CFR 156.144 and PR Notice 2007-4 |
|
“Then offer for recycling if available,” [or alternative recycling statement from Table 6] “or puncture and dispose in a sanitary landfill, or by other procedures approved by state and local authorities. If rinsate cannot be used, follow pesticide disposal instructions. If not triple rinsed, these containers are acute hazardous wastes and must be disposed in accordance with local, state and federal regulations. DO NOT cut or weld metal containers.” |
40 CFR 156.140(a)(3), PR Notice 2007-4, and PR Notice 83-3 and 2003 Label Review Manual. |
|
C. All Other Products
For pesticide products labeled for all uses other than household or residential uses and for which pesticide disposal or container handlings statements have not been specifically identified by the Agency (e.g., in a RED or a PR Notice), registrants should use the pesticide disposal and container handling statements described below. Statements in quotation marks may be used verbatim and additional guidance is provided in brackets. However, please note that only label language required by a final rule is required to be used verbatim. Any regulatory language in indicated in the tables below in bold text.
1.. Pesticide Product Disposal Statements. Pesticide products that are not hazardous wastes or highly toxic products as described above and that are registered for all uses other than household or residential should bear the following pesticide disposal statement:
“Wastes resulting from the use of this product must be disposed of on site or at an approved waste disposal facility.”
Alternately, labels may bear the following pesticide disposal statement that does not direct the user to dispose of wastes on site. This language may be preferred in some states.
“To avoid wastes, use all material in this container by application according to label directions. If wastes cannot be avoided, offer remaining product to a waste disposal facility or pesticide disposal program (often such programs are run by state or local governments or by industry).”
2. Container Handling Statements. Labels of products for which pesticide disposal and container handling statements have not been specifically identified by the Agency (e.g., in a RED) should use Tables 4 through 7 to determine the recommended container handling statements. A complete container handling statement should include container-type language, residue removal instructions, recycling statements, and container disposal instructions.
Table 4 provides the recommended container handling statements by container type based on the recommended language originally published in PR Notice 83-3 and updated to reflect the container and containment regulations published in August 2006 (and also PR Notice 2007-4). Table 5 provides options for residue removal instructions from the container and containment regulations and from PR Notice 83-3. Please note that the container and containment regulations provide alterative versions of some of these statements, and that the Agency would like to provide an alternative to the burning statement provided in PR Notice 83-3. The alternative statements and the circumstances under which they can be used are presented in Table 6 below.
As above, statements in quotation marks may be used verbatim; additional guidance is provided in brackets. Please note that only label language required by a final rule is required to be used verbatim, and this regulatory language is indicated in the tables below in bold text.
TABLE 4: Container Handling Statements for Products Registered for All Uses Other Than Household or Residential |
||
Container Type |
Container Handling Statements |
Source |
Non-Aerosol Metal Containers - Nonrefillable |
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type language from Table 6] |
40 CFR 156.140(a)(1) and (2) and |
[Insert appropriate residue removal instructions by formulation and container type. See Table 5.] |
40 CFR 156.144 and |
|
“Then offer for recycling if available or reconditioning if appropriate” [or alternative recycling statement from Table 6] “…or puncture and dispose of in a sanitary landfill, or by other procedures approved by state and local authorities.” |
40 CFR 156.140 (a)(3), Notice 2007-4 and PR Notice 83-3 |
|
Non-Aerosol Metal Containers - Refillable |
“Refillable container. Refill this container with pesticide only. Do not reuse this container for any other purpose.” [or alternative container type language from Table 6] |
40 CFR 156.140(b) and PR Notice 2007-4 |
“Cleaning the container before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller.” [or alterative cleaning statement from Table 6] |
