Department of Pesticide Regulation
|Brian R. Leahy
|Edmund G. Brown Jr.
|May 17, 2013
|County Agricultural Commissioners|
DISPOSAL OF PROPANIL DRY FORMULATION EMPTY CONTAINERS
Dry formulations of propanil products (new and existing stock)
Existing stocks of older labeled products without the closed mixing system requirement may be used by the end-user until such stocks are depleted.
1. Closed system technology for the transfer of dry formulation from the container to the mix or spray tank:
The two registrants, RiceCo, LLC and Willowood, LLC, have taken different approaches to packaging the dry formulations.
Willowood has opted to use the "Lock and Load" technology currently used for products such as Temik® Brand 15G "Lock'n Load" and Thimet® 20-G "Lock'n Load". This technology meets both U.S. EPA and DPR requirements as a closed mixing system.
RiceCo has developed a new closed system technology they call "RiceCo Delivery System I" (RDSI).
The RDSI consists of three parts:
DPR's enforcement staff has received numerous calls from both industry and County personnel expressing concern with this new technology. DPR asks that you monitor any issues that arise this use season pertaining to this new closed system technology so that prior to next season we can share the information with RiceCo and work with them to find solutions.
Please be reminded that any person who improperly uses or alters a closed delivery system that compromises the integrity of the system, does so in violation of Food and Agricultural Code section 12973, use of a pesticide in conflict with its registered labeling.
2. Disposal of emptied pesticide containers.
The Willowood dry formulated product is packaged in a refillable, returnable plastic container. Willowood intends to impose a container deposit on pest control dealers selling their product to encourage return of the emptied containers to the dealer location. Representatives from Willowood have indicated they will implement a container retrieval program where emptied containers will be retrieved from the dealers at specified intervals during the use season.
The RiceCo dry formulated products are packaged in non-refillable bags made of a synthetic material. The following label instructions for container disposal are provided for the RiceCo products, under the label section titled "Container Disposal":
"Nonrefillable container. Do not reuse or refill this container. Completely empty bag into application equipment. Then offer for recycling if available or 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."
The following bag disposal options have been identified:
Again, please report any problem associated with the use of dry formulations of propanil (including container disposal) to the Enforcement Branch Liaison assigned to your county.
If you have questions, contact the Enforcement Branch Liaison assigned to your county.
|Original Signature by:|
| George Farnsworth
Chief, Enforcement Branch
cc: Mr. Joe Marade, DPR
1001 I Street ·
P.O. Box 4015 · Sacramento,
California 95812-4015 ·
A Department of the California Environmental Protection Agency