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Retail Resources - EGLE Pesticide Container Repair Guide and Template

Each year, a significant volume of consumer pesticides are disposed as a result of container damage during retail distribution.  In 2009 alone, the U.S. Environmental Protection Agency (U.S. EPA) estimated nearly five million pounds were disposed as a result of damage.  The strict packaging requirements of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) unfortunately have a secondary impact.  They function well to protect consumers from exposure hazards during use and the environment from impacts associated with misuse.  However, they also prevent retail from repairing pesticide containers that are damaged during distribution because they require any person who packages FIFRA regulated pesticides to be a FIFRA registered pesticide producer.

To reduce the volume of pesticides requiring disposal as a result of damaged packaging, retailers have worked with pesticide manufacturers to upgrade and redesign packaging. They have also established unique handling protocols to minimized error and damage. To further reduce volumes requiring disposal from damaged packaging, in October 2009, U.S. EPA published a Pesticide Container Repair Interim Policy that allows retailers with a U.S. EPA approved container repair program to repair and sell pesticides with damaged packaging.  To help simplify the process of developing a proposed minor container repair program, EGLE's Retail Environmental Workgroup developed a Pesticide Container Repair Guide and Template for retailers seeking approval of a minor container repair program.

The template has been reviewed by U.S. EPA FIFRA program staff and determined to be consistent with the policy; however each program must be submitted to the U.S. EPA for review/approval consistent with the U.S.EPA October 9, 2009 Pesticide Container Repair Interim Policy, and will be reviewed on a case by case basis by the U.S. EPA . The template was also reviewed by the Michigan Department of Agriculture and Rural Development and verified consistent with Michigan's pesticide regulations.  However, some states do not allow pesticide container repairs and some may have repair requirements beyond what is provided in the template.  When developing a proposal, applicants need to review and identify any unique state requirements in advance of submitting a proposed repair plan for approval and must include that information in the proposed plan.  For questions on state program requirements, see the National Pesticide Information Center, State Pesticide Regulatory Agency Web page, and contact the relevant state agencies.


Christine Grossman