40 CFR 156.156(a) and (b) and PR Notice 2007-4 |
|
“Then offer for recycling if available or reconditioning if appropriate” [or alternative recycling statement from Table 6] “…or puncture and dispose of in a sanitary landfill, or by other procedures approved by state and local authorities.” |
PR Notice 83-3 and consistency with the recycling section of the nonrefillable container statement above. |
|
Plastic Containers - Nonrefillable |
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type language from Table 6] |
40 CFR 156.140(a)(1) and (2) and |
[Insert appropriate residue removal instructions by formulation and container type. See Table 5.] |
40 CFR 156.144 and |
|
“Then offer for recycling if available” [or alternative recycling statement from Table 6] “…or puncture and dispose of in a sanitary landfill, or by incineration, or, if allowed by state and local authorities, by burning If burned, stay out of smoke.” [or alternative burning statement from Table 6] |
40 CFR 156.140 (a)(3), PR Notice 2007-4, and PR Notice 83-3 |
|
Plastic Containers - Refillable |
“Refillable container. Refill this container with pesticide only. Do not reuse this container for any other purpose.” [or alternative container type language from Table 6] |
40 CFR 156.140(b) and PR Notice 2007-4 |
“Cleaning the container before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller.” [or alterative cleaning statement from Table 6] |
40 CFR 156.156(a) and (b) and |
|
“Then offer for recycling if available” [or alternative recycling statement from Table 6] “or puncture and dispose of in a sanitary landfill, or by incineration, or, if allowed by state and local authorities, by burning If burned, stay out of smoke.” [or alternative burning statement from Table 6] |
PR Notice 83-3 and consistency with the recycling section of the nonrefillable container statement above. |
|
Glass Containers - Nonrefillable |
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type language from Table 6] |
40 CFR 156.140(a)(1) and (2) and |
[Insert appropriate residue removal instructions by formulation and container type. See Table 5.] |
40 CFR 156.144 and |
|
“Then offer for recycling if available” [or alternative recycling statement from Table 6] “…or dispose of in a sanitary landfill, or by other procedures approved by state and local authorities.” |
40 CFR 156.140 (a)(3), PR Notice 2007-4, and PR Notice 83-3 |
|
Glass containers - Refillable |
“Refillable container. Refill this container with pesticide only. Do not reuse this container for any other purpose.” [or alternative container type language from Table 6] |
40 CFR 156.140(b) and PR Notice 2007-4 |
“Cleaning the container before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller.” [or alterative cleaning statement from Table 6] |
40 CFR 156.156(a) and (b) and |
|
“Then offer for recycling if available” [or alternative recycling statement from Table 6] “…or dispose of in a sanitary landfill, or by other procedures approved by state and local authorities.” |
PR Notice 83-3 and consistency with the recycling section of the nonrefillable container statement above. |
|
Aerosol Containers |
“Do Not Puncture or Incinerate!
or “Do Not Puncture or Incinerate! [Please note that while these statements are from PR Notices that address household or residential products, the Agency is recommending the same statements for all other aerosol products.] |
PR Notices 94-2, 2007-1, and 2007-4 Need to make sure it is not significant new guidance to recommend hh language for non-hh aerosols. |
Paper and Plastic Bags - Nonrefillable |
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type language from Table 6] |
40 CFR 156.140(a)(1) and (2) and |
“Completely empty bag into application equipment.” |
40 CFR 156.144 and |
|
“Then offer for recycling if available” [or alternative recycling statement from Table 6] “…or dispose of empty bag in a sanitary landfill or by incineration or, if allowed by state and local authorities, by burning. If burned, stay out of smoke.” [or alternative burning statement from Table 6] |
40 CFR 156.140 (a)(3), PR Notice 2007-4, and PR Notice 83-3 |
|
Paper and Plastic Bags - Refillable |
“Refillable container. Refill this container with pesticide only. Do not reuse this container for any other purpose.” [or alternative container type language from Table 6] |
40 CFR 156.140(b) and PR Notice 2007-4 |
“Cleaning the container before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller.” [or alterative cleaning statement from Table 6] |
40 CFR 156.156(a) and (b), PR Notice 2007-4, and |
|
