4.2 Transporting & Storing Pesticides Securely (Pes 800)
Key Takeaways
- Never carry pesticides in the passenger compartment of a vehicle, and never stack containers higher than the sides of the vehicle.
- Always carry product labels, Safety Data Sheets, and a spill kit when transporting pesticides on highways.
- Pes 802.03 requires that pesticides and unrinsed containers be stored in a separate room, protected and secured so they are not readily accessible to children and the general public.
- Pesticide storage room floors must be smooth to allow complete recovery of spills; earthen floors are prohibited, and the room must be vented to the outdoors.
- Storage signage must include the word Warning, Danger, or Pesticides in lettering at least one and one-half inches high, followed by wording indicating pesticides are in storage.
4.2 Transporting & Storing Pesticides Securely (Pes 800)
Pes 304.09(b)(2)g makes this an examination subject in so many words: "proper identification, storage, transport, handling, mixing procedures and disposal methods for pesticides and used pesticide containers, including precautions taken to prevent children from having access to pesticides and pesticide containers."
Serious pesticide accidents are more likely to occur while product is in transit than at any other time. The applicator is usually the first and only responder.
Transportation
The vehicle
- Brakes, tires, and steering must be in proper working order; repair all fluid leaks before putting a truck on the road.
- Inspect application equipment before transport - hoses under pressure for wear and cracks, hose clamps for rust.
- Carry supplies and replacement parts to make emergency repairs if a leak develops en route.
- Flatbed trucks should have tie-down rings or racks.
- Enclosed cargo boxes add security against curious children, thieves, and vandals.
Loading rules
+------------------------------------------------------------------+
| TRANSPORT DO NOT LIST |
+------------------------------------------------------------------+
| x NEVER carry liquid pesticides in the PASSENGER AREA |
| x NEVER stack containers higher than the sides of the vehicle |
| x NEVER transport pesticides with food, feed, or seed |
| x NEVER leave a loaded vehicle unattended and unsecured |
| x NEVER transport leaking or unlabeled containers |
+------------------------------------------------------------------+
Spilled chemical in a cab produces fumes that are inhaled for the length of the trip, and is very difficult to remove. Keep containers in the original shipping box where possible - many of those boxes meet U.S. Department of Transportation packaging standards. Carry the minimum quantity the day's work requires.
What rides with the load
- Product labels and Safety Data Sheets, organized alphabetically by product name for fast retrieval. Pes 502.02 independently requires that a complete copy of the labeling accompany service containers and application equipment in the transporting vehicle.
- A spill kit: absorbent material, a broom and shovel dedicated to pesticide use, heavy-duty containment bags or a recovery drum, and the PPE the labels call for.
- Protect product from temperature extremes and moisture; freezing or overheating can destabilize formulations.
The operator
The driver and the company owner are accountable for injuries and for any release to the environment. Because the driver is the first person able to contain a spill, the driver must know basic emergency response steps, company reporting guidelines, and who notifies local, state, and federal authorities.
Drivers moving pesticides that are regulated as hazardous materials in placard quantities must follow DOT rules on commercial driver licenses, placarding, shipping papers, and annual inspections, and must implement a transportation security plan. DOT placards are diamond-shaped and are read by emergency responders to size up a scene quickly.
New Hampshire storage rules (Pes 802)
Pes 802.03 sets nine requirements for storage by private and commercial applicators. Learn the physical ones - they are the testable ones.
