# REPORT OF

# THE
- EPA/SFIREG · 

# CERTIFICATION

··. AND TRAINING



# -

TASKFORCE

**-----~-------------** 

# AUGUST30,1985

• 

### •!XBCUTIVE SU&I4ARY The pesticide applicator training and certification programs have made a si1ni!icant contribution to the safe use of potentially hazardous pesticides. Because o! this contribution, John A. Moore, Assistant Administrator !or Pesticides and Toxic Substances, EPA, formed a task force to review the existing programs to determine what, if any, actions should**b~** taken to further improve the programs_and to expand their scope of coverage. This Task Force was composed o! representatives o! EPA, USDA, StateCooperative Extension Services, and State Lead Agencies. Based on its review o! the current programs, the Task

.Force reached the following conclusions: 1) The pesticide applicator training and certification programs have resulted in improved human health and

·environmental protection and have permitted the continued

use of a variety of beneficial pesticides. 2) EPA should use, whenever·possible, restricted use classification and the ability ofState Lead Agencies and StateCooperative Extension Services to provide initial

---·· J··a· · nd continuing certification and training of pesticide applicators in developing regulatory solutions to

- ·----poTential pesticide problems. 3) EPA should re-articulate the three ways application may be performed to ensure..safe and proper use of restricted use pesticides. These levels are a) use under the direct supervision of a certified applicator, b) use in the physical presence of a certified applicator or c) use only by a certified**appli~ator.** EPA should develop

·and use decision criteria for determining what pesticide

uses require specified levels of supervision or training. 4) EPA should require states to establish dealer licensing programs. 5) Current training and certification materials should be evaluated; national core training materials and national category specific training manuals should be established or updated; and additional**education~!** materials need to be developed, and
.present ones updated, to address a number of key areas (chronic health effects, groundwater contamin4tion, endangered species, pesticide**disp~sal** and calibration techniques). 6) EPA and USDA should establish a central point for the collection and distribution of educational, training and regulatory materials.

•

### 7) EPA. USDA. State Cooperative Extension

**Servi~es,** 

### and State Lead Agencies should meet

**periodi~ally** 

### to review exiatlni programs and to

**dis~uss** 

### new training and regulatory

**approa~hes.** 

### 8) All state

**~ertificatlon** 

### and training plans should be reviewed by EPA and. to the extent

**ne~essary,** 

### updated. 9) The certification and training programs

**sh~uld** 

### be elevated to a

**hiih~r** 

### priority within EPA. 10) Better mechanisms for communicating federal regulatory

**de~isions** 

### which may

**impa~t pesti~ide**  

### appllcatoi certification and training programs are necessary to ensure adequate lead time for states to Implement needed programs and for

**appli~ators** 

### to

**be~Dme ~erti!ied.**  

### 11) Minimum competency standards should be developed for trainers and non-certified applicators working under the direct supervision of a certified applicator. 12) Private applicator competency standards should be amended to ensure uniformity with

**commer~ial** 

### applicator core standards; PIFRA 

### should be amended to give EPA the discretion to require examining of private applicators to determine competency.
_ 13) State plans should be reviewed and amended, as necessary. t

### o provide !or peri

### o d1

### c_r

### enewa1 

### o! cer t i!ication: continuing education should be a key element in this renewal

**pro~ess.** 

### 14) FIFRA 

### should be amended tomake it unlawful !or anyone to recommend the use of a pesticide inconsistent with its labe1 

### or labe1i

### ng except as PIFRA 

### otherwi"se provides•

•

### IMTBODUCTION
On May 8, 1985, Dr. John A. Moore, Assistant Administrator for Pesticides and Toxic Substances, EPA, appointed the following individuals as a special Task Force to review the current system 

### ot pesticide applicator training and certification and to make recommendations for any needed changes and improvements. L.O. Nelson

- Office 

### ol the Indiana State

**Chemi~t** James H. Davis- Office 

### ot·Pesticides and Toxic Substances, EPA 0. Norman Nesheim- Oklahoma State University John Osmun- Purdue,University JimWells- California Department of Food and Agriculture Ron Conley -Georgia Department of Agriculture Art G. Losey -Washington Department of Agriculture Ken Kadlec

- Texas Department of Agriculture James Parochetti

- U.S. Department of Agriculture Charles Smith

- U.S. Department of Agriculture FredWoods -U.S. Department ofAgriculture Dave Combs

