What is IBC Reconditioning? Compliance in Collection, Triage and Reprocessing

1. What is IBC Reconditioning? Compliance in Collection, Triage and Reprocessing Brian J. Bilyeu Cropland Containers, Inc. Brian P. Evoy Fibre Drums Sales, Inc. (DBA FDS Packaging, Inc.) TPSA Annual Conference Mobile Riverview Plaza Hotel – Mobile, AL February 6, 2013

2. We want to communicate to everyone in the Agricultural Chemical Industry that sending empty totes to Reprocessors is: • Safe • Efficient and • Environmentally sound Goal of Presentation TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

3. AGENDA • Compliance with local and federal regulations and guidelines for empty bulk containers – IBC’s • IBC (Intermediate Bulk Container) Collection • Triage of IBCs • IBC Reprocessing – Inspection & Reconditioning • Water Treatment • IBC Rebottling, Remanufacturing & Recycling TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

4. Educate ALL Emptiers – Empty “Means” Empty • We have ALL Emptierssign a Tote Return Form • An “Agreement between IBC Refurbishes and Emptiers” • An “Empty IBC Certification” Form • The Reprocessor Assumes No Ownership of Any Container Unless All of Terms & Conditions of All Tote Return Forms Are Met TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

5. Break it Down for the Emptier • We Train our staffs to point out the most important terms and conditions of all agreements with ALL Emptiers • Legally Empty • Reusable • Consequences of NON-Compliance TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

6. Empty IBCs – Prior to Pick-up • We Request pictures representing the units that they are wishing to be retrieved • Pictures enhance communication and reinforce tote return forms • Doing this helps reduce the number of “Junk” or “Heavy Units” shipped by the Emptier TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

7. Empty IBC Certification We emphasize the importance of Triple Rinsing… • Triple Rinsing - "P-list" products specifically listed by name in 40 CFR 261.33 (e), EPA says the packaging is empty only "if the packaging...has been triple-rinsed using a solvent capable of removing the product, or has been cleaned by another method shown to achieve equivalent removal.“ • Triple Rinsed • EPA defines triple rinsing in 40 CFR 165.1 • P-listed products require Triple Rinsing • All Triple Rinsed containers need to be marked or punctured TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

8. “EMPTY” Applies to ALL Totes • Treat ALL Units Equally when referring to “EMPTY” RCRA Definition 40 CFR 261.7 (b)(1)(iii)(B) (B) No more than 0.3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is greater than 119 gallons in size Empty IBC RCRA Empty IBC TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

9. IBC Triage (Inspection) TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

10. Triage Raw IBCs Correctly Employees are trained on what to do with ALL totes being received that DO NOT meet an established “Empty” standard • IBC’s are unloaded off trucks, graded for condition as cutters, washers, heavies or scrap and recorded by type • “REJECT” stickers are used on the front valve side marking plates to identify any NON-Compliant heel and scrap totes before being moved to the quarantine area • This applies to all Hazardous & Non-Hazardous last contained IBC’s TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

11. Rejected Units • We Designate an area for ALL rejected units • Ideally, it is a diked space • All units are marked as “Quarantined” • To assist with best record keeping: • We take digital pictures of ALL units showing the date and time • We ALWAYS refer to these Non-Compliant heavytotes as “Product Shipped in Error Being Returned to Original Shipper and Owner of the Product” TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

12. IBC Reconditioning TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

13. IBC Inspection and Reconditioning • IBC’s are inspected for excessive residue and damage upon receipt • Serial numbers are recorded where appropriate • Missing or damaged component parts are recorded • Digital pictures are taken of any units that are triaged & categorized • All non-compliant units are immediately placed in quarantine • All washers are readied for IBC reconditioning • IBC’s are cleaned on the exterior, removing labels, unless otherwise specified by customer: • Chemical, heat gun, high-pressure hot water spray or steam • IBC’s are pre-rinsed with water whenever appropriate TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

14. IBC Inspection and Cleaning • IBC’s are cleaned on the interior and exterior: • Hot caustic or chemical solution, or cold or hot high pressure water • Interior & Exterior Washes – Both Fresh & Re-used cleaning options • Many utilize final steam or clean water rinse • Air drying and siphon or vacuuming • All fittings and bottle inspected • Air Differential Leakproofness Test • All passed or successfully tested IBC’s are given a final inspection • IBC’s are compliantly marked for Hazardous or Non-Hazardous Non-Food Grade Re-use • We compliantly destroy any reconditioned units that fail the air test TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

