Background on option to lock facilities or valves 

EPA Office of Pesticide Program staff Nancy Fitz and Jeanne Kasai
participated in the Pesticide Regulatory Education Program (PREP) on
Pesticide Container/Containment Implementation July 14 – 18, 2008 in
Grand Rapids, Michigan.  

The 34 participants represented pesticide State Lead Agencies, Tribes,
and EPA Regions and Headquarters.  The course goal was “…for
participants to come away with a fuller understanding of the
requirements of the federal container/containment regulations…”  
Some of the participants had experience as investigators or inspectors
for their pesticide program.  

During the course, the group questioned the requirement that valves be
locked if the facility itself was locked.  This discussion led to the
amendment giving the option that facilities lock valves (if required) or
the facility itself in § 165.90(a)(5). 

