Page 1 of 8 Registrants’ Soil Fumigant Applicator Training Program Components Overview

October 8 , 2012

This document provides an overview of the various components of the Registrants’ Soil Fumigant Applicator Training Program, including the testing protocol, securi ty measures, documentation for training, regulators’ access to information, and the program evaluation and revision plan.

Testing Protocols

There are two testing protocols: one for the on

- line testing and one for in

- person training. Each component is de scribed in more detail below.

On

- Line Testing

The registrants anticipate that most certified applicators will take the on

- line training programs and tests.

The first time that a user logs into the training program, the individual will be required to provide his/her name, address, email address, state certified applicator license number for each state in which certified, if certified in more than one state, and employer and occupation. The individual also will be asked to review and agree to a statem ent regarding verification that he/she is the person named in the log

- in information and is the certified applicator licensed by the indicated state or states. The language is:

I certify that I am the individual named on the registration form

and that ( 1) the certified applicator license information shown on the registration form is my uniqu e license number issued by the

state or states indicated or (2) I am a state regulator, grower advisor, or fumigant distributor and I am accessing this program

for in formational purposes only in connection with my duties as such an employee. I acknowledge that it is a violation of the Federal Insecticide, Fungicide

, and Rodenticide Act (FIFRA) to apply a pesticide in a manner inconsistent with its label including

the requirement s regarding a state certified applicator license and soil fumigant training

.

The user will then be required to create a unique password and each time a user wants to access the program, he/she will need to use the password.

There also is a statement as part of the site registration that includes the language suggested by EPA and also covers remaining issues. The reference to the Terms of Use in this statement will provide a link to a page with the additional Terms of Use. The additional Te rms of Use statement is appended as Attachment 1 to this Overview

.Registrants’ Soil Fumi gant Aplicator Training Program Components Overview October 8, 2012

Page 2 of 8 Other security measures for testing include the variability of the test questions for any given test. For example, there may be 25 questions for a specific module, but only 15 for each individual test for that module. The computer will randomly choose the questions for a specific test. Moreover, for the multiple choice questions, the computer will randomly rearrange the answers in each test so that for a specific question “B” may be th e correct answer when one user takes the test and when the next user takes the test the correct answer will be “C.” (The actual language for the correct answer will not change.)

Each chapter in each module will have three review questions, except for Cha pter 3, which has two review questions. The review questions will remain static in the training program and so will be identical in each training session. The review questions are also included in the bank of questions for the exam and so may appear in a graded module exam.

The exams to be graded will be given at the end of each module (not each chapter), and applicators will be encouraged to complete a module and take the exam at each sitting, but will

not be forced to do so. Each module exam will co nsist of 15 questions.

The number of questions in the test question bank for each module is as follows: Module

1

– 33; Module 2

– 31; Module 3

– 25; Module 4

– 36; Chloropicrin

– 44; Methyl Bromide

– 48; 1,3

- D Chloropicrin

– 50; Metam

– 54; and Dazomet

– 53. The breakdown of questions that pertain to each of the chapters in the training is as follows:

i. Module 1, Chapter 1

– 11

ii. Module, 1, Chapter 2

– 10

iii. Module 1, Chapter 3

– 12

iv. Module 2, Chapter 4

– 15

v. Module 2, Chapter 5

– 16

vi. Module 3, Chapter 6

– 16

vii. Modu le 3, Chapter 7

– 9

viii. Module 4, Chapter 8

– 20

ix. Module 4, Chapter 9

– 16

x. 1,3D plus Chloropicrin, Chapter 1

– 25

xi. 1,3

- D plus Chloropicrin, Chapter 2

– 25

xii. Methyl Bromide, Chapter 1

– 28

xiii. Methyl Bromide, Chapter 2

– 20

xiv. Metam, Chapter 1

– 28

xv. Metam, Chapter 2

– 26

xvi. D azomet, Chapter 1

– 28

xvii. Dazomet, Chapter 2

– 25

xviii. Chloropicrin, Chapter 1

– 20

xix. Chloropicrin, Chapter 2

– 24Registrants’ Soil Fumi gant Aplicator Training Program Components Overview October 8, 2012

Page 3 of 8 There is a total of 374 exam bank questions. Each graded module exam will have a random mix of questions for all chapters in the module selected from the exam question bank. There will be 15 questions on each module exam. The randomization is truly random, so the program will assign a representative number of questions from the exam bank for each chapter in the module exam. Because the program contr ols the individual questions presented in each exam, it is not possible to state definitively the exact number of questions that will be selected from each chapter.