- EPA Region 8 Harold Kazmaier

- EPA Region 1 Anne Lindsay -Office of Pesticide Programs, EPA John Seitz -Office of ComplianceMonitoring, EPA Amore complete listing is attached to this report (At-tachment '1)• Four meetings of theTask Forcewere held, the first occurring on May 22, 1985 and the last occurring on August 20, 1985. Most of the meetings were public. Members of the pesticide producing industry, pesticide user associations, and others attended and provided comment. In addition, five subgroups were established and held meetings to address specific issues as f011ows: 

### I. Overview and accomplishments II. **Restricted~se** classification and direct supervision III. Content-of·certification and training materials IV. State plans, enforcement and measurement of competency V. Continuing competency and maintenance of applicator certification Asixth group was established to review and update the two documents: 1) Guidance
.for Developing Programs of Continuing Certification for Pesticide Applicators and 2) Maintenance of Applicator Certification. The suggested changes were reviewed and approved by the Task

**For~e.** In addition, concurrence is being sought from the Association of American PesticideControl o·

fticials (AAPCO), Extension Cormlittee on Policy (ECOP), U.S. Department of Agriculture (USDA), Environmental

**Prote~tion** Agency (EPA), and representative industry groups.

•

### After examining the Issues specified in I. through

## v. and considering public comment on them, theTask Force has prepared the following report. This report recognizes the major accomplishments of the

**curr~nt** 

### pesticide applicator training and certification programs in limiting the risk of adverse human ,nd environmental effects !rom the use o! restricted use pesticides. It alsomakes recommendations for the improvement of these programs, based on 1) the experience of nearly a decade in running these programs, 2) changes in application

**t~chnology**

**,** 

### and 3) the additional types of·risk for which the Environmental Protection

**Ag~ncy** 

### is considering restricted use classification. The Task Force encourages EPA to use, whenever possible, restricted use classification and the ability of State Lead Agencies and StateCooperative Extension Services to provide initial and continuing certification and training of pesticide applicators in developing regulatory solutions to potential

**pesti~ ide** 

### _ problems.

... '-;

• · ..--:-. -··TASK POBCE REPORT I. OVERVIEWAND ACXXNPLISBM!MTS Amendments to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in 1972 gave EPA the authority to restrict uses of pesticides, whose potential hazards may pose unreasonable adverse effects unless used by, or under the direct supervision of, a certified applicator•. These amendments gave the primary responsibility

.tor developing and maintaining applicator certification programs to the individual states. EPA was to establish standards for the certification programs, and USDA and EPA were to develop training materials for the education o! pesticide users in the certification programs. EPA issued regulations governing standards for

**ce~tlfication** in October 1974 and regulations governing state plans inMarch 1975. The requirements and provisions were largely implemented by 1976. USDA, through the State

**Cooperativ~** Extension Services (SCES's), provided leadership in the development of the PesticideApplicator Training (PAT) program. The individual states, through State Lead Agencies (SLA's), usually State Departments of Agriculture, developed and put into place state pesticide applicator certification programs. Currently all but two states have developed and are operating certification programs. In those two states EPA operates federal certification programs so that applicators there have the opportunity to become eligible to use restricted use pesticides. Since 1976, this

**cooperati~** Federal-State effort has led to 

### i number of accomplishments that have both improved human health and environmental protection and also permitted the continued use of a variety of beneficial pesticides. Accomplishments of the PesticideApplicator Certification and 

### TralalagProgram. A. Over 2million private and commercial pesticide

**applic~tors** have been trained to become certified to use 

### re stricte d use pest lcides, res u 1 t i ng in abou t 1•2m i 1 1 i o n people being certified by State Lead Agencies. B. The program has created a heightened awareness among farmers, extension personnel. state governments responsible for enforcement of pesticides, commercial

**pesticid~** applicators. and the public of the

**prin~iples** and importance o! safe pesticide use.

**pesticid**

**~** · regulations, and environmental concerns, including the potential hazards associated with the use or misuse o!

**pesticides**

**~**

•

## c. The training and certification programs provide a mrn1mum standard of competence for all persons who use restricted use pesticides and require these individuals to keep abreast of changing technology to maintain their certification•

. D. Pesticide registration has continued for some pesticides which might otherwise have been cancelled by EPA if the option of restricted use classification had not been available. · 

### B. The programs have made users aware of the importance of the pesticide label as the guide to proper use or the pesticide and as a legal and enforceable document. P. The StateCooperative Extension Services have·greatly

