4.2 Storage, Inventory, and Fire-Department Submittal

4.2 Storage, Inventory, and Fire-Department Submittal

Quick Answer: If you are a licensed applicator or dealer and you store pesticides, send the local fire company — by May 1 each year — a list of pesticides stored or likely to be stored, a location description or diagram, and a cover letter citing N.J.A.C. 7:30-9.5(b). Keep the list separate from the storage area and keep cover letters three years. Staging at a load or application site for less than seven calendar days, or personal residential use, is excepted. Never put pesticides in food, drink, or household containers.

N.J.A.C. 7:30-9.5 is storage. N.J.A.C. 7:30-9.6 is containers. Core candidates mash them together. Locked restricted-use cages, the May 1 fire packet, and the soda-bottle prohibition are three different duties, and the exam will test them as three different duties.

Restricted-use pesticides when unattended

7:30-9.5(a) requires restricted-use pesticides and containers contaminated by restricted-use residues, when unattended, to be stored in a secure, locked enclosure. The enclosure must bear prominently displayed warnings in English and in any other language the Department designates to reflect the ethnic majority of the local geographic area. An unlocked shed behind the shop, or a locked shed with no warning, fails (a) even if your May 1 letter is perfect.

The May 1 fire-company packet

7:30-9.5(b) applies to any person required to be a licensed pesticide applicator or dealer who stores any pesticide — not only restricted-use products, and not only dealers. During the license year you maintain a list of pesticides stored or likely to be stored. Each year you send the local fire company:

1. A copy of that list
2. An explanatory cover letter
3. A written description or diagram depicting the exact location of the area on the property where the pesticide is stored

Update and send that package each year by May 1. 7:30-9.5(b)3 tells you what the cover letter must do: explain that the list has been sent pursuant to N.J.A.C. 7:30-9.5(b). Rutgers Cooperative Extension repeats that citation so firefighters know why a landscape company just mailed them an inventory. A letter that says only "here is our chemical list" without the rule citation does not match (b)3.

Keep the list at a location separate from the actual storage site ((b)2). Taping the inventory to the inside of the pesticide shed puts it in the fire — the one place first responders cannot read it. Keep a copy of each year's cover letter on file three years and produce it immediately on Department request ((b)4).

Exceptions sit in the (b) lead-in. The subsection does not apply to individuals storing pesticides for personal use on their private residence, or to persons storing pesticides for less than seven calendar days at loading or application sites in connection with their use. A four-day staging pile at a school ballfield is inside the exception. Day eight at that field, or a year-round shop inventory, is not. "Likely to be stored" means you list products you reasonably expect to hold during the license year, not only what happens to be on the shelf at 8:00 a.m. on May 1.

Buildings, fumigants, vehicles, food, and spills

Do not store restricted-use pesticides in a building wholly or partly occupied as a private residence unless the storage room is structurally separate from living areas and ventilation keeps fumes out of living space. Multi-family housing adds a location-risk test. The same structurally-separate-and-ventilated rule applies to commercial establishments and institutions. Storage of a restricted-use fumigant listed in 7:30-2.10(a)2 in a multi-family residence or in multi-unit commercial or institutional buildings is treated as a significant risk and is prohibited, except ethylene oxide stored under OSHA 29 CFR Part 1910.

Service vehicles that store or transport pesticides must, among other 7:30-9.5(f) items: display signs on at least two sides identifying the vehicle as containing pesticides or as a pest-control service vehicle, with lettering at least three inches high, plus applicable advertising and (for applicator businesses) 7:30-7.1(e) markings; secure containers smaller than five gallons against spills and bumps; pad glass; brace five-gallon-or-larger containers; carry absorbent plus a shovel and/or broom and pan used exclusively for spills; carry an accessible, working 10-B:C dry chemical or carbon dioxide extinguisher; keep pesticides in a compartment separate from the driver (a grillwork or heavy screening partition is enough); lock or secure unattended containers and portable application equipment in open areas; and use hatch or door covers that prevent tank spillage while moving.

7:30-9.5(g): do not store or display a pesticide next to food or animal feed (personal-residence exception). 7:30-9.5(h): anyone who stores or displays any pesticide must have exclusive spill-response equipment immediately available — enough absorbent for a potential liquid spill and a shovel or dustpan-and-brush, or a recovery system. Personal-residence storage is excepted from (h).

Never food, drink, or household containers

7:30-9.6(c) is the one-line rule Core exams love: No person shall place or keep any pesticide in any container commonly used for food, drink, or household products. A soda bottle, milk jug, spray bottle that once held glass cleaner, or leftover detergent jug is illegal even if you write the product name on the cap with a marker.

Service containers are legal when they carry a copy of the registered label or a readable label with brand or trade name, EPA registration number, name and percentage of active ingredients, and the signal word (Danger-Poison, Warning, or Caution) — 7:30-9.6(b). Original labeled containers must remain readable. 7:30-9.6(a) bans storing, transporting, or possessing a pesticide whose registered label is missing, obscured, altered, unreadable, or damaged beyond use, with listed exceptions for service containers, application equipment, manufacturing or formulating, and public officials performing official duties.

Worked: Coastal Green LLC stores 12 herbicides and insecticides in a locked, posted shed behind 14 Route 9. By May 1 the office mails the local fire company (1) the product list, (2) a plot diagram showing the shed behind the office, and (3) a cover letter stating that the list is sent pursuant to N.J.A.C. 7:30-9.5(b). The list lives in the office filing cabinet, not in the shed. Cover letters from the last three May 1 mailings stay in that cabinet. On a Tuesday they stage three jugs at a commercial turf site and finish by Friday — five calendar days, so no extra fire letter for that site. They mix in original jugs or labeled service containers, never a leftover iced-tea bottle.

High-yield traps

• The fire packet is due May 1, not October 31 (that date is the commercial license expiration).
• The cover letter must cite 7:30-9.5(b).
• The list is kept separate from storage.
• The duty covers any pesticide stored by a licensed applicator or dealer, not only restricted-use products.
• The staging exception is less than seven calendar days at a load or application site.
• Food, drink, and household containers are never pesticide containers.

Official resources

• N.J.A.C. 7:30-9.5 Storage of pesticides
• N.J.A.C. 7:30-9.6 Containers and container labeling
• Rutgers PAT storage inventory with cover letter (due May 1)