If an incorrect response to an exam question is given, the program will note that the

an swer is incorrect, but the correct response will not be shown during the exam. At the end of the exam, the applicator will be shown the correct answer for multiple choice questions but not

others.

A passing grade of 70% will be required for each module e xam. Applicators are required to take and get a passing grade of 70% on all four general application modules and at least one active ingredient specific module to obtain Proof of Completion documentation (described below in the “Documentation of Completio n of the Program” section). Users have the ability to retake

exams. Partial credit will not be given for multiple choice questions. Whether partial credit for multiple choice answers is necessary and able to be implemented will be evaluated after one y ear of program implementation. Answers to exams taken on

- line will not be disclosed, as the grading will be done by computers. One taking the training may choose to view the correct answers for any questions they answered incorrectly, but they will not b e shown answers to any other questions not on the test

, but in the question bank.

The website that administers the training program will function according to the following criteria:

• The content of all training materials will be legible on standard si zed computer monitors to persons with normal vision

, and the sound will be audible on standard computers to persons of normal hearing abilities.

• The training program will track each individual user’s progress and successful completion of each module.

• The training program will function effectively on current versions of major

internet browsers

, including Internet Explorer, Chrome, Firefox, and Safari.

• A help desk will be available by telephone from 8:00 a.m. to 5:00 p.m. Eastern

Time

, Monday through Fr iday, except holidays

, to assist users who have questions or concerns regarding functionality. The help desk number will appearRegistrants’ Soil Fumi gant Aplicator Training Program Components Overview October 8, 2012

Page 4 of 8 on slides throughout the on

- line training program.

The registrants will ensure that reasonable efforts will be made to address as soon as possible other problems with program functionality that are caused by the program itself. The help desk will make all reasonable efforts to return calls promptly and by the following business day.

In

- Person Training Testing

Some registr ants will be providing in

- person presentations of the training program. The locations of these programs will be decided on an individual basis by the registrants once the training program is live on

- line. Each such program will be organized by an individ ual registrant and will be advertised according to their standard methods. The applicators who attend a presentation will be notified in advance which chemical specific modules will be offered. All of these programs will include the material in the on

- li ne version for the general fumigation modules and for as many of the active ingredient specific modules as are offered at that location. Due to time constraints, not all of the active ingredient specific modules will be offered at each

in

- person training presentation, and there generally will not be an opportunity to review a hard copy of another chemical specific module and take the exam at an in

- person training session. However, once an individual has successfully completed the training program for the general fumigation and at least one active ingredient specific module, the individual can take additional active ingredient specific training modules either on

- line or at another in

- person training session without repeating the successfully completed modul es. An applicator who wishes to take in

person training for a different chemical specific module will be able to do so depending upon the schedule and locations offered for such training by the individual registrant for that active ingredient. An individ ual does not need to have his or her own computer to take the training; the training will be accessible through computers located at libraries and other community locations available to the public.

In some on

- line training presentation instances, the r egistrants may play the on

- line module from a computer attached to a projector and sound system. Alternatively, the presenters may use the slides and deliver the script for the program, but the slides will be the same for all programs. There will be an o pportunity for those attending the in

- person program to take a written version of the module tests for the general fumigation and whatever active ingredient specific module or modules are covered in the in

- person training. Achieva will create three

versio ns of the test with the same random order as the computer so that it will not be possible to merely copy from a nearby person also taking the test. Each in

- person presentation will follow

the additional security procedures relating to the test taking ( su ch as providing one’s certified applicator license information )

, described in the written protocol that was provided to EPA on September 26, 2012

.Registrants’ Soil Fumi gant Aplicator Training Program Components Overview October 8, 2012

Page 5 of 8 Exams will be given at the end of each module. The exams will be limited to the modules offered at the spe cific in

- person training session. Additional modules can, as stated, be

taken on

- line.