**in~reased** their efforts in pesticide education. 

### G. The programhas resulted in the development and use or a number or educational materials on pesticide application based on "core" instructional publications. These materials are easily adapted to meet specific pesticide user training needs. · 

### B. The program has highlighted problem areas where greater pesticide safety educational efforts needed to be made. I. One program effort targeted for commercial applicators has been to increase pesticide deposition in the target area thereby reducing pesticiae drift by both ground and aerial application. As an example, a national educational program was conceived, developed and implemented as a self-regulatory and voluntary program to improve pesticide application by agricultural aircraft. This educational effort involves the public (U.S. Department of Agriculture, Environmental Protection Agency, State Cooperative Extension·services and State Land Grant Universities) and the private sectors (aerial

**applicator~.** agricultural chemical companies, and the National Agricultural

**Avia~ion** Association). Through their joint efforts, a national program to improve Berial application accuracy has resulted in: improved accuracy of pesticide application by aircraft; improved pesticide applicator knowledge; improved pesticide safety; minimization of
.environmental hazards; and

**minimization ~**  of pesticide enforcement ac)ivities. In the thre6 years since this program began,

**15~** of total agricultural aircraft applying
.pesticides have been calibrated at least twice by

**t~is** program through participation in this program.

### J. For the commercial applicator, the certification process has both improved the competency of the applicator and resulted in the elimination of the less competent individuals !rom the industry. K. As a result of the Pesticide Applicator Training Program, people who had not previously used the State Cooperative Extension Services are now using them as a source of lnformati

_ Qn tor other agricultural problems
_as well. L. An EPA funded evaluationwas concluded in 1979 on the North Carolina Pesticide Applicator Training Program by the Educational Testing Service, Princeton, New Jersey. This comprehensive evaluation showed many positive results that are typical of most states. According to the study, training was most successful in encouraging participants to refer to labels for information on pesticide use, to mix and load the chemicals in a place chosen to reduce the chance of an accident, and to properly dispose of empty containers. However, participants did not always follow all the important points presented in trainine. The assessment concluded that the training program increased participants' level of pesticide knowledge and use. Also, the

**s.tud~ ln**  **l.u ded**  a follow-up test that showed knowledge

**last~d** over an 11- month period. Before they start
- ed-t

- r-8-i.n-ing
__.s.tud.y

_____ _ participants said they thought the program would be

·beneficial, but after they completed the training their

attitudes toward the

**pro~ram** were even more favorable
.

**~.** An extensive EPA funded evaluation was concluded in 1981 on the private applicator pesticide training and certification program in five states. The evaluation was done by Abt Associates, Cambridge, MA. The executive summary of the Abt study states "· •• the eeneral observations of all these studies tend to support the contention that the private pesticide applicator training programs have had a substantial positive impact

**o~** the·

**grow~s'** awareness about the personal and environmental s a f e t y i s s u e s r e1· ated·to t he use and h a n d 1ing oC pesticides." Some specific highlights from the report

**includ~:** 1) Over

**80~** of all respondents indicated that they found the state private pesticide applicator training to be "very worthwhile" or "somewhat worthwhile," with nearly halt indicating "very worthwhile
."

•2) Over two-thirds of the respondents indicated that a major advantage of the private pesticide applicator training and certification programs was that lt taught proper use, how to prevent misuse, and limits restricted pesticide use to qualified users only, and half of the respondents could site no specific disadvantage of the program. 3)
.About three-fo
. urths of the growers surveyed perceived at least one of their behavioral practices to be affected by training. 

### M. The State Lead Agencies responsible for certification and enforcement of pesticide regulations, industry groups, trade associations, and educational groups such as vocational agriculture have stepped up their educational efforts in pesticide safety. This is done to complement and supplement the StateCooperative Extension Services' efforts. 0. The program has resulted in an improvement of state regulatory programs and enhanced the cooperation and coordination between the StateCooperative Extension · Services, the State Lead Agencies responsible for enforcing FIPRA, and EPA. ' P. Educational groups,

**sue~**as community

**eolleg~s,** have developed curricula in support of Pestieide·Applicator Training Programs, using StateCooperative Extension Service materials
. 

### Q
. Many trade and industry groups which have conducted educational meetings are using their meeting formats to qualify for approved credits !or maintenance of certification in the Pesticide Applicator Certification and Training Programs. 