“Then offer for recycling if available” [or alternative recycling statement from Table 6] “…or dispose of empty bag in a sanitary landfill or by incineration or, if allowed by state and local authorities, by burning. If burned, stay out of smoke.” [or alternative burning statement from Table 6] |
PR Notice 83-3 and consistency with the recycling section of the nonrefillable container statement above. |
|
Fiber Drums with Liners - Nonrefillable |
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type language from Table 6] |
40 CFR 156.140(a)(1) and (2) and |
“Completely empty liner by shaking and tapping sides and bottom to loosen clinging particles. Empty residue into application equipment.” |
40 CFR 156.144 and |
|
“Then offer for recycling if available” [or alternative recycling statement from Table 6] “…or dispose of liner in a sanitary landfill or by incineration or, if allowed by state and local authorities, by burning. If burned, stay out of smoke.” [or alternative burning statement from Table 6] |
40 CFR 156.140 (a)(3), PR Notice 2007-4, and PR Notice 83-3 |
|
Fiber Drums with Liners - Refillable |
“Refillable container. Refill this container with pesticide only. Do not reuse this container for any other purpose.” [or alternative container type language from Table 6] |
40 CFR 156.140(b) and PR Notice 2007-4 |
“Cleaning the container before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller.” [or alterative cleaning statement from Table 6] |
40 CFR 156.156(a) and (b), PR Notice 2007-4, and |
|
“Then offer for recycling if available” [or alternative recycling statement from Table 6] “…or dispose of liner in a sanitary landfill or by incineration or, if allowed by state and local authorities, by burning. If burned, stay out of smoke.” [or alternative burning statement from Table 6] |
PR Notice 83-3 and consistency with the recycling section of the nonrefillable container statement above. |
|
Compressed Gas Cylinders |
“Refillable container. Refill this container with pesticide only. Do not reuse this container for any other purpose.” [or alternative container type language from Table 6] |
40 CFR 156.140(b) and PR Notice 2007-4 |
[The Agency will likely waive the requirement for residue removal statements for gas cylinders on a case-by-case basis.] |
40 CFR 156.144 (a) and (d) |
|
“Return empty cylinder for reuse” or other similar wording. |
PR Notice 83-3 |
|
Foil Outer Pouches of Water Soluble Packets (WSP) |
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type language from Table 6] |
40 CFR 156.140(a)(1) and (2) and PR Notice 2007-4 |
[No residue removal statement is currently specified in regulations or policy] |
40 CFR 156.144 (a) and (d) and PR Notice 83-3 |
|
“Offer for recycling, if available.” [or alternative recycling statement from Table 6] “…or, dispose of the empty outer foil pouch in the trash as long as WSP is unbroken” |
40 CFR 156.140 (a)(3), PR Notice 2007-4 and PR Notice 83-3 |
|
All Other Nonrefillable Containers |
“Nonrefillable container. Do not reuse or refill this container.” [or alternative container type language from Table 6] |
40 CFR 156.140(a)(1) and (2) and PR Notice 2007-4 |
[Insert appropriate residue removal instructions by formulation and container type. See Table 5.] |
40 CFR 156.144 and PR Notice 2007-4 |
|
“Then offer for recycling if available” [or alternative recycling statement from Table 6] “…or puncture and dispose of in a sanitary landfill, or by incineration, or by other procedures allowed by state and local authorities.” [or other disposal statement suggested by registrant and approved by EPA] |
40 CFR 156.140 (a)(3), PR Notice 2007-4 and PR Notice 83-3 |
|
All Other Refillable Containers |
“Refillable container. Refill this container with pesticide only. Do not reuse this container for any other purpose.” [or alternative container type language from Table 6] |
40 CFR 156.140(b) and PR Notice 2007-4 |
“Cleaning the container before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller.” [or alterative cleaning statement from Table 6] |
40 CFR 156.156(a) and (b) and |
|
“Then offer for recycling if available or…” [or alternative recycling statement from Table 6] “…or puncture and dispose of in a sanitary landfill, or by incineration, or by other procedures allowed by state and local authorities.” [or other disposal statement suggested by registrant and approved by EPA] |
PR Notice 83-3 and consistency with the recycling section of the nonrefillable container statement above. |
|
Manufacturer may replace this phrase with one indicating whether and how the fiber drum may be reused.
Manufacturer may replace this phrase with one indicating whether and how the fiber drum may be reused.