The test questions and review questions will be as described for the on

- line training. The

tests used in the in

- person training will be generated by computer with ra ndom questions and order of questions. There will be at least three such randomly generated exams used for in

- person training for each module. Pens and/or pencils will be available for those taking the in

- person training; calculations or other notes can be written on the paper on which the test is printed. Calculators will not be provided, as the questions have been designed in a manner that does not require calculators. The focus of the training is on the need to check the product specific and applicatio n specific label provisions.

Labels may not be available for the initial in

- person training; as such, sessions will likely occur before the labels are in the field and effective. Whether sample labels will be available for future training sessions afte r they are available in the field will be considered during the evaluation process.

Participants will be permitted to ask non

- substantive questions, such as how much time is available. Proctors will be instructed that they cannot answer any substantive questions regarding the exam, and those taking the exam will be notified of the conditions at the beginning of the exam. While no substantive questions will be allowed during the exam, it is possible that questions may be asked during the classroom porti on of the presentation. The in

- person training will be led by representatives from the registrants who are familiar with the program and with the Phase 2 labels for the products and will answer questions.

Exams from in

- person training programs will be gr aded by the appointed registrant representatives who will have the exam answer keys. Registrant representatives with access to the exam keys will be limited, and there will be strict rules prohibiting dissemination to persons not employees of, contractors to, or attorneys for the individual registrant and who the registrants have not appointed to possess the answer keys. The registrants plan to provide, at the time of the training, information on the likely timeframe before exam results and documentation of completion will be available for those taking in

- person tests.

Certified applicators who are under age 18 may be permitted to take in

- person training programs if applicable state law permits them to do so.Registrants’ Soil Fumi gant Aplicator Training Program Components Overview October 8, 2012

Page 6 of 8 Documentation of the Completion of the Pro gram

Once a user has successfully completed the training program, received a passing score of 70% on all four general fumigation modules and at least one active ingredient specific fumigation module, the system will generate a training acknowledgement for m (Proof of Completion documentation) that will be emailed to the user. This P roof of C ompletion

document ation includes the following statement: “This document serves as proof of completion of the U.S. EPA required training for soil fumigant applicators. A copy may be attached to applicable FMPs to comply with the label requirement for documentation of completion.” The Proof of Completion documentation includes the name of the certified applicator, the certified applicator’s license number(s) and state( s) in which those licenses exist, and the Completion Date. The Completion Date is the date that the user first completes all of: (1) the general training modules (modules 1

- 4) and (2) one chemical

- specific module. The Proof of Completion

documentation w ill also list all of the modules the certified applicators has successfully completed following the Completion Date. The Completion Date will remain the same even if

additional chemical

- specific modules are taken at a later date. The applicator must reta ke and complete the general training modules plus one chemical

- specific module to obtain a new Completion Date.

A copy of the Proof of Completio n documentation is appended as Attachment 2. There are two pages. The 8 .5 x1 1 sheet can be attached to the F MP. The second page can be trimmed to a wallet sized card. In addition to this information, the user will be able to access the system and reprint this information when needed. For those who complete the on

- line training, the

Proof of Completion documen tation will be sent to users one business day following the Completion Date and again when an additional active ingredient module is completed.

The Proof of Completion d ocument ation also will be provided to those who take the test in person, but under a longer timeframe. At the time that they take the tests, in

- person training attendees will be asked to provide contact information, including an email and hard copy address. For those attendees that provide email information, Achieva will email the Proof of Completion d ocument ation to them once they are entered into the system. For those who do not have an email address, the Proof of Completion d ocument ation will have to be mailed via the United States Postal Service regular mail delivery. Because it wil l take time to grade the tests, provide the information to Achieva, enter it into the system, and then send the Proof of Completion d ocument ation to the applicator, there will be a time lag between taking the tests and receiving the Proof of Completion d oc ument ation for those that take the test in person.