### II. RESTRICTED USECLASSIPICATIONAND DIRECT SUPERVISION

· More attention is now being given to the FIFRA provision for restricting uses of certain pesticides. This is occurring because 1) PIFRA mandates
. that restricting uses must be considered by EPA before deciding on the necessity of cancellation and 2) EPA recognizes the merit of restricted use classification as a way to minimize such hazards as chronic effects, ground water contamination and threats to endangered species.I I Thus it becomes important that restricted use pesticides be plaeed only in the hands o! competent persons who are knowledgeable

**~nd** skilled in their proper use. There are a number of ways to aeeompllsh this as speelfleally provided in current regulations for applicator eertlfieatlon (40 CFR 171.3, 171.4(e), 171.4(d) and 171.6). A. As specified in 40 CFR 171.6, there are three ways that the use of a restricted use pesticidemay be performed: 1) Only by a eertl!led applicator. 2) By a competent, non-certified applicator working in the aetual presence of a eerti!ied applicator. 3) Under the direet

**super~ision** of a certified applicator who has provided verifiable instruction to and is in control of the competent, non-certified person. Many certified applicators (principally eommereial applicators) rely on this provision. Present EPA poliey is well articulated in FIFRA Compliance Program Pulley No. 2.3. (Attachment 12) "Direet supervision" has been interpreted quite broadly and the actual'degree of supervision exercised by a certified applicator may range from very elose, "line of sight" supervision to the provision of guidance and being available in the event 

### ol need by the non-certified applicator. Existing

**regula~ions** (40CFR 171.6) specify that the availability of the certified applicator to the persons workini under his/her supervision be directly related to the hazard o! the situation. The decision as to the level of supervision needed for a given restricted use pestleide has ienerally been left to the judgment or the certl!ied applicator. B. EPA should require states to implement regulations specifying direet supervision to be the same as or equivalent to FIFRA Compliance ProgramPolicy No. 2
.3
. (Attachment 12) 

## c. EPA should develop decision criteria !or determining what level of training and/or supervision is necessary to ensure safe use of a restricted use pesticide. These criteria should:be developed through a process that allows for public participation and should take into account the type and degree of hazard posed by a pesticide and the particular knowledge, technical expertise, and experience needed to ensure safe and proper use. •D. Usini the decision criteria, EPA should review existing restricted use pesticides. B. Based on the established decision criteria, EPA should use 40 CPR 171.4(d) of the existini regulations to establish special standards, including specified levels of trainini or supervision, for use of certain pesticides or for certain use and applicationmethods which require more strin1ent attention. Examples miiht be Compound 1080, certain fumigants, or aerial application. In these three examples, only the certified applicator might be permitted tomake the

**app~ieation.** F. PIFRA requires a pesticide applicator working under the direct supervision of a certified applicator to be a competent person (See. 2(e)(4)). Inmany situations, pesticide application is an art, e.1•• termitlcide

·· application. In such eases, the application
..ls best done by a person who has had specific trainini'"Tn how to ·:...... handle such pesticide specific situations. In many types of application this does not require that this be a. certified person so lon1 as the latter is In control. When making decisions regarding the registration or regulation of pesticide uses, EPA should consider that there are ranges of pesticide applications that are best handled by specifically trained, competent persons who work under the direct supervision of a certified applicator. For commerci&l applicators, such persons could be identified as registered technicians, for example. It ls important that they not be thought of or identified as certified under the broader, more sophisticated provisions of FIFRA See. 4(a)(1) and 40 CFR 171.3. G
. For commercial applicators, the supervisory certified applicator should ensure that training is provided to all persons working under his/her supervision in the safe and

**prope~ ~se**  of pesticides
. This training should be desi1ned to ensure comprehension of current label use direclions and precautions. Applicators should maintain verifiable records of the training provided (an expansion of 40 CFR 171
.6)
. B.· For private applicators. the supervisory certified applicator

**~hould** enBure that appropriate training·

**~nd** current label use directions and precautions are provided to all persons working under his/her supervision and shouldmaintain verifiable records of the training provided (an expansion

## o! 40 CFR 171.6).



## ..1. EPA ahould require states to establish dealer licensing pro1rams. These pro1rams should, as a minimum,: 1) Identity those dealers who sell

**restrl~ted** use

**produ~ts.** 2) Require the dealers to keep

**re~ords** of

**ea~h transa~tion**  involving restricted use

**produ~ts** Indicating the use pattern tor

**whi~h** it was

**pur~hased** and quantities sold. 3) Require that there be

**re~orded** the eertifieation number of the applieator purehasing or intending to use eaeh restrieted use produet. 4) Provide for appropriate enforeement
=·· -- •• penal

. t
-

ies-.

