Yesterday (May 2) an industry committee met with the IL Dept of Ag management team and Weights & Measures officials to discuss issues surrounding IDA's recent letter requesting Certificates of Conformance (COC) for large scales. Ag retail, grain, asphalt and aggregate producers participated in the discussion. From IFCA, Jean Payne, John Allen from Brandt Consolidated and Dick Stiltz from Lincoln Land FS represented the ag retail industry. Tom Walz from Walz Scale, Brad Fryburger from S IL Scale, Kerby Damery from Decatur/Danville Scale and Louie Straub from Fairbanks provided valuable input from the scale service prospective. Thank you to all these gentlemen for providing their time and expertise to help the industry as a whole.
Certificates of Conformance with NTEP (National Type Evaluation Program) are documents that scale manufacturers obtain to assure that their products meet national standards. The consensus at the meeting was the proof of a COC would only be required for scales installed after July 2002 (this was when the law was updated to insert the word "new" into the statute). The committee also unanimously recommended that transfer of ownership does not mean that the scale is "new." IDA will now internally review the recommendations of the committee and provide regulatory clarification on these issues; we are optimistic that IDA will accept the committee's recommendations.
So, in the meantime, continue to keep your large scales maintained and certified, and life as we know it will continue to go on. We requested that enforcement of the COC for scales installed prior to 2002 when ownership changes occur also be suspended until language clarifying "new" is put into the law. Regarding flow meters, we have requested another meeting with IDA later this summer to address those issues and will bring in retail representatives and experts from the meter industry to provide input. Enforcement of NTEP requirements on meters should also not be occurring pending further meetings with IDA. If you encounter any enforcement issues with large scales or meters regarding COCs or meters being red-tagged, please contact IFCA immediately. We appreciate that IDA convened this meeting with the industry to address this issue. IFCA has a long history of being able to work productively with IDA to ensure compliance and fairness for the industry and this meeting was further evidence of the value of our partnership with IDA.
USEPA recently issued several color flow-charts to help repackaging establishments determine the compliance requirements for refilling pesticide containers. There are 3 flow charts, one that explains "service containers" one that explains filling tanks larger than 119 gallons and one for filling smaller containers. We have posted these flow charts on the IFCA homepage under "USEPA New Minibulk Regulations." If a farmer asks you to refill a minibulk that the farmer owns, the minibulk must meet the requirements of the regulation for you to legally refill it in accordance with your repackaging agreement. If you have questions about this regulation please contact IFCA.