May 16, 1994

Notice To: Manufacturers, Producers, Formulators, and Registrants of Pesticide Products

Attention: Persons Responsible For Registration of Pesticide Products

Subject: Recycling Empty Aerosol Pesticide Containers

This notice offers registrants use of an optional label statement permitting recycling as an alternative to instructions to dispose of aerosol pesticide containers. Registrants may add a label reference to recycling the empty aerosol pesticide container. The optional statement may be placed on the label without notice to the Agency as provided in 40 CFR 152.46(b)(3).

1. Background
2. Policy And Rationale
3. Effective Date

1. Background

   Recycling of aerosol containers is increasing dramatically and represents a significant potential recycled resource given the large numbers of units produced each year (approximately 3,000,000,000 aerosol containers of which 10% hold pesticides). Aerosol pesticide containers, however, are not now recycled to any appreciable extent because of the nature of the current safety and label instructions that require disposal of these containers. Failure to follow label statements for registered pesticides is a violation of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Changing these label instructions to permit recycling of aerosol pesticide containers would allow such recycling programs to operate and reap significant environmental and economic benefits.

2. Policy And Rationale

   The Agency believes that recycling of empty metal aerosol pesticide containers can be safely and appropriately accomplished. Recycling can preserve valuable metal resources and reduces the demand on diminishing land-fill space. Recycling processes involve compaction and melting of the metal with combustion of the pesticide residues. Compaction of aerosol containers can be accomplished without danger of explosion. Subsequent heating at the high temperatures achieved in steel furnaces or aluminum smelters would incinerate any toxic residues.

   The label statement must specify that containers be emptied through normal use prior to recycling and remind users that recycling centers for aerosols are not available in many areas (see label example).

   The Agency will permit a recycling statement to be added, at the registrant's discretion, to the disposal instructions for aerosol pesticide containers. This statement, or variations which do not alter its intent, may be placed on the label without notification and without further Agency approval. Any variation in text must retain references to recycling only empty pesticide containers and limited availability of recycling programs. Do not use general statements such as xxx recycle where available xxx. The following statement is acceptable for this purpose:

   This container may be recycled in aerosol recycling centers. At present, there are only a few such centers in the country. Before offering for recycling, empty the can by using the product according to the label (DO NOT PUNCTURE!). If recycling is not available, wrap the container and discard in the trash.

   Registrants may use their currently approved disposal instructions as an alternative to the last sentence of the above statement. The statement-DO NOT PUNCTURE OR INCINERATE CONTAINER!-(or equivalent) must be retained in the Physical or Chemical Hazard section of the Precautionary Statements. (Registrants must retain or use language that reminds users not to puncture containers for the purpose of emptying them). If other changes to the disposal or recycling instructions are desired, an application for amendment must be submitted to the Registration Division Product Manager.

3. Effective Date

   This policy notice is effective immediately. If you have questions, contact the Registration Division.

   Stephen L. Johnson, Acting Director
   Registration Division

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