At this time, the registrants anticipate that those who successfully take the in

- person training and testing will receive their Proof of Completion d ocument ation in approximately two

to four weeks after the training. Factors that will impact the exact time include the number of people who take the in

- person exam and the length of time needed to grade all exams from aRegistrants’ Soil Fumi gant Aplicator Training Program Components Overview October 8, 2012

Page 7 of 8 specific training session. Registrants will work to complete this process in an effici ent and timely manner. Achieva will incorporate the results of the testing into the database within three business days after the receipt of the spreadsheet from the registrant. Applicators who provided

a valid email address at the time of the in

- person testing will receive the results via email the next business day after incorporation of the results into the Achieva database. For applicators who did not provide a valid email address, the material will be printed and mailed via U.S. mail,

which will lik ely take another five to seven business days. The registrants estimate that it will take one to three weeks for the information to be entered into the tracking database.

The Proof of Completion d ocument ation is the primary method of documenting that an applicator has passed the exams. A n additional method of verification for regulators will be provided. At this time, a computer system is not feasible for this supplementary verification method. For the immediate future, regulators will be able to obta in confirmation from Achieva that an individual has passed the exam by contacting the Achieva help desk , which will be

available between 8:00 a.m. and 5:00 p.m. Eastern Time , Monday through Friday, except holidays. The information will be linked to the ap plicator’s name, state of certification, and state certified applicator number. The help desk will be staffed

, but m essages also can be left 24 hours per day, 7 days per week. The help desk will return calls no later than the next business day.

State an d tribal regulators have indicated that in some cases their inspectors or other enforcement personnel are certified applicators and can log in using the same procedures as other certified applicators. Some jurisdictions have informed the registrants that their enforcement personnel are not certified applicators. In those instances, registrants will provide an alternate code to be used in lieu of the certified applicator number, in response to a request from the jurisdiction

.

Program Evaluation and Rev ision Plan

Once the system is up and running, Achieva will keep track of information on the training. More specifically, Achieva will provide the registrants information on the number of people who take the on

- line training program, the number of people w ho complete the program,

and the number of people who pass . Achieva will also identify any exam questions which received an above average number of incorrect responses . Applicators who take the in

- person training will receive a paper survey at the end o f training, which will be collected on

- site. Applicators who take the on

- line training will be sent a short survey via email. All participants will receive an email address where they can send comments at any time.

Approximately two months after the l aunch date, the r egistrants will conduct a preliminary evaluation of the statistical information on use and operation of the training program,

as well as the comments received from users and regulators . This preliminary evaluation willRegistrants’ Soil Fumi gant Aplicator Training Program Components Overview October 8, 2012

Page 8 of 8 focus on identifyin g and correcting issues relating to content and functionality . A similar

evaluation will be conducted approximately six months after the launch date. A detailed

evaluation of the training program and system will be conducted approximately 12 months after

the launch date. Part of the 12

- month evaluation will be to determine the subsequent review

dates

, which will be discussed with and approved by EPA

.

I ssue s identified during the evaluations will be resolved prior to the next evaluation if

feasible. If an issue cannot be addressed in that time period due to the severity of the issue identified and the difficulty of a modification to the program, the registrants will notify EPA

, describing the issue and why modifications are not feasible.

The registran ts will also consider during the evaluation periods whether any changes are needed to the system developed for regulators to verify which applicators have completed the training

. If feedback from regulators using the system indicate s that the system does not effectively meet their needs, the registrants will modify the system accordingly, or will explain to EPA why such modifications are not feasible. The registrants will also consider during the 12

- month evaluation period the feasibility of enhancements to the program that would assist vision

and hearing

- impaired users.

The registrants will make reasonable efforts to correct errors and problems with program functionality during each evaluation . If significant err ors or problems are identified prior to the next scheduled evaluation, the registrants will make reasonable efforts to correct these errors in a timely manner rather than waiting for the next schedule d evaluation. If the errors or problems

cannot be corrected or will take extensive time to cor rect, th e n the registrant s will discuss with EPA options and time frames for addressing the issue as soon as reasonably poss ible. The registrants will make reasonable efforts to ensure that that program content is accurate on an ongoing basis as well as part of the periodic review process.