TABLE 5: Residue Removal Instructions (See also 2007-4) |
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Pesticide Formulation Type |
Type of Container |
Residue Removal Instructions |
All dilutable formulations |
Rigid, nonrefillable containers (all sizes) |
“Clean container promptly after emptying.” [40 CFR 156.146(a)(1)] or “Triple rinse or pressure rinse container (or equivalent) promptly after emptying.” [40 CFR 156.146(a)(2)] or “Triple rinse container (or equivalent) promptly after emptying.” [40 CFR 156.146(a)(3)] [On the pesticide product label, the chosen statement from this row must immediately precede the required triple rinse (and pressure rinse, if applicable) statement(s) from the following rows.] [40 CFR 156.146(a)] [A registrant who wishes to require users to clean a container with a diluent other than water (e.g., solvents) must submit to EPA a written request (i.e., an amendment) to modify the residue removal instructions for review and approval. [40 CFR 156.146(d)] [Note that EPA may, on its own initiative or based on data submitted by any person, modify or waive the requirements of 40 CFR 156.146] [ 40 CFR 156.144(d)] |
Liquid dilutable formulations |
Rigid, nonrefillable containers small enough to shake (i.e., with |
“Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. Fill the container ¼ full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times.” [40 CFR 156.146(b)(1)] [If pressure rinsing is referenced, the following pressure rinse instructions must be included in addition to the triple rinse instructions in this row.] [40 CFR 156.146(c)] “Pressure rinse as follows: Empty the remaining contents into application equipment or a mix tank and continue to drain for 10 seconds after the flow begins to drip. Hold container upside down over application equipment or mix tank or collect rinsate for later use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at about 40 PSI for at least 30 seconds. Drain for 10 seconds after the flow begins to drip.” [40 CFR 156.146(c)(1)] [Note that EPA may, on its own initiative or based on data submitted by any person, modify or waive the requirements of 40 CFR 156.146] [ 40 CFR 156.144(d)] |
Solid |
Rigid, nonrefillable containers small enough to shake (i.e., with |
“Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank. Fill the container ¼ full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times.” [40 CFR 156.146(b)(2)] [If pressure rinsing is referenced, the following pressure rinse instructions must be included in addition to the triple rinse instructions in this row.] [40 CFR 156.146(c)] “Pressure rinse as follows: Empty the remaining contents into application equipment or a mix tank. Hold container upside down over application equipment or mix tank or collect rinsate for later use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at about 40 PSI for at least 30 seconds. Drain for 10 seconds after the flow begins to drip.” [40 CFR 156.146(c)(2)] [Note that EPA may, on its own initiative or based on data submitted by any person, modify or waive the requirements of 40 CFR 156.146] [ 40 CFR 156.144(d)] |
All dilutable formulations |
Rigid nonrefillable containers that are too large to shake (i.e., with capacities greater than 5 gallons or 50 lbs) |
“Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank. Fill the container ¼ full with water. Replace and tighten closures. Tip container on its side and roll it back and forth, ensuring at least one complete revolution, for 30 seconds. Stand the container on its end and tip it back and forth several times. Turn the container over onto its other end and tip it back and forth several times. Empty the rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Repeat this procedure two more times.” [40 CFR 156.146(b)(3)] [If pressure rinsing is referenced, one of the following pressure rinse instructions must be included in addition to the triple rinse statement described in this box.] [40 CFR 156.146(c)] [for liquids] “Pressure rinse as follows: Empty the remaining contents into application equipment or a mix tank and continue to drain for 10 seconds after the flow begins to drip. Hold container upside down over application equipment or mix tank or collect rinsate for later use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at about 40 PSI for at least 30 seconds. Drain for 10 seconds after the flow begins to drip.” [40 CFR 156.146(c)(1)] or [for solids] “Pressure rinse as follows: Empty the remaining contents into application equipment or a mix tank. Hold container upside down over application equipment or mix tank or collect rinsate for later use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at about 40 PSI for at least 30 seconds. Drain for 10 seconds after the flow begins to drip.” [40 CFR 156.146(c)(2)] or [Pressure rinsing instructions more suitable for larger containers. A registrant who wishes to provide users with different pressure rinsing instructions for larger containers must submit to EPA a written request (i.e., an amendment) bearing the proposed language for review and approval. See section IV.B of PR Notice 2007-4 for additional information.] [ 40 CFR 156.144(d)] [Note that EPA may, on its own initiative or based on data submitted by any person, modify or waive the requirements of 40 CFR 156.144 and 156.146] [ 40 CFR 156.144(d)] |
All other products |
Nonrefillable containers |
For nonrefillable containers, the container-containment regulations in 40 CFR 156.144 and 156.146 only specify residue removal instructions for dilutable pesticide products in rigid containers. For other products, registrants may use residue removal instructions from PR Notice 83-3 (see list below) or may suggest other residue removal instructions. Examples of residue removal instructions from PR Notice 83-3: |