-.-· ....: This requirement would be

**mu~h** like the existing one for federal eer.tlfieation programs deseribed in 40 CFR 171.11(1).

**~.** EPA should require the states to

**enfor~e** more vigorously a1ainst the sale of

**restri~ted** use

**pesti~ides** to

**appli~ators** whose

**~ertifi~ation ~ategory**  is not appropriate for the labeled use of the pesticide. Where appropriate, EPA should

**spe~ify** on the label the

**parti~ular** limitationr-of use, e.r. tor retail sale to and use by

**appli~ators ~ertified**  tor use of aquatic

**herbi~ides.** 111
. CONTENT OP CERTIPJCATJON AND TRAININGMATERIALS It Is Important that

**~ertifled appll~ators**  have the necessary training and demonstrate the required

**~ompetency** to use restricted use pesticides safely and in

**a~~ordan~e** with label directions. Furthermore, previously certified applicators must receive periodic

**edu~ation** or training to maintain their

**~ompetency** levels and to keep abreast of new developments in pesticide usage. Since the initial development of state training materials, pesticide application techniques and technology have

**~hanged,** and public awareness of new

**pesti~ide** related concerns has increased. EPA is increasingly relying on restricted use classification to decrease hazards, other th

- an scute hazards, such as chronic effects, groundwater

**~ontamination** and threats to endangered

**spe~ies.**

**Te~hnologi~al ~hanges,**  new

**~oncerns** and new regulatory approaches are not adequately:reflected in many state

**certifi~ation** and training programs. Furthermore, no mechanism exists tor ensuring that state programs are currently and routinely provided access to newly generated technical information or to information on new regulatory approaches related to pesticides.

C)A. The Pesticide Applicator Training Program 

### tor both private and commercial applicators must, by regulation, include: (1) Label and Label Comprehension (2) Safety and Health ( 3 ) Env i r onment (4) Pests (5) Pesticides (8.) Equ lpment (7) ApplicationTechniques and Technology (8) Laws and Regulations In addition, such topics as the following should also be included: (1) Liability/insurance Information (2) Professional responsibility of applicator to use pesticide products properly in order to protect such products for future use (3) Dealingwith public concerns relating to the use of pesticides B. State Lead Agencies and StateCoopeerative Extension Services, in cooperation with their respective EPA Regional Offices, should evaluate current training and certification materials immediately, and on a regular basis thereafter, to determine if they are sufficient and up-to-date.

1) ln addition to their ongoing liaison each State Lead Agency and State Extension Service should meet at least once a year prior to the beginning of the educational cycle to formally review the pesticide training and certification programs to determine areas where education could strengthen pesticide certification plans. Examples of such areas include: (a) the types and number of violations and misuses of pesticides that could be minimized with adaitional education and (b) the development o! educational programs in anticipation o! restricted use classifications that would impact on new clientele. 2) Many o! the educational materials used in current

**pest !~**  **ide** applicator training are based on . publications initially developed 

### tor the Pesticide Applicator Training program in the mid-1970's by EPA and USDA.-. These publications, for the most part, have not been revised except for the original EPA/USDA core

**man~al** which was revised by North Carolina State University and is used by approximately 50 percent of the states. The 13 northeastern states use their own category specific publications as do most o! the remaining

**st~tes**• •The ECOP Task Force on Pesticide Education recently estimated, based on a survey 

### ot states, that about halt the states could use assistance in revising current materials. Such revisions would provide needed uniformity and identity for the pesticide applicator training program and essential assistance to many of the smaller states. 3) EPA, USDA, StateCooperative Extension Services and State Lead Ag
. encies, in cooperation wi"th industry and trade association groups, should establish or update national core trainingmanuals and national category specific training materials to be used either as a beginning point for updating state specific programs or as an Integral part of the state programs. 4) EPA, USDA, State Lead Agencies and StateCooperative Extension Services should establish mechanisms to ensure that information on new developments in pesticide use and application is conveyed on a regular basis to previously certified applicators between certification cycles. C. There is an urgerit need tor additional educational materials in a number 

### ot areas Including chronic health effects, potential for groundwater contamination, potential for impact on endangered species, pesticide ·-· disposal, and'calibration techniques. Specific suggestions for updating are given below,

