Pesticide Stewardship Conference
Mobile, Alabama
February 5-7, 2013
Reusable Industrial Packaging Association

RIPA is the U.S.-based trade association for firms that recondition,
recycle, and/or manufacture industrial containers such as drums and
IBCs.

The membership is comprised of approximately 75 U.S firms
operating over 100 facilities.

Members are also located in Canada, Mexico and other nations.

RIPA’s Mission: Promoting Safe and Sustainable Design,
Manufacturing, Remanufacturing and Reuse for the Industrial
Packaging Industry.
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Composite IBCs in “AgChem” Service
Pesticides: Herbicides and Insecticides
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Glossary of Terms
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Registrant – Pesticide manufacturer

Ag Retailer – Co-ops; farm supply outlets; pesticide
distributors

Hazmat Mark – DOT mark indicating the container’s UN
certification and performance rating

FIFRA Label – EPA; “FIFRA” is federal pesticide law; label
includes registrant’s instructions on product use and
container management

EPA Container and Containment Rule - Into effect August
16, 2011
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Intermediate Bulk Container (IBC) – a DOT hazmat
container term

Composite IBC - HDPE plastic bottle-in-a-cage design;
typically 275 and 330 gallons, blow-molded bottle.

Mini Bulk – AgChem industry term for similarly sized
containers – but generally all “heavy” plastic, “roto-molded”

Refillable Container - An EPA term; a narrower construct
than the term “reusable” or “reconditioned” as found in DOT
hazmat rules; typically refilled with the same or very similar
product for distribution to application site(s) by coops and
ag’ retailers; may be refilled by registrants only when triple
rinsed.
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Recycling - General term; conversion of a used product into another type of
product. See ACRC list of approved products.
Reconditioning – DOT hazmat term; re-certified for reuse in hazmat service;
marked as recertified (i.e., leakproofness tested).
IBC Reprocessing – DOT hazmat term for reconditioning & re-certifying IBCs;
Includes:
Routine Maintenance (washing) – requires visual verification of
“leaktightness”
Repair (includes re-bottling) – requires leakproofness test
Remanufacturing (conversion to new hazmat design type; also,
“cross bottling”; full certification tests required)
2 ½-Year & 5-Year Tests and Inspections – For IBC packaging; part of the
Qualification and Maintenance rules
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Refillers must repackage into “refillable containers” that:

Comply with at least DOT Packing Group III standards that EPA
has adopted by reference;

Are durably marked with a serial number or “bar code”;

Have a tamper-evident device, one-way valve or both on each
opening (other than a vent); and

Are on the registrant’s description of acceptable containers.
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The following requirements apply each time a container is refilled.
The refiller must:
Identify the pesticide previously in the container (by looking at
the label);
Visually inspect the container to ensure that it is in good shape;
Clean the container if necessary –
The refillable container must be cleaned between uses
unless all tamper-evident devices and one-way valves are
intact and it is filled with the same or a very similar product.
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Some things to consider:
•
Pesticide companies have been moving to composite IBCs in recent years
due to their lower cost compared to traditional “mini bulks”.
•
The industry’s Ag Container Recycling Council funds collection of smaller
containers (e.g., 2 ½-gallon jugs and 5-gallon pails).
•
By conducting a “pilot” IBC collection program in Iowa, the Council
determined that “infrastructure” (e.g. reconditioners) exists such that
ACRC will not fund IBC collection.
•
ACRC and its members generally direct that emptied plastic containers be
recycled into a set of “approved” products (e.g., tire stops, agricultural
drain pipes, industrial pallets). This historically has been the preference of
registrants, as opposed to reusing something like a plastic packaging.
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Things to consider (cont’) • Some pesticide products are DOT hazmats and some are not.
Some are EPA-designated haz wastes (P-List) and some are
not.
• All containers should be triple rinsed by the end user before taken
out of service.
• IBC cages that are clean are reusable by reconditioners.
RIPA has advised EPA on this issue and EPA has indicated that it
would proclaim clean cages reusable.
• The EPA / FIFRA label instructions (written by the chemical
company) include instructions on container disposal. These
instructions carry the force of law.
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Need clear EPA statement that IBC cages are reusable.
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Need agrochemical recognition that professional
container management has benefits: energy, carbonfootprint, and landfill savings.
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Infrastructure exists to help clear the field.