TELONE™ Stewardship Tip Sheet: Bulk Site Self-Inspection Checklist

Posted on | by Justin Harrison

Managing a bulk site isn’t just about keeping the tanks full—it’s about maintaining safety, efficiency, and compliance. The EPA mandates regular inspections (yes, they really do check!) and requires you to keep detailed records. If the idea of juggling those requirements makes your head spin, don’t worry—this blog post will cover the major inspection points and you can download a convenient checklist to use at your bulk site facility.

We break down every inspection point into clear, actionable steps. No guessing games, no overlooked items—just straightforward guidance tailored to your site’s needs. And here’s the kicker: following this checklist could save you from costly downtime, hefty fines, and last-minute scrambles during the busy season. Let’s dive in!

PREPAREATION IS KEY

Investing time now in preventive maintenance and thorough inspections will prepare you for a smooth soil fumigation season next year. A well-maintained site protects your team and equipment and enhances your reputation for reliability with your customers. Let us help you take out the guesswork of conducting a bulk site inspection! Remember, there’s no coming back from a poor start!

REGULATORY REQUIREMENTS: EPA STANDARDS

As specified in 40 CFR 165.90, the EPA mandates monthly inspections of each bulk tank, its appurtenances, and each containment structure where pesticides are stored or dispensed. Additionally, 40 CFR 165.95 requires that you:

  • Keep Records for 3 Years
  • Inspection and maintenance records must include:
    • The name of the person conducting the inspection or maintenance.
    • The date the inspection or maintenance was conducted.
    • Conditions noted during the inspection.
    • Specific maintenance performed.
  • Furnish Records on Request
    • These records must be accessible to the EPA if requested.

Failing to meet these requirements can result in fines or operational delays, so maintaining accurate records is critical.

CUSTOMIZING YOUR INSPECTION PROCESS

Further below, we provide a suggested list of items to inspect at your bulk site. Use this list as a starting point and customize it for your facility. Consider additional requirements, such as those related to:

  • Rail Delivery: Inspect unloading areas and ensure compliance with rail-specific safety standards.
  • Site Security: Verify fencing, locks, and other measures to control access to your site.

This example list focuses on physical infrastructure and does not cover administrative items such as repackaging agreements or DOT vehicle requirements.

ASSIGN RESPONSIBILITY AND FOLLOW-UP

  • Designate Personnel: Assign a specific, trained person to conduct inspections and maintain records.
  • Ensure Follow-Up: Implement a system to address and resolve any issues identified during inspections.
  • Leverage Teleos Support: Bulk site maintenance may be reimbursable under the Teleos stewardship program. Keep a file of receipts and consult your TELONE Specialist for guidance.

PRO TIP: Thorough documentation and consistent follow-through ensure compliance and reinforce operational safety and efficiency, reducing the risk of costly downtime or repairs. Download the checklist here!

For reference, here is what the checklist looks like:

In conclusion, managing your bulk site is a critical part of your onsite stewardship plans. It is important to stay on top of safety and maintenance issues, and track your compliance for EPA record keeping. When in doubt, be sure to reach out to your TELONE™ Specialist to help answer your questions. We are here to help.

Disclaimer:
The resources and information provided are meant purely for educational discussion, contains only general information about legal matters, and is not to be construed as advice. Please note that any information or resources provided are not legal or regulatory advice, and should not be treated as such. You must not rely on the information provided as an alternative to legal advice from your attorney or other professional services. Teleos Ag encourages readers to consult with counsel, and their local, county, and state regulators. We make no representations or warranties, express or implied, in relation to the information provided through our resources and blog posts. It is the readers responsibility to know the laws related to 1,3- D, appropriate PPE, Licensing, etc., in his or her City, County, State, and Country.

Justin Harrison
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