PPP-136 Pesticide Minibulks
PPP-136PesticideMinibulksFilling, Maintenance, Containment
PesticideMinibulksFilling, Maintenance, ContainmentFred WhitfordDirector, Purdue Pesticide ProgramsJoe BecovitzPesticide Program Specialist, Office of Indiana State ChemistJohn ObermeyerIntegrated Pest Management Specialist, Purdue UniversityMike TitusSafety and Risk Coordinator, Co-AllianceJulie LambersonRisk Manager, Harvest Land Co-opKip LandwehrEHS Manager, Winfield UnitedKevin Leigh SmithContinuing Lecturer and Communication Specialist,Purdue Agricultural Sciences Education and Communication
Understanding ‘Bulk’ and ‘Minibulk’. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Secondary Containment Regulations for Farms and Retailers . . . . . . . . . . 10Requirements for Filling Minibulks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Pressure Testing Minibulks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21Farm-Owned Minibulks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28Acknowledgements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Disclaimer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Minibulks— also referred to asshuttles, totes, or intermediate bulk containers — areroutinely used to safely transport thousands of gallonsof pesticides, fertilizers, and adjuvants between retailersand farms. They have become an irreplaceable part ofagricultural operations.Minibulks provide quantifiable advantages to both theretailer and the farmer, including the following:03 RETURN FOR CREDITApplicators can returnunused product toretailers for credit —no wasted product.02 BULK STORAGEUsers can buy productsin bulk without havingto build bulk storageunits.01 LOWER HANDLING COSTSMinibulks require fewerresources than handling,transferring, and cleaninghundreds of smallercontainers.4Bulk pricing — retailers that order pesticides inbulk quantities receive significant price discounts frommanufacturers. In turn, the retailers can pass thosediscounts on to their farmer customers. This is especiallyimportant when you consider that a 2.5-gallon containertypically costs much more than the same materialpurchased in bulk.04 REFILLABLEMinibulks can berefilled many times.TheAdvantagesof Minibulks05 BULK PRICINGRetailers can offerdiscounts to those whopurchase products inbulk.06 FEWER INJURIESMinibulks reduce thenumber of trips up anddown the spray rig torefill the tank.07 REDUCES PLASTICMinibulks virtuallyeliminate the need forindividual plastic jugsand triple rinsing.
Bulk storage — If used correctly, minibulks allowfarmers to utilize the benefits of buying in bulk withoutbuilding costly permanent bulk storage facilities.Return for credit — farmers could possibly returnany unused product left in minibulks to their retailers ifthe tank’s seals remain intact and the retailers acceptbulk returns.Reduces plastic — minibulks can replace hundredsof smaller plastic containers, which can save a significantamount of time and money. For instance, one 250-gallonshuttle will replace opening, pouring, rinsing, anddisposing of 100 2.5-gallon containers.Refillable — retailers can fill and refill minibulks manytimes over their lifespan. Compare this to the cardboardand plastic waste generated from single-use, and 1- and2.5-gallon containers.Fewer injuries — applicators can dramatically reducetheir pesticide exposure when they can pump productfrom minibulks directly into their sprayers. Pouring outof containers requires repeated climbs up and down thesprayer, which increases the potential for slips and falls.Despite these advantages, there are also legitimateconcerns when using minibulks. Larger containers canmean bigger problems during transport, storage, anduse. In fact, most minibulk spills occur during the loading,transporting, or unloading of the container. A minibulk spillcan mean hundreds of gallons on the ground (which canthen potentially move to environmentally sensitive sites)instead of just 1 or 2 gallons from a jug.This minibulk fell off a truck’s tailgate and incurred significantdamage. Note the broken bars of the cage along the top andthe bulged and dented poly tank inside the cage.In addition to transportation concerns, there are rulesgoverning the filling and storage of bulk and minibulkpesticide containers. These rules are administered andenforced by the U.S. Environmental Protection Agency(EPA), U.S. Department of Transportation (DOT), andOffice of Indiana State Chemist (OISC).This publication provides farmers and retailers guidanceand best practices for managing, storing, handling, andtransporting pesticide minibulks.5
Understanding ‘Bulk’ and ‘Minibulk’We often use terms like “bulk” and “minibulk” withoutmuch thought; however, the regulations clearly identifythe exact meaning of each.The OISC and EPA define liquid bulk pesticide asan undivided quantity greater than 55 gallons. Thisdefinition is different than the DOT’s, which is 119 gallonsAnswerthisquestionQU61THE STORAGE ROOMhe storage room pictured below has . -gallonplastic containers and a-gallon herbicide container.ou an o these e onsi ereu k tanks?NTESTfor hazardous materials. By default, 55-gallon drums and2.5-gallon containers are not considered bulk pesticides.This distinction is more than a little important. Indianapesticide regulations are based on understanding thisdefinition.ESTIO!No, because no single container holds more than 55 gallons.
