Hey Doug,

Did a little more searching, and found an EPA document. 

1998 EPCRA Section 313 differentiates between relabeling, redistributing, and repackaging. From that document: {“Repackaging” refers to the act of removing a toxic chemical from one container and placing that toxic chemical into another container. Simply repackaging one container (that contains a toxic chemical) into another container does not constitute processing of that listed toxic chemical under EPCRA Section 313. The nesting of containers is not repackaging for EPCRA Section 313 purposes.}

The nesting of containers refers to the common practice of overpacks commonly used for depleted toxic chemicals going to TSDs for burial or incineration. What you described is NOT nesting.

Based on the EPA view, decanting a chemical from one bulk container to another container is within the basic definition of repackaging, and is considered "processing" by EPA regulations as well.

There is also a "marketing" definition of "repackaging" that your management may be thinking about, which could be causing the confusion. I believe that marketing repackaging involves changing the identity of the product (rebranding?), which is not your case.

The answer lies with what is driving the question. Who cares? It is their definition that counts. Is this an ISO9000 issue or something of the same ilk. If so, they should answer your question.

Best of luck,

Steve Mikell
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