The registrants will obtain EPA approval before implementing any substantive changes or additions to the content or operation of the training program or to the Program Elements.I. General
Your use of the Soil Fumigant Applicator Training Center websit e (“Website”) means you accept and agree to the terms of use in this agreement (“Agreement”). If you do not, you should leave this Website immediately and not use any content from the Website. We reserve the right to amend this Agreement at any time, and your continued use of the Website following any amendment shall constitute your acceptance of the amendment(s).

II. U.S. EPA Approved Soil Fumigant Training Program
In accordance with the Phase 2 EPA approved labels for soil fumigant s containing Chloropicrin, Dazomet, Methyl Bromide, Metam S odium, Metam Potassium, 1,3- Dichloropropene plus Chloropicrin or Iodomethane to apply the pr oduct an applicator must (1) be a Certified Applicator in accor dance with your state’s program; and (2) complete an approved soil fumigant program listed on the U.S. EPA website. The online training program provided at the Webs ite (“Training Program”) is listed on the U.S. EPA website for soil fumigant training program. If you successfully complete this Training Program, you must still fol low and adhere to all other applicable federal and/or state requirements including, but not limited to, labeling requirements.

This Website is owned and operated by the Soil Fumigant Registrants consisting of Chloropicrin Manufacturers Task Force, Methyl Bromide Industry Panel, Metam Task Force, AMVAC and Dow AgroSciences (collectively “We” or “Us”). We are not a government agency, representative or entity.

III. Your Representations and Warranties
You represent and warrant each of the following: 1. You are at least 18 years of age and have the right to enter into this Agreement;

2. All information you provide to this Website is accurate and complete;

3. You will not knowingly allow another person to claim that he/she has been trained in applying soil fumigants based on your a ccess to this Training Program;

4. If you receive a Documentation of Completion for the Training Program, you are guaranteeing that you personally (i) complete d and reviewed the applicable modules of the Training Program, and (ii) answered and completed all tests at the end of each applicable module of the Training Program;

5. You will not use the content on this Website (“Content”) in any way that is not permitted by this Agreement;

6. Your use of the Content will not violate any applicable law or regulation of any country, state, or other governmental entit y; 7. Your use of the Content will not violate or infringe the rights of any person, firm or company (including, but not limited to, rights of intellectual property, rights of confidentiality or rights of privacy, etc.);

8. You do not reside in any country to which export of USA products are prohibited or restricted; and

9. In the event you have any right, claim or action against any user arising out of that user's use of the Website, you will pu rsue such right, claim or action independently of and without recourse to Us.

IV. Permitted Use of the Website
1. You may access and use the Website only in strict accordance with this Agreement, and for the sole purpose of obtaining for your individual use training, including documentation of such training, in the use and application of so il fumigants containing Chloropicrin, Dazomet, Metam Sodium, Me tam Potassium, 1, 3- Dichloropropene plus Chloropicrin, Methyl Bromide and/or Iodomet hane. Solely in connection with the foregoing, you may print ou t discrete information from the Website exclusively for your own individual and non-commercial use.

2. The content, organization, graphics, design, compilation, magnetic translation, digital conversion and other matters related to the Website are protected under applicable copyrights, trademarks and other proprietary (including , but not limited to, intellectual property) rights. The copy ing, redistribution, use or publication by you of any such matters or any part of the Website, except as expressly authorized in this Agreement, is strictly prohibited.

3. You acknowledge and agree that all copyright, trademarks and all other intellectual property rights in all material or conte nt supplied as part of the Website shall remain at all times vested in Us and/or third parties, and that you do not acquire ownership rights in the foregoing through th e use of or other involvement with the
Website.

