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Label Review Manual
Chapter 13: Storage and Disposal

Table of Contents
Chapters:
  1. Purpose of Manual
  2. What is a Pesticide?
  3. General Labeling Requirements
  4. Types of Label Reviews
  5. Ingredient Statement
  6. Use Classification
  7. Precautionary Labeling
  8. Environmental Hazards
  9. Physical or Chemical Hazards
  10. Worker Protection Labeling
  11. Directions for Use
  12. Labeling Claims
  13. Storage and Disposal
  14. Identification Numbers
  15. Company Name and Address
  16. Graphic & Symbols on Labels
  17. Content/Net Weight Statement
  18. Unique Product Labeling
  19. The Consumer Labeling Initiative and Pesticide Labels


On this page

  • I. Introduction
  • II. Statement Location
  • III. Format
  • IV. Type Size Requirement
  • V. Determining Storage and Disposal Labeling
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    I. Introduction

    Labels for pesticide products are required to bear instructions for the storage and disposal of pesticides and pesticide containers. 40 CFR 156.10(i)(2)(ix). Storage and disposal instructions cover the appropriate storage of the pesticide product; disposal of any unused pesticide product or any rinse liquids resulting from cleaning of pesticide application equipment; and the disposal of the pesticide container. See also PR Notice 2001-6.

    II. Statement Location

    The storage and disposal instructions must appear grouped together, preferably blocked, within the Directions for Use section, and under the subheading “Storage and Disposal” (See 40 CFR 156.10 (i)(2)(ix)). It is preferred that the storage and disposal instructions appear at the end of the Direction for Use section. This placement eliminates the break between the heading "Directions for Use" and the body of the use directions. Where the Directions for Use are contained in a label booklet, at a minimum, the container storage and disposal instructions should appear at the end of the Directions for Use on the container label. In addition, the disposal instructions should be included in any referral statement on the label, e.g., "Refer to booklet for directions for use, and storage and disposal instructions.”

    III. Format

    All products must bear the heading "STORAGE AND DISPOSAL ." The terms “residential,” “household,” “household-use,” “homeowner,” and “domestic use” are used interchangeably throughout this chapter and mean the same thing for purposes of this chapter. These instructions must be set apart and clearly distinguishable from other directions for use. 40 CFR 156.10(a)(2). Blocking these statements with a solid line (a box) is suggested as a means of increasing their prominence. For example:

    STORAGE AND DISPOSAL

    Do not contaminate water, food, or feed by storage and disposal.

    Pesticide Storage . . .
    Pesticide Disposal (old) or If partly filled (new) . . .
    Container Disposal (old) or If empty (new) . . .

    IV. Type Size Requirement

    The heading "STORAGE AND DISPOSAL" must be set in type of the same sizes as required for the child hazard warning. See 40 CFR 156.10(i)(2)(ix) and the table in 156.60(h)(1)9iv).

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    V. Determining Storage and Disposal Labeling

    1. Pesticide Storage Statements. Review the information below to determine the appropriate document to use as the source of pesticide storage statements.

      1. Recent Registration Standard or Reregistration Eligibility Decision (RED) Document. If a Registration Standard or RED Document exists, and is more recent than PR Notice 84-1 or PR Notice 84-5 (for fumigants only), refer to the Registration Standard or RED Document for recommended storage statements. If the Registration Standard or RED Document does not contain storage statements, use the general guidance contained in this section under A. 3. Storage Guidance (below) from PR Notice 83-3.

      2. No Registration Standard or No RED Document. If there is no Registration Standard or RED Document, or if the Registration Standard or RED Document does not contain specific storage statements, review the documents below to determine the appropriate document to use as the source of guidance for the pesticide storage statements.