| Requirement | Detail |
|---|---|
| Label compliance | Store in accordance with the requirements and precautionary storage instructions on the product label |
| Legible labeling | Containers must have legible labeling indicating contents, per Pes 502.02 and Pes 504.01 |
| Separate room | Pesticides and containers that have not been triple rinsed must be stored in a separate room, in a manner preventing contamination of food, feed, seed, livestock remedies, drugs, plants, and other materials from volatilization, leakage, breakage, or other causes |
| Security | Storage rooms must be protected and secured so they are not readily accessible to children and the general public |
| Floor | Floor surface must be smooth, facilitating complete recovery of spills - sealed concrete or plastic, for example. Earthen floors are prohibited |
| Signage | Sign(s) must include the word "Warning," "Danger," or "Pesticides" followed by wording indicating pesticides are in storage, with that word in lettering at least one and one-half inches high |
| Ventilation | Storage rooms must be vented to the outdoors |
| Temperature | Store in a dry place and in accordance with label temperature requirements. Fire suppression systems, where used or required locally, must comply with state fire code RSA 153:1, VI-a |
Pes 802.02 governs the catch-basin - a low point of the storage room floor designed to recover pesticide discharges, washwater, or rinsate. A catch-basin must be a watertight part of the floor that does not connect to below-floor or below-ground piping, containment, or storage, must be built of non-corrodible materials with easy access for cleaning, and any pumps and piping used to remove its contents must be above ground. There must be a mechanism to move a discharge into above-ground storage within one hour of a spill.
Pes 803.01 applies a stricter version to dealers storing prohibited, prohibited-limited use, or state restricted use pesticides: the storage room must be locked rather than merely secured, and the floor must be smooth and impervious.
Pes 801.02 covers material awaiting disposal. Unused or unwanted pesticides held prior to disposal - sealed or opened - and all containers that have not been or cannot be rinsed must be kept in a secure enclosure and maintained to prevent container deterioration, unauthorized use, mishandling, loss, contamination of the environment, and risk to public health.
Good storage practice beyond the rule
- Prevent water damage. Keep product off the floor on pallets or shelving, away from roof leaks and floor drains.
- Control temperature. Freezing splits containers and breaks emulsions; heat degrades active ingredients and raises pressure in aerosols.
- Provide adequate lighting, so labels can be read and leaks seen.
- Use non-porous materials for shelving and benches - metal or sealed plastic rather than bare wood, which absorbs spills permanently.
- Keep labels legible. Replace a damaged label by requesting a copy from the dealer or registrant; an unlabeled container is a disposal problem, not an inventory item.
- Watch shelf life and rotate stock. First in, first out. Buy what the season needs rather than building an inventory that eventually becomes waste.
- Isolate unwanted or waste products so they are never grabbed by mistake.
- Inspect for damage - corrosion, bulging, seepage, crystallization around closures.
Site security
Security is part of the core curriculum because a pesticide storage site is an attractive target. A workable program has four parts:
- Risk assessment - what is stored, how much, how attractive is it, and how exposed is the site?
- Physical controls - locks, lighting, fencing, alarms, restricted keys, limited access points.
- Inventory control - accurate, current records so a loss is noticed immediately.
- Employee training and awareness - staff who know the procedure for reporting a suspicious inquiry, an unfamiliar visitor, or a discrepancy between records and stock.
The benefits run in both directions: the same measures that deter theft and vandalism also prevent the accidental exposures - especially of children - that Pes 802.03(d) is written to stop.
Worked example
A small orchard stores pesticides in a corner of an equipment barn with a dirt floor, alongside bagged seed and a chest freezer of fruit, with an old sign reading "chemicals" in one-inch letters.
Every element of that arrangement fails Pes 802.03:
- the earthen floor is prohibited; the floor must be smooth and allow complete spill recovery;
- pesticides and unrinsed containers must be in a separate room, not adjacent to seed and food;
- the area must be secured against children and the general public;
- the room must be vented to the outdoors;
- the sign must carry "Warning," "Danger," or "Pesticides" in lettering at least 1.5 inches high, followed by wording indicating pesticides are in storage.
When the grower hauls product to a block, the load rides in the bed, not the cab, no higher than the sides, with labels, SDSs, and a spill kit aboard.
What does Pes 802.03 require of the floor in a New Hampshire pesticide storage room?
An applicator is driving to a job site with several containers of pesticide. Which practice is correct?
What signage does Pes 802.03(f) require on a New Hampshire pesticide storage room?