V. Your User Information
In using the Website you agree to the following: 1. When you register with the Website or utilize the Training Program, you accept and agree that We may collect, use and store the following information from you (collectively, “User Information”): “Contact Information” (name, address, telephone number, email address, company name, title/ position, certified applicator license number); “Account Access Information” (user name and password); and “Training Information” (modules completed, test scores, cer tificate status). We may use and share your User Information as follows: • We may use your User Information to provide you with access to and use of the Training Program, to determine your eligibility for documentation of successful completion of the Training Program, to verify your identity when appropriate, and update your User Information; • In response to a request from the U.S. EPA or any other Federal , State or Tribal regulatory or governmental authority or repr esentative, We may provide these entities with your Contact Information and/or Training Information. It is possible that the foregoing entities may, in turn, re lease to others and/or make publically available your Contact Information and/or Training Information in accordance with that entity’s policies. We are not liable or responsible for how these entities may use your Contact Information and/or Training Information. • We may provide, or grant access to, your User Information to our ou tside contractor(s), as may be reasonably necessary to maintain, operate, collect and store information regarding the Website, registrants of the Website, and registrants’ use of the Website and the Training Program; • Your User Information may be used and accessed by Us and our designated or authorized representatives for the purpose of eval uating, establishing, verifying, and maintaining quality control of the Website and Training Program. • In our sole discretion, we may provide or grant access to your User Information as well as disclose details of your use of th e Website, in relation to any, or any threatened, court or legal proceedings or subpoena in connection with this Website including, but not limited to, use of the We bsite by you, anyone under your direction or control, or anyone using any of your Contact Information, whether in connection with the matters set out in this A greement or otherwise.

2. We may keep your User Information for (i) a minimum of three (3) years from the date that you successfully complete the mini mum requirement of the four general fumigation modules and at least one of the active ingredient specif ic modules or (ii) a minimum of one (1) year from the date y ou register with the Website without successfully completing at least four general and one active ingredient specific module.

3. Your User Information will not be used to promote or market any type of product or service to you and/or your company. Howev er, the Contact Information from groups of Website users may be pooled together, and stripped of information that would identify any particular individual, for purposes of analyzing Website users to improve the Website, expand use of the Website, assess interest levels on different aspects, portions, modules of the Website a nd/or the Training Program, and develop research for marketing of soil fumigant products. Pa g e 1 of 2 Fumi g ant Trainin g

9/28/2012 htt p ://fumi g anttrainin g .com/terms. p h p4. We take reasonable measures to maintain the integrity and security of your User Information as provided by and collected fro m you through the Website. However, as you are aware, transmission of information via the world-wide web and electronic storage of information may not always be sa fe and secure due to, for example, the unauthorized and/or illegal activities of others. As a result, you acknowledge that We cannot guarantee, and therefore shal l not be responsible for, the security or privacy of the Website or your User Information.

VI. Right to Monitor and Terminate
1. We have the right, but not the obligation, to monitor activity and content associated with the Website. We may investigate a ny reported violation of this Agreement or complaints and take any action that we deem appropriate (which may include, but is not limited to issuing warnings, suspendi ng, terminating or attaching conditions to your access and/or removing any materials from the Website).

2. We reserve the right to terminate this Agreement, your account on and/or your access to the Website immediately if in our di scretion we believe that you may be violating the Agreement or jeopardizing the integrity of the Website and/or the Training Program, or you or someone else may be abusing your username, password and/or certified applicator license number. If your account or this Agreement as to you is terminated for any reason, you lose the ability to access this Website and must delete and destroy immediately all content and materials acquired from this Website and all copies thereof.

VII. Indemnity
You agree to be fully responsible for (and fully indemnify Us against) all claims, liability, damages, losses, costs and expens es, including legal fees and government fines and penalties, suffered by us and arising out of any breach of the Agreement by you, any other acts or omissions and any liabilities arising in connections your use of the Website, or the use by any other person accessing the Website using your PC, internet access account, or certified a pplicator license number.

