Are facilities required to rinse inert drums?
No. The rinsing of drums containing pesticide active ingredients or inerts or other raw materials is not required by the PFPR rule. However, if a facility does rinse their drums, the wastewater generated by those rinsing operations is covered by the rule. Note that FIFRA (40 CFR 165.9(b)) requires that Group II containers (noncombustible containers which formerly contained organic or metallo-organic pesticides, except organic mercury, lead, cadmium, or arsenic compounds) should first be triple-rinsed before reuse or disposal. Also, there are certain RCRA regulations which require rinsing of containers that have held certain types of hazardous waste (40 CFR 261.7(b)(3)).