        1. Statements for Specific Chemicals: PR Notice 84-1 and an errata sheet dated 4/12/84 contain specific storage statements for the active ingredients listed in Table 1 below:

          TABLE 1: Pesticide Storage Statements
          Active Ingredient Pesticide Storage Statements
          Aluminum phosphide The following statement should be used in addition to the guidance in PR Notice 83-3: "Not for use or storage in or around inhabited areas."
          Liquid Sodium hypochlorite,
          Liquid Calcium hypochlorite          		 "Store this product in a cool dry area, away from direct sunlight and heat to avoid deterioration. In case of spill, flood areas with large quantities of water. Product or rinsates that cannot be used should be diluted with water before disposal in a sanitary sewer. Do not reuse empty container but place in trash collection. Do not contaminate food or feed by storage, disposal or cleaning of equipment."
          Magnesium phosphide The following statement should be used in addition to the guidance in PR Notice 83-3: "Store only in cool, dry, locked, and ventilated room. Protect from moisture, open flames or heat."
          Solid Calcium hypochlorite "Keep this product dry in a tightly closed container, when not in use. Store in a cool, dry, well ventilated area away from heat or open flame. In case of decomposition, isolate container (if possible) and flood area with large amounts of water to dissolve all materials before discarding this container. Do not reuse empty container but place in trash collection. Do not contaminate food or feed by storage or disposal, or cleaning of equipment."
          Terrazole All manufacturing use products should contain the statement, "This product is corrosive to steel and many other metals. Do not transport or store in unlined metal containers."
          Zinc phosphide The following statement must be used in addition to the guidance in PR Notice 83-3: "Store in a dry place. Do not store in or around the home."
        2. Fumigants. Refer to PR Notice 84-5 for specific storage guidance for the following chemicals: methyl bromide; methyl bromide and 2% or less chloropicrin; aluminum and magnesium phosphide; chloropicrin; sodium cyanide; ethylene oxide; and sulfuryl fluoride. For all other fumigants, refer to number 3 below (Storage Guidance from PR Notice 83-3).

        3. Storage Guidance from PR Notice 83-3. Review the general guidance on appropriate pesticide storage instructions from PR Notice 83-3 listed below to determine if the label under review is consistent with the guidance in PR Notice 83-3 Section I (A).

      3. All product labels are required to have appropriate storage instructions. Specific storage instructions are not prescribed. Each registrant must develop storage instructions for each product considering, when applicable, the following factors:

        1. Conditions of storage that might alter the composition or usefulness of the pesticide. Examples could be temperature extremes, excessive moisture or humidity, heat, sunlight, friction, or contaminating substances or media.

        2. Physical requirements of storage that might adversely affect the container of the product and its ability to continue to function properly. Requirements might include positioning of the container in storage, storage temperature, potential for breakage of glass, crushing or damage due to stacking, penetration by moisture, and ability to withstand shock or friction.

        3. Physical requirements of storage that might adversely affect the container of the product and its ability to continue to function properly. Requirements might include positioning of the container in storage, storage temperature, potential for breakage of glass, crushing or damage due to stacking, penetration by moisture, and ability to withstand shock or friction.

        4. Instructions on what to do if the container is damaged in any way, or if the pesticide is leaking or has been spilled, and precautions to minimize exposure if damage occurs.

        5. General precautions concerning locked storage, storage in original container only, and separation of pesticides during storage to prevent cross-contamination of other pesticides, fertilizer, food, and feed.

        6. General storage instructions for household products should emphasize storage in original container and placement in locked storage areas.

    2. Pesticide Product Disposal Statements. The label of each pesticide product is required to bear pesticide disposal statements.

      1. General Statement. The Agency historically has required all products, except for residential/household use products, to bear the following statement for risk management purposes:

        "Do not contaminate water, food, or feed by storage and disposal."

        The Agency prefers that this statement appear immediately under the “Storage and Disposal” heading because it concerns both subjects; however, the statement can be placed elsewhere within the Storage and Disposal instructions.

      2. Other Pesticide Disposal Statements. Review items a. and b. below to determine the appropriate guidance to follow for pesticide disposal statements.

