8.3 Post-Application: Cleanup, Disposal & Records

Equipment Cleanup: Triple-Rinse and Rinsate

Quick Answer: The application is not over when the last nozzle shuts off. Post-application work — equipment cleanup, PPE removal, personal wash-up, container disposal, leftover-spray disposal, and record completion — is where exposure, environmental, and compliance risks re-emerge. The National Core Manual and Michigan Part 83 treat cleanup as a continuation of the application: every rinse, every rinsate drop, and every container has a rule.

After the spray run, triple-rinse the tank, hoses, boom, and nozzles. Triple-rinsing means filling the tank about 10% full with clean water, agitating, and draining through the boom; repeat for a total of three rinses. The combined rinsate is pesticide-containing liquid, not clean water — apply it to a labeled site at or below the label rate. Never pour rinsate down a storm drain, into a ditch, or onto a single spot in the field where it can puddle and run off.

For equipment that cannot be rinsed in the field (some boomless sprayers, nurse trailers), use a dedicated mix/load pad with a sump that captures the rinsate for later labeled-site application.

PPE Removal Order

PPE that protected you during application is now contaminated on its outside surface. Remove it in an order that keeps the dirty side away from your skin and lungs:

1. Outer gloves — peel off one glove with the other, then strip the second by slipping fingers inside. Do not touch bare skin to glove exteriors.
2. Boots and apron — unfasten and lift off without dragging the contaminated side across your face or clothing.
3. Protective suit or coveralls — roll down, inside-out.
4. Respirator — remove last, so that filters and cartridges are not handled while the gloves are still on.
5. Eye protection — remove, then wash face and hands.

Bag disposable PPE for disposal with the pesticide containers. Wash reusable PPE separately from family laundry using hot water and detergent; do not wash pesticide-contaminated clothing with the household wash.

Personal Wash-Up

After PPE removal, wash hands, face, and any exposed skin with soap and water before eating, drinking, smoking, using the restroom, or going home. Shower as soon as you can — ideally at the worksite or immediately on arrival home — and change into clean clothes. Keep a jug of clean water and soap in the truck for field wash-up; do not rely on finding water at the application site.

Container Disposal

Rigid pesticide containers (jugs, drums, mini-bulks) must be triple-rinsed or pressure-rinsed before disposal. After rinsing, puncture or otherwise render the container unusable so it cannot be reused for any other purpose. Disposal options, in order of preference:

1. ACRC recycling. The Ag Container Recycling Council (ACRC) operates a no-cost collection program for triple-rinsed HDPE pesticide containers in many Michigan counties through cooperators. This is the preferred route for agricultural containers.
2. Licensed hazardous-waste hauler. For containers that held RUPs or products with specific disposal language, follow label disposal instructions and use a licensed hauler.
3. Sanitary landfill. Triple-rinsed, punctured containers may be accepted at a licensed sanitary landfill per label and state rules; check with the landfill first.

Never burn pesticide containers in a burn barrel or open fire — burning releases toxic residues and is illegal in Michigan for most containers. Never reuse an empty pesticide container for water, fuel, food, animal feed, or any other purpose, no matter how thoroughly it was rinsed.

Leftover Spray Solution

If you have spray mix left in the tank at the end of a job:

• Best: apply the remaining mix to a labeled site at or below the label rate. Plan the load so this is possible — the core-manual goal is to end the run with the tank as close to empty as the boom will allow.
• Acceptable (with rinsate): rinse the tank and apply the rinsate to a labeled site.
• Never: dump the remaining spray on the ground, into a ditch, down a drain, or into surface water.

Record Completion

Michigan's record rule for commercial applicators is R 285.636.15 (detailed in Section 2.4). It sets two retention periods and one element list:

The seven required elements, identical for both:

• Product name and EPA registration number
• Concentration of the pesticide applied
• Amount of end-use dilution applied
• Target pest, purpose, or crop site
• Date of application
• Address or location of the application
• Method and rate of application

The duty to keep the record belongs to the employer of the commercial applicator, who must hold it at the place of business and produce it to an authorized representative of the MDARD director on request during normal business hours. Federally certified private applicators additionally record restricted-use applications within 14 days and keep them 2 years under 7 CFR Part 110, and WPS training records are kept 2 years — three separate duties with three separate clocks.

Falsifying or failing to keep records is a violation independent of the application itself: a perfectly executed spray with no record is still a violation. Since general-use records run only 1 year and restricted-use records run 3, the simplest compliant policy is a single 3-year retention for everything.

REI Enforcement and Notice

For applications subject to the Worker Protection Standard, the Restricted-Entry Interval begins the moment application ends. During the REI:

• Keep workers and other people out of the treated area unless they are wearing the label-specified early-entry PPE.
• Post WPS warning signs at the normal points of entry if the label requires posting or the REI exceeds 48 hours.
• Notify the worker-in-charge (or the grower, for contract applicators) that the REI is in effect.

For non-agricultural sites (lawns, structures), follow the label's REI and any company or state posting requirement; keep people and pets off until the surface has dried and the REI has passed.

Equipment Storage

After cleanup, store the sprayer and PPE in a locked, ventilated, dry storage area, away from food, feed, seed, and fertilizer, and away from children and animals. Never store pesticides in the cab of the truck or in the living quarters of a home or shop. Triple-rinsed empty containers and ready-to-dispose PPE go into the same secured storage pending disposal or recycling.

Tie-Back to Chapter 2.4

This section operationalizes the record-keeping rules in Chapter 2.4 — the elements listed here are the ones MDARD inspectors ask for first. If you cannot produce, on demand, a record showing the product's EPA Reg. No., the rate, the site, the date/time, and the weather, the application is effectively undocumented even if it was perfectly executed. The 3-year retention period, the at-the-time-of-application rule, and the EPA Reg. No. requirement are all high-yield exam points.