VIII. Disclaimer of Warranties

YOU EXPRESSLY AGREE TO ASSUME TOTAL RESPONSIBILITY AND RISK FOR YOUR USE OF THE WEBSITE. WE MAKE NO EXPRESS OR IMPLIED WARRANTIES, REPRESENTATIONS OR ENDORSEMENTS WHATSOEVER IN REGARDS TO THE WEBSITE. WE EXPRESSLY DISCLAIM ALL WARRANTIES OF ANY KIND, EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, INCLUD ING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, ACCURACY, CORERECTNESS, RELIABILITY, AND NONINFRINGEMENT WITH REGARD TO THE WEBSITE, AND ANY CONTENT CONTAINED THEREIN (INCLUDING THIRD PARTY INFORMATION). WE SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE ARISING EITHER DIRECTLY OR INDIRECTLY FROM ANY USE OF THE WEBSITE, THE SERVICES OR ANY CONTENT CONTAINED THEREIN (INCLUDING THIRD PARTY INFORMATION). IT IS SOLELY YOUR RESPONSIBILITY TO EVALUATE THE ACCURACY, COMPLETENESS, AND USEFULNESS
OF ALL CONTENT PROVIDED BY THE WEBSITE. WE DO NOT WARRANT THAT THE FUNCTIONS PERFORMED BY THIS WEBSITE OR THE SERVICES WILL BE UNINTERRUPTED, TIMELY, SECURE, ERROR-FREE, OMMISSION-FREE OR VIRUS-FREE OR THAT ANY SUCH DEFECTS IN THIS WEBSITE OR
THE SERVICES WILL BE CORRECTED. WE DO NOT WARRANT THE ACCURACY OF COMPLETENESS OF THE CONTENT PROVIDED BY THIS WEBSITE OR THE SERVICES, OR THAT ANY ERRORS IN THE CONTENT WILL BE CORRECTED. THIS WEBSITE AND RELATED SERVICES, AND THE INFORMATION AND CONTENT PROVIDED THEREON ARE PROVIDED ON AN "AS IS", AND "AS AVAILABLE" BASIS.

IX. Limitation of Liability
IF YOU ARE DISSATISFIED WITH THE WEBSITE, OR ANY OF THE CONTENT ON THE WEBSITE, OR WITH THE TERMS OF USE, YOUR SOLE AND
EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE WEBSITE. YOU UNDERSTAND AND AGREE THAT UNDER NO CIRCUMSTANCES WILL WE OR ANY OF OUR AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS REPRESENTATIVES, LICENSORS, SUPPLIERS, OR DISTRIBUTORS BE LIABLE FOR ANY DAMAGES WHATSOEVER, INCLUDING, BUT NOT LIMITED TO, (I) ANY DIRECT, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY OR INDIRECT DAMAGES SUCH AS BUT NOT LIMITED TO, DAMAGES OF LOSS OF BUSINE SS PROFITS, BUSINESS INTERRUPTION, LOSS OF DATA, PROGRAMS OR INFORMATION ARISING OUT OF THE USE OF, OR INABILITY TO USE, THE WEBSITE, OR THE INFORMATION OR CONTENT PROVIDED THEREIN, (II) A NY CLAIM ATTRIBUTABLE TO ERRORS, OMISSIONS, OR OTHER INACCURACIES IN THE WEBSITE, OR THE CONTENT CONTAINED THEREIN DOWNLOADED THROUGH THIS WEB SITE (III) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANMISSIONS OR DATA, (IV) STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE WEBSITE, OR (V) ANY OTHER MATTER RELATING TO THE WEBSITE, EVEN IF WE HAVE BEEN ADVISED OF THE
POSSIBILITY OF SUCH DAMAGES. SINCE SOME STATES DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU. IN SUCH STATES, OUR LIABILITY IS LIMITED AND WARRANTIES
ARE EXCLUDED TO THE GREATEST EXTENT PERMITTED BY LAW.

X. Other Legal Information
This Agreement shall be governed by and construed in accordance with the laws of the District of Columbia. This Agreement conta ins the entire understanding of the parties hereto relating to the use of this Website. This Agreement supersedes any prior written or oral agreement or understand ing with respect to this Website and can only be changed in writing signed by an officer of each member of the Soil Fumigant Registrants. The invalidity or unenforc eability of any provision of this Agreement will not affect the validity or enforceability of any other provision herein.

XI. Accessing Your User Information; Our Contact Information
1. You can access your User Information that we collect from you through the Website by sending us a request in writing to the address below. You also can update and correct factual errors in your Contact Information by sending us a request in writing that credibly shows error.

2. General contact information In you have any questions about the terms of use of this Agreement, the practices of the Website, or your dealings with the Web site, you may contact us by sending
a letter via U.S. mail or email to: Achieva, Inc. 416 West Main Street, Carmel, IN 46032

EMAIL HERE

XII. Third Party Links
We may provide links to third-party sites as a convenience to y ou. We do not control third party sites or links to third party sites. We are not responsible for the content of any linked sites. Links to third-party sites are not endorsements by Us of such sites.

