If a Farmer Owns A Minibulk
We've been getting calls asking how the new USEPA rules apply to farmers who own their own minibulks. If this is the case, and the farmer asks you to refill their minibulk, the minibulk must meet all the requirements of the new rule including: it must be a DOT approved package, the tank must be on the registrant's approved list of packages, it must have a unique identification number, contain one-way valves or tamper evident devices, and retesting is required every 2.5 years from date of manufacture. The tank must also be properly labeled for the product it contains. If the farmer brings the tank to you for refilling and the one-way valve or tamper evident devices are not intact, proof that the tank was properly cleaned must be provided by the farmer in writing to the refiller, or the refiller needs to clean the tank before filling it.
Remember that minibulks that you use in your custom application business are "service containers" and are not subject to this regulation. USEPA has provided an updated powerpoint presentation that provides a good overview of the rule with commonly asked questions. You can view this powerpoint here http://www.ifca.com. The IFCA website also lists numerous compliance guides to help you understand this regulation, which went into effect last August. Illinois Dept of Ag will be conducting compliance visits this year, so if you have any questions please contact IFCA.