The Honorable Stephen Johnson
Environmental Protection Agency
1201 Pennsylvania Avenue, NW
Washington, DC 20460

August 9, 2007

Dear Administrator Johnson,

ARA requests your support in getting the EPA to move quickly on publishing a proposed rule to make empty plastic pesticide disposable container recycling a regulatory requirement. The more than 15 year success of the Agricultural Container Recycling Council (ACRC) voluntary program and other independent voluntary programs could be undermined if non-refillable pesticide container recycling is not required to be supported by pesticide registrants.

ARA and its members understand the need to make non-refillable pesticide container recycling a regulatory requirement so that it is supported by all pesticide registrants. However, we also believe it is vital to implement a national approach to this stewardship arena to avoid a patchwork of state-by-state requirements that will be difficult to manage and not be as effective as a consistent national program. Both agricultural and other pesticide users need a uniform, national program for recycling in order to develop a highly effective system for proper rinsing of empty containers, inspection and transportation to collection centers where the registrant