**howe~er,** this list should not be considered all-inclusive. 1) With respect to chronic health effects, current training and test·ing materials should be updated to address the following specific issues: (a) Types of chronic effects: (1) Oncogenicity or Carcinogenicity, (2) Teratogenicity, (3) Reproductive Effects. (b) The use of animal tests and epidemiological studies to predict possible health e!!ects. (c) The·concept that risk is a !unction of both
. toxicity and exposure. (d)

**Metho~s** to reduce possible exposure, including specifically the importance o! proper use of protective clothing.

• •

### -----·- 2) With respect to groundwater contamination, current training and certification materials should be updated to address the following specific issues: (a) Nature of groundwater: (1) Aquifer definition, (2) Groundwater vulnerability, (3) Uses of groundwater. (b) Movement of pesticides through and over soil: (1) General process of leaching, (2) Characteristics of pesticides likely to leach, (3) Soil characteristics that affect leaching, (e.g., soil type and permeability, soil moisture, soil temperature), (4) Effect of climatic conditions (e.g., rainfall), (5) Effect of agricultural practices (e.g., irrigation, crop cover/tillage, slope).

**--· (cr)**  **·- ~xplanation**  of label restrictions.

**--- ---t**  **~~pes** of groundwater monitoring and availability 

### ot

**feder~l,** state, local and private testing .laboratories.



# - (e) Possible remedial action if groundwater is found to be contaminated. (f) Legal consequences of contaminating groundwater

. (g) Specific information on local groundwater conditions. 3) With respect to endangered species, current training and testingmaterials should be updated to address the following issues: (a) Laws and

.regulations relating to endangered

·species and consequences of endangering such

species. · (b) -sources of information on location and ."· identification of endangered species. (c) Importance of complying with label restrictions or other requirements identified on the label•

••4) With respect to disposal methods, current training and testing materials 1hould be updated to address the following issues: (a) Proper methods for disposing of small and large quantities of pesticides. (b) Consequences of improper disposal (e.g. groundwater contamination). (c) Laws and regulations relating to disposal of pesticides. 5) Despite the extensive development of educational materials on calibration, there is a continuing need for Innovative training

**and certificatio~**  materials arid methods to address the following issues: (a) Type of formulation to be applied. (b) Types of application equipment and the criteria for selection of the proper equipment. (c) Basic elements of calibration, including calculation of treatment area, nozzle characteristics, ground speed, operating pressure, and swath

**width~** ' (d) Equipment cleaning and maintenance•


## .... D. EPA and USDA should establish a central point for collection and distribution of educational and training materials developed by state and federal agencies, industry groups and others as well as regulatory documents which have bearing on the certification and training programs. To ensure that the central material collection/ distrLbution point remains valuable over time, a mechanism should also be established for

**pe~iodic** review and replacement o! out-dated materials.



### - E. EPA, USDA, State Lead Agencies and StateCooperative Extension Services shouldmeet periodically (at a minimum every two years) to reviewexistingCertification and Training

**p~ograms** and to discuss new training and ·. regulatory approaches.I

I IV. STAT! PLAMS, BMFOBCEMBMT AND M!ASUBBMEMT OF CCMPETEHCY 

### Most state plans were developed and approved over a period of time from 

### 1974 to 

### 1980 with EPA

**~egional** 

### offices responsible for final plan approval. In order to implement the program rapidly; EPA was forced to allowmaximum flexibility when approving state plans
. As a result there were differences in emphasis on various provisions of the state plans. This has resulted in substantial variation among state statutes, regulations and

**poli~ies** 

### with regard to certification and·training. Most state plans have not·been reviewed or updated since their initial approval. Since that time a number of changes have occurred, including a new emphasis on classifying pesticides as restricted use, a decrease in funding levels, new areas of concern relating to the use of pesticides (such as groundwater contamination, chronic health effects and endangered species), and

.general program changes necessitated by local pesticide

**probl~m~.** 

### These factors·, in combinationwith changing management priorities within EPA, have led to significant differences among current state programs. Differences in state requirements weaken the effectiveness of EPA's use of certification and training as an option in the regulation of a pesticide's use, inhibit interstate reciprocity, result in a lack of uniform training and

**ertification** 

### among states, and hinder implementation of regulatory decisions. A. 

### EPA should use, whenever

**pos~ible,** 

### restricted use classification and the ability of State Lead Agencies and StateCooperativeExtension Services to provide initial and continuing certification and training of pesticide applicators in developing regulatory solutions to potential pesticide problems
. B
. EPA should review all state pesticide applicator certification and training plans to determine if they are in compliance with 40 CFR 171 

### regulations. State plans should

**b~** 

### amended to b ..r·ing them into compliance and up to
/ 

## . date with the current programs as appropr1ate. C. EPA should reestablish its leadership role in the pesticide applicator certification and training programs at the headquarters level and provide increased regional office assistance. This should include elevating the program to a higher priority within EPA with program

**~** 

### orientation, more senior level management involvement, and increased funding to the states and regional offices commensurate wi:th the need to strengthen the certification and training programs.