All other products |
Refillable Containers |
[Instructions for cleaning each refillable container prior to disposal are required. The residue removal instructions must be appropriate for the characteristics and formulation of the pesticide product and must be adequate to protect human health and the environment. The statement on residue removal could include any one of the following, and must be reviewed and approved by the Agency (unless the statement in quotation marks is used):
[Note that EPA may, on its own initiative or based on data submitted by any person, modify or waive the requirements of 40 CFR 156. 156] [ 40 CFR 156.144(d)] |
TABLE 6: Optional Alternative Container Handling Statements for Products Registered for All Uses Other Than Household or Residential. |
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Applicable Products |
Statement From |
Optional Alternative Statement(s) |
Source |
All Products |
“Offer for recycling, if available.” |
“Offer for reconditioning, if appropriate.” or “Once cleaned, some agricultural plastic pesticide containers can be taken to a container collection site or picked up for recycling. To find the nearest site, contact your chemical dealer or manufacturer, or contact [a pesticide container recycling organization] at [phone number] or [website].” or [A recycling statement approved by EPA and published in an EPA document, such as a PR Notice.] or [An alternative recycling statement that has been reviewed and approved by EPA. For example, registrants have the option of using more specific recycling statements if they meet the Federal Trade Commission guidelines, per PR Notice 2007-1.] |
PR Notice 2007-4 and 40 CFR 156.140(a)(3) |
All Products in nonrefillable containers |
“Nonrefillable container. Do not reuse or refill this container.” |
“Nonrefillable container. Do not reuse this container to hold materials other than pesticides or dilute pesticides (rinsate). After emptying and cleaning, it may be allowable to temporarily hold rinsate or other pesticide-related materials in the container. Contact your state regulatory agency to determine allowable practices in your state.” |
PR Notice 2007-4 and 40 CFR 156.140(a)(1) and (2) |
“Ready-to-use” products with directions allowing a concentrate to be poured into the container and diluted by the end user |
“Nonrefillable container. Do not reuse or refill this container.” |
“Nonrefillable container. Do not reuse or refill this container unless the directions for use allow a different (concentrated) product to be diluted in the container.” |
PR Notice 2007-4 and 40 CFR 156.140(a)(2)(iii) |
All products in refillable containers. |
“Refillable container. Refill this container with pesticide only. Do not reuse this container for any other purpose” |
“Refillable container. Refill this container with” [insert common chemical name] “…only. Do not reuse this container for any other purpose.” |
PR Notice 2007-4 and 40 CFR 156.140(b)(2) |
All products in refillable containers. |
“Cleaning the container before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller” |
“Pressure rinsing the container before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller.” |
PR Notice 2007-4 and 40 CFR 156.156(a)(2) |
All products in containers that could be burned. |
“…or, if allowed by state and local authorities, by burning. If burned, stay out of smoke.” |
“Do not burn, unless allowed by state and local ordinances.” |
Agency suggestion. This statement may be preferred by some state regulatory agencies. |
VI. Examples of Storage and Disposal Labeling
A. Household or Residential Use Product
The box below is an example of a typical Storage and Disposal section of a household product label:
STORAGE AND DISPOSAL Do not contaminate water, food, or feed by storage and disposal. Pesticide Storage Store in a cool, dry area. Always store pesticides in the original container. Store away from food and pet food. Pesticide Disposal and Container Handling Nonrefillable container. Do not reuse or refill this container. |
B. Products that are Hazardous Waste or Highly Toxic
The box below is an example of a typical Storage and Disposal section of a label for a product that is an acute hazardous waste when disposed:
STORAGE AND DISPOSAL Do not contaminate water, food, or feed by storage and disposal. Pesticide Storage Store in a cool, dry area under lock and key. Post as a pesticide storage area. Always store pesticides in the original container. Store away from food, pet food, feed, seed, fertilizers, and veterinary supplies. Place liquid formulations on lower shelves and dry formulations above. Pesticide Disposal Pesticide wastes may be hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of Federal Law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance Completely empty bag into application equipment by shaking and tapping sides and bottom to loosen clinging particles. If not emptied in this manner, the bag may be considered an acute hazardous waste and must be disposed in accordance with local, state and federal regulations. When empty, dispose of bag in a sanitary landfill or by incineration or offer for recycling if available. Do not burn, unless allowed by state or local ordinances. |
C. All Other Products
The box below is an example of a typical Storage and Disposal section of a dilutable agricultural product in a nonrefillable plastic container:
STORAGE AND DISPOSAL Do not contaminate water, food, or feed by storage and disposal. Pesticide Storage Store in a cool, dry area under lock and key. Post as a pesticide storage area. Always store pesticides in the original container. Store away from food, pet food, feed, seed, fertilizers, and veterinary supplies. Place liquid formulations on lower shelves and dry formulations above. Pesticide Disposal Container Handling |