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Label Review Training: Module 3: Special Issues, Page 30

Section 7: What other label areas require special attention?

4. Container handling/disposal statement

Container handling instructions include information on whether the container is refillable or nonrefillable, a reuse statement, a recycling/reconditioning statement, and information on how to remove residues from emptied pesticide containers and what to do with the pesticide container after it is emptied.

Plant-incorporated protectants, pesticidal articles not exempted from FIFRA by §152.25(a), transport vehicles, and products listed in §156.140(a)(5) are not required to have refillable/nonrefillable and reuse statements.

Residue removal instructions must be on the label under the heading “Storage and Disposal.” Exceptions include 1) residential/household-use products, gases, pesticidal articles not exempted from FIFRA by §152.25(a); and 2) transport vehicles. Apart from the list of products above, nonrefillable, rigid containers with dilutable pesticides and refillable containers are required to have residue removal instructions.

The following is a good example of a storage and disposal statement for a dilutable agricultural product in a nonrefillable plastic container.

storage disposal

Generally, registrants making changes to a label to update the container handling statement to comply with the pesticide container regulations may submit a label notification if they use the exact language statements as provided in §§156.140–156.156. If they wish to use different language, they must submit changes using a label amendment. In addition, EPA has the option in §156.140(c) and §156.144(d) to modify or waive the requirements for label statements regarding whether the container is refillable or nonrefillable, as well as reuse, recycling/reconditioning, and residue removal instructions.

Resource

To determine storage and disposal statements, see Chapter 13 of the Label Review Manual.

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