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9/28/2012 htt p ://fumi g anttrainin g .com/terms. p h p

# S O I L F U M I G A N T A P P L I C A T O R T R A I N I N G



# P r o o f o f C o m p l e t i o n

P r e s e n t e d t o

O n t h i s d a y



## F o r s u c c e s s f u l l y c o m p l e t i n g t h e S o i l F u m i g a n t A p p l i c a t o r T r a i n i n g

* * * T h e C e r t i f i e d A p p l i c a t o r n u m b e r s a r e t h o s e e n t e r e d o n t h e

r e g i s t r a t i o n p a g e b y t h e p e r s o n c o m p l e t i n g t h e t r a i n i n g

p r o g r a m a n d a r e t h e s o l e r e s p o n s i b i l i t y o f t h a t p e r s o n

. * * * T h i s d o c u m e n t s e r v e s a s p r o o f o f c o m p l e t i o n o f t h e U

. S

. E P A r e q u i r e d t r a i n i n g f o r s o i l f u m i g a n t a p p l i c a t o r s

. A c o p y o f t h e d o c u m e n t m a y b e a t t a c h e d t o t h e a p p l i c a b l e F M P s t o c o m p l y w i t h t h e l a b e l r e q u i r e m e n t f o r d o c u m e n t a t i o n o f c o m p l e t i o n

. C o m p l e t i o n R e f e r e n c e N u m b e r 

# Barbara Christianson

MD 12345 VA 678910

On this day 

# September 10, 2012

4 General Training Program

4 Metam Training Program 4 Dazomet Training Program



## 100001T h i s d o c u m e n t s e r v e s a s p r o o f o f c o m p l e t i o n o f t h e U . S . E P A r e q u i r e d t r a i n i n g f o r s o i l f u m i g a n t a p p l i c a t o r s . A c o p y o f t h e d o c u m e n t m a y b e a t t a c h e d t o t h e a p p l i c a b l e F M P s t o c o m p l y w i t h t h e l a b e l r e q u i r e m e n t f o r d o c u m e n t a t i o n o f c o m p l e t i o n . * * * T h e C e r t i f i e d A p p l i c a t o r n u m b e r s a r e t h o s e e n t e r e d o n t h e r e g i s t r a t i o n p a g e b y t h e p e r s o n c o m p l e t i n g t h e t r a i n i n g p r o g r a m a n d a r e t h e s o l e r e s p o n s i b i l i t y o f t h a t p e r s o n . * * * 

# S t e p 1

C u t a l o n g t h e d o t t e d l i n e t o c u t o u t y o u r P r o o f o f C o m p l e t i o n

.



# S t e p 2

F o l d t h e c u t o u t i n h a l f a l o n g t h e t h i n b l a c k l i n e

.

Barbara Christianson

MD 12345 VA 678910 On this day September 10, 2012

4 General Training Program

4 Metam Training Program 4 Dazomet Training Program

100001To : Nicole Zinn/DC/USEPA/US@EPA,

Cc: Cathryn Britton/DC/USEPA/US@EPA,

Bcc: Subject: Fw: Soil Fumigant Applicator Training Program -- Program Elements

From: John Leahy/DC/USEPA/US - Monday 10/08/2012 09:21 PM

From: "Lisa M. Campbell" <LCAMPBELL@lawbc.com>

To: Richard Keigwin/DC/USEPA/US@EPA, John Leahy/DC/USEPA/US@EPA
Cc: "Sara Beth Watson, Esquire" <swatson@steptoe.com>, "Roger H. Miksad, Esquire" <rmiksad@wileyrein.com>, "David E. Barnekow " <debarnekow@dow.com>

Date: 10/08/2012 07:51 PM Subject: Soil Fumigant Applicator Training Program -- Program Elements

Rick and John –

Appended is the revised program elements document and the attachments referenced in the document. Please let us know if you have any questions.

LISA M. CAMPBELL B E R G E S O N & C A M P B E L L P C 2200 Pennsylvania Avenue, N.W. Suite 100W | Washington, D.C. 20037

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