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Janitorial
All Containers›Shop by use case›Janitorial›Getting started›From drum to jugShop all janitorial →
Getting started

From drum to jug

By Dwight Davis, Founder

Updated

On this page8
Two questions decide whether there is a project here at all, and both are answered before any liquid moves.

One: is the product a pesticide?

Does it, or will your description of it, claim to destroy or suppress harmful microorganisms on surfaces? If so it is an antimicrobial pesticide and it has to be registered, and a registered product carries an EPA registration number.

Two: if it is, do you have a written contract?

A registrant may allow you to repackage their product under their registration only if they have entered into a written contract with you to repackage it and to use their label. The registrant must give you that contract before they sell you the product.

Three: is your establishment registered with EPA?

The repackaging has to happen at, or be done by, a refilling establishment registered with EPA under 40 CFR 167.20. That is a registration you hold, not something the registrant can lend you.

Four: does the container meet subpart C?

Designed, constructed and marked to the 49 CFR requirements the rule enumerates. If the answer is no, the lawful options are a compliant container from elsewhere or not repackaging, and nothing we sell supplies it.

Five: is the label the registrant’s, unchanged?

The product is labeled with the registrant’s own label with no changes except an appropriate net contents statement and your EPA establishment number. Your branding is not one of the permitted changes.

If any answer is no, stop at that answer

This is the one property in the library where the honest advice is sometimes to not do the thing. Repackaging without all five conditions is a section 12 violation, and the exposure runs to the registrant too.

For a non-pesticide concentrate, go straight to the jug

Hazard communication, a safety data sheet, dilution instructions and a closure that resists the chemistry. That is a normal packaging project and it is what this shelf is for.

References

40 CFR 165.70, Refillers who are not registrants. Paragraph (b) sets the five conditions under which a registrant may let you repackage their product into refillable containers, including an EPA-registered refilling establishment and a written contract; paragraph (c) makes repackaging without them a violation of section 12 of the Act for which both you and the registrant may be liable. law.cornell.edu
40 CFR 165.67, Registrants who distribute or sell pesticide products to refillers for repackaging, the mirror of 165.70. Paragraph (d) requires the registrant to provide the written contract to the refiller before the product is distributed or sold to them; paragraph (e) keeps the registrant responsible for product integrity. law.cornell.edu
40 CFR 165.45, Refillable container standards. Paragraph (a)(1) requires a non-DOT-hazardous pesticide in a portable refillable container to be designed, constructed and marked to comply with an enumerated list of 49 CFR requirements for a Packing Group III material, including parts 178 and 180; paragraph (b) requires full 49 CFR parts 171-180 packaging where the product is a DOT hazardous material. law.cornell.edu
29 CFR 1910.1200, Hazard Communication, which sets what a shipped container of a hazardous chemical carries and requires a safety data sheet. law.cornell.edu
Written from federal regulation, not from a plant floor. FIFRA is administered by EPA and the states have their own pesticide programs on top of it. Nothing here is a registration, a contract or a finding that a container complies; those are the registrant’s, the lawyer’s and the container manufacturer’s to give.