Mobile, Alabama February 5-7, 2013

1. Pesticide Stewardship Conference Mobile, Alabama February 5-7, 2013

2. 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.

4. Pesticide Stewardship Conference Composite IBCs in “AgChem” Service Pesticides: Herbicides and Insecticides

5. Pesticide Stewardship Conference Glossary of Terms

6. Pesticide Stewardship Conference • 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

7. Pesticide Stewardship Conference • 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.

8. Pesticide Stewardship Conference 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

9. Pesticide Stewardship Conference 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.

10. Pesticide Stewardship Conference 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.

11. Pesticide Stewardship Conference 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.

12. Pesticide Stewardship Conference • 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.

13. Pesticide Stewardship Conference • Need clear EPA statement that IBC cages are reusable. • Need agrochemical recognition that professional container management has benefits: energy, carbon-footprint, and landfill savings. • Infrastructure exists to help clear the field.