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Pesticide Container and Containment Regulations for IBC’s. Patrick Nellenbach. What Does Do?. Agrium is the only publicly traded company that crosses the entire agricultural value-chain.
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Pesticide Container and Containment Regulations for IBC’s Patrick Nellenbach
What Does Do? Agrium is the only publicly traded company that crosses the entire agricultural value-chain. • We are now the largest direct-to-grower distributor of seed, agricultural crop protection products and crop nutrients. • CPS operates 872 retail centers, 72 terminals and 19 distribution centers in the U.S., Argentina, Chile and Canada.
Operations In Michigan • Retail facilities which engage in repackaging and custom application activities • Wholesale and Distribution Centers which deliver to other retailers and our retail network
Challenges that Container and Containment Rules Present After August 16, 2011- Regulatory • Will our Existing Inventory of tanks be usable after the compliance date? • Tamper Evident Devices and One Way Valves? • How do we meet DOT Testing Requirements? • Container and Inspection Identification • Recordkeeping as a Wholesaler and Retailer • Educating Our Employees
Challenges that Container and Containment Rules Present After August 16, 2011- Business • How do we forecast the purchase of new tanks? • Tank Manufacturers- Composite and Rotary Molded • Mitigating Rinsate Generation • Shipping Practices • Customer Owned Tanks? • Educating of our Customers
What Did Do to Prepare We Created a Committee to address the New Rule • It was composed of Operations Staff, Regulatory Staff, Manufacturing Staff, Retail Staff and Wholesale Staff from all the regions of the company • We wanted to pool our experiences to develop procedures that the company as a whole could adopt • We wanted individuals each region could turn to for guidance and progress • We wanted to develop a framework of preferences to communicate to Tank and component manufacturers • We wanted to develop sound business practices but we also wanted to integrate stewardship
Any Progress? • I believe we influenced how manufacturers will design tanks for the future • Overwhelmingly decided to adopt the comprehensive use of one way valves • Centralized communication regarding the purchase of tanks for both manufacturing and retail • Centralized recycling and disposal efforts for tanks • Have begun to develop standard operating procedures for marking, inspection and testing activities
We Still Have Some Work To Do • We have not identified one data base for inspection documentation • Knowing a little more about how the law will be implemented • Physically Identifying those tanks that need to be removed from the system
What Type of Tank Going Forward? • Strong Sturdy Tanks • One Way Valves • Effective Flow • Efficiently Vents that cannot be removed • The Fewer Openings the Better • Pumps on the top of tanks may present a challenge