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Local governments are responsible for the storage of any unused or excess pesticides. The recommended procedures and criteria for proper storage apply to areas where pesticides are classified as highly toxic or moderately toxic, and have written on their labels DANGER, POISON, WARNING, or the skull and crossbones symbol. FIFRA defines adequate storage as placing pesticides in proper containers and in safe areas to minimize the possibility of accidental release that could result in adverse effects on the environment. Storage sites should be in a dry, well ventilated, separate area where fire protection is provided. Identification signs should be posted to advise of the contents and hazardous nature of the pesticide. The potential environmental impacts from pesticide storage are air, soil and water contamination from accidental releases. Because pesticides are typically stored in large quantities for future use, accidental releases may be large, causing immediate detrimental effects on the surrounding environment.
Pesticides that cause adverse effects on the environment should be stored only in facilities where special attention has been given to the hazardous nature of the pesticide. Temporary storage of highly toxic or moderately toxic pesticides may occur at isolated sites and facilities where there is unlikely contact with external conditions that may cause a release. Each container should be stored with the label plainly visible, and the container should be inspected for corrosion and leaks. The storage of pesticides must follow FIFRA guidelines under which all pesticides stored by the local government must be registered or ruled exempt from the registration requirements (40 CFR 152.15 through 152.30). FIFRA covers Worker Protection Standards that must be followed when personnel handle pesticides. In addition, FIFRA also lists safety measures that must be followed by personnel that are around pesticides and containers.
Reporting/Notifying
Under FIFRA, EPA or a registrar can cancel or suspend the registration of a pesticide or of a specific use of a pesticide. In such situations, EPA or the state regulatory agency would request that all entities having supplies of that pesticide notify the state. If a local government has on hand any amounts of canceled or suspended pesticides, it must notify the state of the amount. In response, the state will provide specific directions as to what to do with the pesticide.
There are many pesticides included on EPA's List of Extremely Hazardous Substances. Under EPCRA, if a local governments has on hand more than the threshold amount established for any of those pesticides, it must notify, in writing, both the Local Emergency Planning Committee (LEPC) and State Emergency Response Commission (SERC), and provide a contact name who can provide more information, as required. Pesticides on the list include methyl parathion, aldicarb, endosulfan, and methyl bromide.
Also under EPCRA, if a local government has an accidental release of any of the extremely hazardous substances, or a release of any of the chemicals on EPA's Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) hazardous substances list, it must immediately notify EPA or the state if the release exceeds the reportable quantity for that pesticide.
Many local government operations may be required to develop risk management plans if they store certain chemicals onsite. Sources that produce, process, handle, or store hazardous substances above threshold quantities will be required to implement a risk management plan to detect and prevent or minimize accidental releases. The list of chemicals contains 77 toxic substances and 63 flammable substances. Examples of the substances include anhydrous ammonia, chlorine, hydrochloric acid, methane, and propane. (Dowden et. al., 1994)
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