AnswerthisquestionQU2A farmer has a single 265-gallon minibulk on the farm.Is this shuttle considered bulk?NTESTBULK OR NOT?ESTIO!Yes, by definition any container that holds more than 55gallons is a bulk tank.There are two types of bulk pesticide storage tanks:larger stationary storage tanks and smaller minibulks.Stationary storage tanks are generally constructedof stainless steel for durability and ease of cleaning.They hold between 400 and 5,000 gallons. These tanksrequire secondary containment — see Bulk Pesticide andFertilizer Storage on Indiana Farms (Purdue Extensionpublication PPP-63, available at edustore.purdue.eduand ppp.purdue.edu).In addition, stationary tanks are usually equipped withdedicated plumbing. The dedicated plumbing is usedto fill minibulks and sprayers and helps to significantlyreduce cross-contamination by keeping productsseparate from one another. Stationary pesticide tanks(unlike bulk fertilizer tanks) are usually stored under roof.7
State and federal regulations define smaller minibulksas tanks with a capacity of more than 55 gallons but notexceeding 400 gallons. Most minibulks in use today aresomewhat standardized and hold roughly 110, 125, or265 gallons (tank capacities of 120, 135, and 275 gallons,respectively). Minibulks may arrive at the retailer alreadyfilled by manufacturers, or they may be refilled from theretailer’s bulk tanks. Retailers often store minibulks inthe same heated contained buildings as their stationarybulk tanks.AnswerthisquestionQU83FARMER vs AG RETAILERSome farmers have their own 3,000- to 5,000-gallonbulk tanks on the farm. Do the regulations differbetween a farmer and the ag retailer?NTESTMinibulks are designed to be mobile, shuttling productto the farm or field where users can transfer the materialdirectly to sprayers. Farmers and retailers also placeminibulks on trailers along with water and other supplies.The trailers become mobile mixing sites and can easilyfollow sprayers from one field to the next.ESTIO!No, stationary tanks held by farmers and retailers mustfollow Indiana secondary containment regulations.
At one time, minibulks came in dozens of shapesand colors. It was easy to identify a particular pesticideproduct based on the shape, color, and size of thecontainer.Today, most manufacturers place their productsin caged plastic tanks. Cage tanks are basicallynondescript molded plastic tanks that have supportingsteel or aluminum shells around them and bladdersinside the cage.9
Secondary ContainmentRegulations for Farms and RetailersAlthough minibulks are sometimes used for semi-permanentstorage, they are really designed to be mobile containersthat can be filled, emptied, and refilled quickly. If used theway they are intended (as temporary storage), then theregulations state that minibulks that are stored or used atretailers or farms for 30 days or less do not require IO!For prefilled minibulks delivered to retailers or farms,the 30-day period starts on the day of delivery. Forretailers that refill minibulks, the 30-day period starts onthe day the minibulk is filled. If OISC inspects a facility, itis likely the facility that’s being inspected (whether farmor retail) will have to furnish proof of date filled or datedelivered.ORDERED EARLYApplicators often order minibulks in the fall to get adiscount on early purchasing. Do they fall undersecondary containment regulations?It depends on whether the minibulks were delivered.Applicators can buy material in the fall and ask retailers tohold them until spring. Regulations don't take effect until aminibulk touches the property.Different Rules Apply to FertilizersThe requirements for storing bulk pesticides and fertilizers are different.Regulations for bulk fertilizer storage start when quantities exceed 7,500gallons or a single tank holds more than 2,500 gallons.See Bulk Pesticide and Fertilizer Storage on Indiana Farms (Purdue Extensionpublication PPP-63), available at edustore.purdue.edu and ppp.purdue.edu.10
Minibulks stored at the farm or retailer for more than30 days must be in secondary containment. There are afew secondary containment options for storing minibulks.AnswerthisquestionQU5 Storing minibulks within an existing secondarycontainment structure. Minibulks cannot be storedin fertilizer containment unless separated by a wall.IS IT A MINIBULK?Are sprayer tanks considered minibulks?NTESTThese options can include:ESTIO!No. Sprayer tanks are considered application equipment,and do not fall under the bulk containment regulations.11
Using an already existing 10-foot x 20-foot mix/loadpad, which is sometimes referred to as operationalarea containment. Building a separate 10-foot x 20-foot sloped pad thatholds a minimum of 750 gallons. The pad needs toslope toward a sealed sump that allows users torecover material from a ruptured minibulk.The operational pad holds filled minibulks, while the emptiesare legally stored outside of containment.12
AnswerthisquestionQU6NTESTESTIOON A TRAILERDoes putting minibulks on a trailer exempt them fromthe 30 days?No, it does not. If the minibulk is stored on a truck, trailer,or the ground for more than 30 days, it must havesecondary n8ESTIOESTIO!Once emptied, a minibulk can be stored anywhere.LESS THAN 55 GALLONSI have a 110-gallon minibulk that still has 25 gallons ofproduct in it. Can it be outside of containment since itis less than 55 gallons?The container’s capacity determines whether it is a bulkcontainer and requires secondary containment. The examplein this question means that this minibulk must be stored insecondary containment if stored beyond the 30 days.!AnswerthisquestionTESTQU9Can I use the operational pad associated withstationary tanks to store minibulks?NQUNTEST7Do I have to store empty minibulk containers incontainment?NTESTCONTAINMENT FOR EMPTIES?ESTIO!Indiana regulations allow the use of an operational pad thatis 10 x 20' and that can hold 750 gallons.13
Requirements for Filling MinibulksFederal regulations spell out specific requirements thatdealers must comply with when they take product fromstationary bulk tanks to fill minibulks.EPA RegistrationAccording to the regulations, any facility that “produces”a pesticide product is required to register with EPA as apesticide-producing establishment. Production can meanthat the facility mixes ingredients according to a labeledformula to make a pesticide product. Or, as is usuallythe case with ag retailers, production can mean simplytransferring pesticide product from one container toanother for the purpose of resale. All pesticide-producingestablishments must report their production (even zeroproduction) to the EPA by March 1 of the following year.Unique IDWhenever users refill or repackage minibulks, they mustmark each one with a unique ID or serial number.However, minibulks obtained directly from manufacturersand shipped to customers do not require unique serialnumbers. If farmers bring minibulks back to retailers forrefilling, all of the repack agreement requirements kick-in,including assigning the shuttle an ID number.Repackaging AgreementsRetailers must have repackaging agreements from eachmanufacturer to repackage bulk pesticide products.Retailers must make copies of current agreements availablefor inspection by the OISC at each repackaging location.The written contracts lay out exactly what products agretailers can repackage, what containers the products canbe repackaged in, how and when to clean minibulks, andinspection protocols.Do Rules Apply to Farmers?Do farmers with their own bulk tanks have to follow the same requirementsas ag retailers?Farmers who store bulk pesticides for their own use, are considered end users.Under this use, farmers are not subject to EPA’s bulk repacking regulations.However, if a farmer acts as a retailer and sells minibulks to other growers,then that farmer now falls within the full scope of the repackaging regulations.14
123EPA REGISTRATIONREPACKAGING AGREEMENTSUNIQUE IDsThe EPA requires any facilitythat produces a pesticideproduct to register as apesticide-producingestablishment.Retailers must have agreements from pesticide manufacturers to repackage bulkpesticides.Retailers who refill andrepackage materials mustmark the minibulk with aunique ID or serial number.456EXEMPT FOR DIRECT SHIPONE-WAY VALVESTAMPER-EVIDENT SEALSMinibulks obtained directlyfrom manufacturers andshipped to customers donot require unique serialnumbers.Minibulks must be equippedwith one-way valves that onlyallow product to flow out ofthe tank.Retailers must place tamperevident seals on or aroundtank openings before theyship minibulks.789NEW LABELSRECORD KEEPINGINSPECTAttach a new label to theminibulk each time it is filled.Include the EPA establishment number and netcontents on the new label.Each time retailers fill containers, they must record theunique IDs, dates, and EPAregistration numbers for theproducts. Retailers must keepthese records for 3 years.Retailers must inspectminibulks for leaks andbroken seals at each refill.Minibuiks may need apressure test with recordevery 2.5 years.15
One-way ValvesRefillable minibulks must have one-way valves that onlyallow product to flow out of the tank.16Tamper-evident SealsRetailers and manufacturers must place tamper-evidentseals on or around openings before they ship minibulks.These external seals provide important visual clues whenusers return minibulks. The seals help protect the product’sintegrity while in service. If the seals are intact, the productin the tank has not been tampered with. If any of the sealsare broken, retailers must follow the specific cleaninginstructions found in their repackaging agreements beforethey can refill the minibulks — even if they refill minibulkswith the same product.
AnswerthisquestionQU1NTESTESTIO!CLEANING PROCEDURES PER MANUFACTURERWhich cleaning procedure must be followed whenswitching a minibulk over from one product to anotherif the pesticide manufacturers are different?Use the cleaning procedure for the product that was lastused in the tank to remove any residue. You should then beable to fill that cleaned minibulk with any other pesticideproduct you choose as long as you have a repackagreement to do so.17
New LabelsAttach new labels to minibulks each time you fill them.The labels should include the EPA establishmentnumber and net contents. The establishment numberon the minibulk is the same one the EPA assigned to thefacility. This holds true even if a facility fills a minibulk fora “sister” facility. The establishment number written on aminibulk is always the number for the location where thecontainer is filled.It is important to note that the tank’s net contents arenot the same as the tank’s capacity. The net contentsare the amount of product that was put into the tank atrefilling. For example, let’s say a customer brought backa 250-gallon tank to the retailer for refilling. There were50 gallons remaining in the tank when the customerbrought it in. The dealer put 200 gallons in the tank.The net contents written on the label would be 200gallons, not 250 gallons. Although not required, somedealers also include the date the minibulk was refilledon each label.AnswerthisquestionQU1NTESTESTIO!How much did the retailer put into this minibulk?18A farmer brings back a 250-gallon minibulk with 25gallons left in the tank. The retailer puts in 225 gallonsin the minibulk. What amount of product would bewritten on the label attached to the minibulk?The net contents is always the amount added to a tank, notwhat the tank can hold.It is not legally required to include the date that the pesticide was put into the tank.However, it does serve to provide information on the OISC 30-day policy.
This minibulk isbeing weighed toget its tare weight.If the retailer knowshow much 1 gallonweighs, then theretailer can weighout the number ofgallons a farmerrequests.19
Record KeepingEach time retailers fill containers, they must record theunique ID numbers, dates, and EPA registration numbers forthe products. Retailers must keep these production recordsfor three years. If the product is a restricted-use pesticide(RUP), then retailers must keep an additional, more detailedrecord of sale or application for two years. Each year,retailers must submit a summary of all pesticide production(amounts filled for each bulk pesticide product) to the EPA.Inspection and Cleaning RequirementsRetailers must determine if minibulks can be refilledby reviewing the tank labels to see if they are markedas refillable or non-refillable. Since most minibulks aremeant to be reused, inspecting them is perhaps the mostimportant part of the refilling process.Proper inspections can reveal faulty containers, leakingvalves, tanks that need to be recertified (pressure-tested), orcontamination issues. Failing to inspect returned containersbefore refilling them can result in contamination issues,which may cause thousands of dollars in unintentional cropdamage and ruined reputations.When you inspect minibulks: Ensure that all valves are functioning. Examine the outside of the tank for any spills, leaks,or cracks. Examine the pesticide label on the outside of the tankand all tamper-evident seals to ensure they are intact.If the tank labels do not match the product aboutto be put into them, or if any seal is cut or broken,then retailers must clean the minibulks according tothe instructions in the repack agreement. They mustclean the tanks over a wash pad where they cancollect the rinse water.AnswerthisquestionQU201NTESTESTIO!BROKEN SEALS ON A TANKWhat should you do if a minibulk has a broken seal?When the security devices have been breached, there isno guarantee of what’s in that container or what mighthave been added. It could be a huge risk to the farmerand retailer to assume the material left in theminibulk has not been contaminated. In many cases,it is the policy of the retailer to refuse to take back theprodu
PPP-136 Filling, Maintenance, Containment Pesticide Minibulks. Fred Whitford Director, Purdue Pesticide Programs Joe Becovitz Pesticide Program Specialist, O ice of Indiana State Chemist John Obermeyer Integrated
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