• •

### D. The State Lead Agencies and StateCooperative Extension Services should develop and implement a mechanism for increased Industry participation in the applicator eertlfieatlon and contlnulnr certification programs and in developing and providi,g for applicator training needs. 1. EPA regional offices should be more effectively utilized to play a larger role in the planning and development of pesticide**applicat~r** certification and training programs to enhance consistency among states, to promote the potential for reciprocity and to provide more program expertise to the states. P. EPA should develop and implement an effective mechanism to communicate to the states anticipated federal regulatory decisions which may impact pesticide applicator certification and training programs. The mechanism should**provid~** sufticient lead

_ time 

### tot..**t~e** states to effectively implement uniform and orderly required or needed changes in the programs. State certification and training programs need to beable to accommodate regulatory decisions such as the actions taken against wood preservative pesticides. 

### G. State Lead Agencies should establish a notification system to effectively alert pesticide**deal~rs** and applicators of decisions on pesticides that are scheduled to**becom~** classified for restricted use. B
. EPA and USDA, jointly and in cooperation with State Cooperative Extension Services and the State Lead Agencies, should assess the effectiveness of current state and federal pesticide applicator certification and training programs. This assessment must include the continuing competency part of the programs. As a part of this assessment, uniform evaluation criteria for determining the effectiveness of training and certification programs should be developed. I. 1)**~PA** should amend the 40 CFR 171
.4(b) private applicator competency standards to ensure uniformity with the general commercial applicator standards in 40 CFR 171. 2) EPA should seek, and USDA support, a FIFRA amendment giving discretion to EPA to require examining of private applicators to determine competency.

### J. EPA should develop uniform, minimum competency standards for each of the following groups: 1) Trainers (this would Include Extension Service, Industry, state lead agencies, vocational agricultural personnel and anyone else who is Involved in providing pesticide training). 2) Non-certified applicators applying restricted use pest1cides u n d
. er the dir ect supervi s ion·of a certified applicator. K. Individual states should adopt legislation and/or regulations which would require Individuals who make pesticide application recommendations (i.e. consultants, county agricultural extension agent advisors, Industry representatives) to be certified•

.L. EPA and USDA should seek an amendment to Section 12 of PIPRA making it unlawful for any person to recommend a pesticide use inconsistent with the label or labeling except as provided under Section

**2~ee)** of PIFRA.· 

### M. EPA and USDA, in cooperation with State Lead Agencies, StateCooperative Extension Services and industry, as appropriate, should develop and implement "Train the Trainer" programs for individuals providing the actual training,to pesticide applicators.
V. CONTIMUIMG CXNPETEHCY AHD MAIMTEMAMCE OF APPLICATOR CE.RTIFICATIOM

Although a system of initial certification of pesticide applicators has been put in place in nearly all states, the
. process of periodically renewing certification is less well defined. Clearly the intent of PIPRA is to have applicators of pesticides continue to maintain their competency and understand changing technology
. The actual word "recertification," however, does not appear In the law; the lack of that preciseword has resulted in a weakness in the certification program. Each state was given the responsibility to show in

**i~s** state plan how it

**woul~**assure continued competency (40 CFR 171.7-8). At the time this may have seemed acceptable, but it has resulted in a hodgepodge of systems, some of which are excellent and others nearly non-existent. Furthermore, EPA has never followed· through on this aspect of state plans
. Most people in the pesticide

**ar~na** have come to believe that the best route to renewal of applicator certification is through some educational process. This may be realized through programs 

### ot continuing certification and/or by other requirements
.

•

### A. 1) As part of the previously recommended general review of all 

### atate plans, State Lead Agencies should review, revise and update their atate plans to identify provisions for perlodlc renewal of pesticide applicator certification. 2) In addition, StateCooperative Extension Services should review, revise and update the training portion of state plans in support of continuing programs leading to renewal of certification. B. As a part of state plan reviews, EPA should require that all certification plans contain a renewal period not to exceed five years. 