        1. Registration Standard or RED Document Issued after 2/12/86. If the label under review involves a chemical for which a Registration Standard or RED Document was issued after 2/12/86, refer to the Registration Standard or RED Document to determine if any specific pesticide disposal statements exist. If no specific guidance exists, refer to statements under number (2) below to determine the appropriate pesticide disposal statement.

        2. If the label under review involves a chemical for which a Registration Standard or RED Document was issued before 2/12/86 or if there is no RED Document, consider the disposal statements in the guidance set out in PR Notice 83-3 and described below.

          1. Except those products intended solely for residential/household-use, the labels of all products that contain active ingredients that are Acute Hazardous Wastes ( see PR Notice 83-3 for list) or assigned to Toxicity Category I on the basis of oral or dermal toxicity, skin or eye irritation potential, or Toxicity Category I or II on the basis of acute inhalation toxicity should generally bear one of the following pesticide disposal statements:
            "Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of Federal Law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance."
            Alternatively, the disposal statement given for Furadan 3G and Furadan 4F in section C below can be used.

          2. The labels of all products, except those intended for household use, containing active or inert ingredients that are Toxic Hazardous Wastes (see Pr notice 83-3 for list) or meet any of the criteria in 40 CFR 261, Subpart C for a characteristic hazardous waste must bear the following pesticide disposal statement:
            "Pesticide wastes are toxic. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of Federal Law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste representative at the nearest EPA Regional Office for guidance."
            Alternatively, the disposal statement given for Furadan 3G and Furadan 4F in section C below can be used if the first sentence is changed to "Wastes associated with the pesticide are toxic hazardous wastes."

          3. Labels for all other products, except those intended for household use, must bear the following pesticide disposal statement:
            "Wastes resulting from the use of this product must be disposed of on site or at an approved waste disposal facility."
          4. PR Notice 2001-6 provides new disposal instructions for non-antimicrobial residential/household use products. The disposal statements specified in PR Notice 2001-6 for products in pressurized containers and in non-pressurized containers are:

            1. For products in Pressurized Containers
              Do Not Puncture or Incinerate!
              If empty: Place in trash or offer for recycling if available.
              If partly filled: Call your local solid waste agency or [toll free number which meets the criteria in paragraph II.E] for disposal instructions.
            2. For products in Non-Pressurized containers

              If empty: Do not reuse this container. Place in trash or offer for recycling if available.
              If partly filled: Call your local solid waste agency or [toll free number which meets the criteria in paragraph II.E] for disposal instructions. Never place unused product down any indoor or outdoor drain.

              Labels for antimicrobial household products may bear the following disposal statement: “Securely wrap original container in several layers of newspaper and discard in trash,” per guidance provided in PR Notice 84-1. These products are not covered by PR Notice 2001-6.

      3. Specific Pesticide Disposal Statements.

        Furadan 3G and Furadan 4F

        "Wastes associated with the pesticide are acutely hazardous wastes. Excess pesticide, spray mixture or rinsate must be handled and disposed in accordance with local, state and federal regulations. If these materials cannot be used according to label instructions or cannot be returned and must be disposed, contact your State Environmental Control Agency or the Resource Conservation and Recovery Act (RCRA) Hazardous Waste representative at the nearest EPA Regional Office for disposal guidance."


    3. Container Disposal Statements.

      1. All pesticide products, including household products, must bear container disposal statements that are specific for each type of container. For non-antimicrobial, residential/household-use products, PR Notice 2001-6 has replaced the earlier container-specific statements with revised ones (see paragraph 2.a.(1)) below. Registrants still have the option of using more specific recycling statements if they meet the Federal Trade Commission guidelines. Antimicrobial residential/household-use products may use the revised statements but are not required to use them.


        PR Notice 94-2 allows registrants, at their discretion, to use alternate container disposal statements permitting the recycling of empty aerosol pesticide containers. The alternate statements must specify that containers be emptied through normal use and note that recycling centers for aerosol containers are not available in many areas. The alternate statements are in addition to the disposal instructions.

      2. Review sections a. and b. below to determine the appropriate document to use as the source of the container disposal statements.

        1. Residential/household-use Products. If the label under review involves a chemical for which a Registration Standard was issued after 2/12/86 or a RED has been issued, refer to the Registration Standard or RED to determine if specific container disposal statements are provided. If no specific labeling is provided or if no Registration Standard or RED exists, use one of the following container disposal statements:

          1. "Securely wrap original container in several layers of newspaper and discard in trash." (Reference PR Notice 84-1). Note that this statement has been replaced by a new instruction in PR Notice 2001-6 which states, for non-antimicrobial, pressurized containers, “Do Not Puncture or Incinerate! If empty: Place in trash or offer for recycling if available.” and for non-antimicrobial, non-pressurized containers, “If empty: Do not reuse this container. Place in trash or offer for recycling if available.” EPA will monitor for the new statements beginning October 1, 2003. Note for partly filled containers specific language see PR Notice 2001-6.

          2. For aerosol containers, "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 option is not available, wrap the container in several layers of newspaper and discard in the trash." (Reference: PR Notice 94-2) The phrase “wrap the container in several layers of newspaper and” may be omitted from the instruction, per PRN 2001-6, so that it would read....option is “not available...discard in the trash.”

            Note: The older allowable statement in 2.a.(1) above is identical to the older statement required for the disposal of residential/household-use pesticides. Consequently, the same statement could serve as disposal instructions for the pesticide and the container.

        2. All Other Products. If the label under review involves a chemical for which a Registration Standard or RED Document was issued after PR Notice 83-3 (issued 3/29/83), refer to the Registration Standard or RED Document to determine if specific container disposal statements are provided. If no specific labeling is provided or if no Registration Standard or RED Document exists, refer to Table 2 which provides the container disposal statements from PR Notice 83-3. These statements are still applicable to all non-residential/household use products and antimicrobial, residential/household use products.

        3. Specific Container Disposal Language.

        Furadan 3G

        "Completely empty bag into application equipment by shaking and tapping sides and bottom to loosen clinging particles. Then dispose of bag in a sanitary landfill or by incineration, or, if allowed by state and local authorities, by burning. Otherwise, the bag is an acute hazardous waste and must be disposed in accordance with local, state and federal regulations."

        Furadan 4F

        "Non-returnable Plastic or Metal containers: Triple rinse (or equivalent) and empty rinsate into application equipment. Then offer for recycling or reconditioning, or puncture and dispose in a sanitary landfill, or by other procedures approved by state and local authorities. If rinsate cannot be used, follow pesticide disposal instructions. If not triple rinsed, Furadan containers are acute hazardous wastes and must be disposed in accordance with local, state and federal regulations. DO NOT cut or weld metal containers."

        TABLE 2: Disposal Statements
        Container Type Disposal Statements
        Metal Containers (non-aerosol) Triple rinse (or equivalent). Then offer for recycling or reconditioning, or puncture and dispose of container in a sanitary landfill, or by other procedures approved by state and local authorities.
        Paper and Plastic Bags Completely empty bag into application equipment. Then dispose of empty bag in a sanitary landfill or by incineration, or, if allowed by state and local authorities, by burning. If burned, stay out of smoke.
        Glass Containers Triple rinse (or equivalent). Then dispose of in a sanitary landfill or by other approved state and local procedures.
        Fiber Drums with Liners Completely empty liner by shaking and tapping sides and bottom to loosen clinging particles. Empty residue into application equipment. Then dispose of liner in a sanitary landfill or by incineration if allowed by state and local authorities. If drum is contaminated and cannot be reused, dispose of it in the manner required for its liner.
        Plastic Containers Triple rinse (or equivalent). Then offer for recycling or reconditioning, or puncture and dispose of in a sanitary landfill, or incineration, or, if allowed by state and local authorities, by burning. If burned, stay out of smoke.
        Compressed Gas Cylinders Return empty cylinder for reuse (or similar wording).
        Foil outer pouches of water soluble packets (WSP) Dispose of the empty outer foil pouch in the trash, as long as WSP is unbroken.

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