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Pesticide Container and Containment Regulations for IBC’s

Pesticide Container and Containment Regulations for IBC’s. Patrick Nellenbach. What Does Do?. Agrium is the only publicly traded company that crosses the entire agricultural value-chain.

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Pesticide Container and Containment Regulations for IBC’s

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  1. Pesticide Container and Containment Regulations for IBC’s Patrick Nellenbach

  2. What Does Do? Agrium is the only publicly traded company that crosses the entire agricultural value-chain. • We are now the largest direct-to-grower distributor of seed, agricultural crop protection products and crop nutrients. • CPS operates 872 retail centers, 72 terminals and 19 distribution centers in the U.S., Argentina, Chile and Canada.

  3. Operations In Michigan • Retail facilities which engage in repackaging and custom application activities • Wholesale and Distribution Centers which deliver to other retailers and our retail network

  4. Challenges that Container and Containment Rules Present After August 16, 2011- Regulatory • Will our Existing Inventory of tanks be usable after the compliance date? • Tamper Evident Devices and One Way Valves? • How do we meet DOT Testing Requirements? • Container and Inspection Identification • Recordkeeping as a Wholesaler and Retailer • Educating Our Employees

  5. Challenges that Container and Containment Rules Present After August 16, 2011- Business • How do we forecast the purchase of new tanks? • Tank Manufacturers- Composite and Rotary Molded • Mitigating Rinsate Generation • Shipping Practices • Customer Owned Tanks? • Educating of our Customers

  6. What Did Do to Prepare We Created a Committee to address the New Rule • It was composed of Operations Staff, Regulatory Staff, Manufacturing Staff, Retail Staff and Wholesale Staff from all the regions of the company • We wanted to pool our experiences to develop procedures that the company as a whole could adopt • We wanted individuals each region could turn to for guidance and progress • We wanted to develop a framework of preferences to communicate to Tank and component manufacturers • We wanted to develop sound business practices but we also wanted to integrate stewardship

  7. Any Progress? • I believe we influenced how manufacturers will design tanks for the future • Overwhelmingly decided to adopt the comprehensive use of one way valves • Centralized communication regarding the purchase of tanks for both manufacturing and retail • Centralized recycling and disposal efforts for tanks • Have begun to develop standard operating procedures for marking, inspection and testing activities

  8. We Still Have Some Work To Do • We have not identified one data base for inspection documentation • Knowing a little more about how the law will be implemented • Physically Identifying those tanks that need to be removed from the system

  9. What Type of Tank Going Forward? • Strong Sturdy Tanks • One Way Valves • Effective Flow • Efficiently Vents that cannot be removed • The Fewer Openings the Better • Pumps on the top of tanks may present a challenge

  10. Questions?

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