15. All placards, product labels, • lanyards and others are removed. • All units will then undergo a • pre-flush. TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

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17. 2. All markings and any graffiti are removed and label plates are cleaned. TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

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19. 3. Each unit is washed based on the last contained content. TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

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21. 4. All units receive a freshwater rinse. The insides are siphoned thoroughly. Each unit then goes through a drying process. TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

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23. 5. Valve installation and air differential testing is completed. TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

24. 6. Final visual Inspection and Compliant Labeling TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

25. Cleaned and Organized Warehousing • All units built to customer specifications TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

26. Water Treatment TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

27. Water Treatment Equipment TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

28. Water Treatment • Solutions for solids & liquids are vast • Wastewater is a moving target and no two process waters are alike • Reprocessors utilize different chemistries when processing wastewater depending on the composition of the generations • Reprocessors must comply with local laws and local Water Reclamation Authorities for discharging • Reprocessors submit samplings to their regional Water Reclamation Authorities on a continuous basis as determined by local authorities • EHS Personnel audit Reprocessor’s facilities frequently and all have varying expectations • The chemistries and the processes are ever evolving but the goal is always Compliance TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

29. What is IBC Rebottling?

30. Benefits of IBC Rebottling • Inner receptacle is determined scrap while cage in left is good re-usable condition • No cross contamination of previous products • No further UV degradation of plastic • Resets the DOT 2.5 year life TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

31. IBC Rebottling • Upon Receiving the IBC the bottles are graded. • Any bottle that is brittle, cut, punctured or stained beyond reuse will be compliantly destroyed • The inner receptacles are cut and bailed or shredded into grind • The bailed or ground plastic is sold to compliant vendors that reproduce non food grade items such as corner protectors, drain tile or pallets. TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

32. IBC Rebottling - Refurbishing a Re-Used Cage • Cleaning label plates • All original product labels and any markings are destroyed • Adhesive or graffiti removed from cage and marking plates • High Pressure Hot Wash of cage • Cleaning of plastic corner protectors • Repairing bent or damaged cages • Replacing or tightening hardware on the cages • Cleaning and straightening out top bars before reinstalling • Painting or touching up where ever oxidation or rust is evident TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

33. IBC Cage Repair • The cages are completely refurbished and readied for re-use TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

34. Receiving Inner Tanks & Preparing For Cage TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

35. IBC Rebottling - Six Sided IBC Bottle Inspection • When receiving new replacement bottles (inner receptacles) for use in IBC reprocessing operations • A six-sided visual inspection must be performed by a plant employee on each bottle after it is removed from the delivery truck. • Scrutiny of all four sides, the top and bottom of the bottle. • The purpose is to check for damage caused in transit that may result in the bottle being unusable • Any damage is immediately reported to a Supervisor & quarantined • All employees are trained to execute the 6 sided inspection and adhere to a written training SOP TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

36. Rebottled - Repaired IBC • This activity is specific to a single manufacturer’s composite components • The manufacturer of the cage and the inner tank are the same TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

37. IBC Remanufacturing TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

38. IBC Remanufacturing • The activity is specific to a cross-bottled or hybrid IBC, where different manufacturer’s composite component parts are used • The manufacturer of the inner receptacle is not the same as the manufacturer of the cage TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

39. Benefits of a Completed New Rebottled IBC • Meets all DOT (PHMSA) and EPA requirements • As Good as New • Factory sealed and Leakproofness tested inner receptacles • Reduces Liability TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

40. In Conclusion • Industrial and Agricultural Chemical Companies are using more and more Reconditioned and Rebottled Composite Blow Molded IBC’s as they are excellent containers • When handled properly, IBC’s are proven capable of multiple Re-uses • RIPA Members comply with all Local, State and Federal Regulating Agencies including: DOT (PHMSA), EPA and OSHA • We encourage you to use RIPA members to collect and reprocess or recycle your empty IBC’s • We welcome any opportunities and are ready for building a sustainable business partnership with your Industry TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13

41. Thank you for this opportunity and for your attention. Questions????? TPSA 13th Annual Pesticide Stewardship Conference ~ Mobile, AL ~ 2-6-13