## c. States should distinguish clearly between certification and licensing, e.g., certification: the formal and legal indication that a pesticide applicator has met the standards of competency prescribed under PIFRA and atate laws. licensing: the issuance by a state of a license or permit to a person or a firm for business purposes. In some states certification is a prerequisite for obtaining a license. D. 1) EPA, State

-Lead Agencies and StateCooperative ExtensionServices should esi4bllsh the premise that keeping pace with changing technology is an educational process which requires continuing learning by the applicator. 2) As a basis for assuring continuing competency, EPA, State Lead Agencies and State Cooperative Extension Services should make available in a timelymanner appropriate Information and opportunities for attending training. B. Although each state has the right to establish its own logistic procedures, EPA should seek sufficient standardization of training and the process 

### ot certification renewal to facilitate interstate commerce. Presumably this would
.be achieved through the updating of state plans. What ls most needed is a system of documenting an'd quantifying training programs and othe· r educational opportunities so that there is·consistency among states. This w ill require planning and negotiating until a workable format is established. P. As a cooperative effort, the CooperativeExtension Service and Lead Agency in each state should
.reevaluate the jurisdictional role of 

### each and, where needed, update their roles to assure maximum effectiveness o! training and certification during the renewal process. •

### G. As pesticide situations arise (e.g•• required changes in use patterns), EPA. in cooperation with the State Lead Agencies and StateCooperative Extension Services. should promptly Identity information that applicators must know In order to keep current In their areas of competency. Likewise, these state organizations should establish responsive systems of information transfer to the pesticide applicators. B. State Lead Agencies should ensure that the

**~uality** 

### of continuing certification programs is such that high standards of competency can be universallymaintained. This will enable pesticide applicators to adjust to changing situatl·ons of themost rigorous nature, thus assuring a sound basis for restricted use application. J. 

### In eonsidering trainingmaterials and programs for eontinulng competency and maintenance of eertifleation, states should utilize not only those developed by EPA and StateCooperativeExtension Servlees, but whatever may be appropriate from various governmental ageneies, environmental groups, industry (manufacturers and user groups), and labor.

**~.** 

### Some unit of measurement is reeommended to quantify most training programs, e.g•• continuing **certi~uloll.JJours** 

### (CCH's). EPA needs to take the lead, workingwith both the State

**Le~d** 

### Agencies and the StateCooperative
.. Extension Services, in seeking a widely acceptable unit. Other approaches may alsol)e desirable for certainminor eategories or situations where specific, new information needs to be made immediately available and understood by a cateeory of applicators (e.g., the use of mailed informationwhich an applicator must read, comprehend, and signs off that he/she understands the material). 

### K.



### L. State Lead Agencies should

**consi~er** 

### the process of eontinuing education as a priority In the certification renewal process. This Is not to rule out reexamination or othe-r approvedmethods as an·adjunct requirement where appropriate. The option of recertification by examination must, of course, be retained for use when other options have not beenmet by an applicator. Two documents currently exist to provide guidance to those

**stat~** 

### developing programs to support continuing certification. These documents have already received consensus endorsement by StateRegulatory Agencies, the
. StateCooperativeExtension Services, the using industry and EPA ("Guidance for Developing Programs of Continuing Certification for PesticideApplicator Certification" and "Maintenance of Applicator Certification (MAC)"). These documents should be revised and updated inme
. diately, endorsed by appropriate organizations, and given wide distribution as appropriate. • .,...

# _ ...

# ---·------.

# ... CBRTIPICATIOM AMD TBAIMIMG TASK POBCB 

### Co-chairpersons

.0. 

### Nelson. PesticideAdministrator rfice of the StateChemist !partment of Biochemistry ndue University !St Lafayette, IN 47907 L7-494-1587 

### James H. Davis, Special Assistant Office of Pesticides and Toxic Substances U.S. EPA 401 M

### Street, S.W. TS-788 

### Washington, DC 20460 202-382-2982 

### Representatives form State Extension Services
• Norman Nesheim xtension PesticideCoordinator epartment of Entomology 01 LSW 

### klahoma StateUniversity tillwater. 

### OK 74078 05-624-5531 

### John Osmun. PesticideTraining: Coordinator Purdue University PesticideTrainingOffice Entomology Ba11 

### West Lafayette, IN 47907 317-494-4565 

### Representatives from State Lead Agencies

'imWells. BranchChief tivision of

### Pest Management :alifornia Department of Food and Agriculture

.220 N

### Street lacramento; CA 95814 116-445-5343 

### ton Conley, Assistant Commissioner

**~ntomology ~Pesticide**  

### