Mini-Bulk Service Containers

On August 10, 2011 the USEPA Pesticide Container Containment (PCC) Regulations came into effect creating new regulatory requirements for refillable mini-bulk containers and bulk pesticide storage facilities.  Some of the new mini-bulk requirements include one way valves, tamper evident devices, unique identification numbers for mini-bulk containers and pressure testing of mini-bulk containers.  Many of these new requirements can be circumvented by designating refillable mini-bulks as "service containers", meaning they would only be used to tender pesticide application equipment in the field and not refilled and sold as a portable refillable container (PRC).  Although companies do not have to comply with many of the USEPA PCC regulations by designating a mini-bulk as a service container, this does not exclude USDOT pressure testing of tanks and compliance with packing specifications.  Keep in mind, even if mini-bulk tanks are designated as "service containers" they still must comply with USDOT regulations.  If you have any questions about the PCC regulations or USDOT requirements, please contact Kevin Runkle at the IFCA office.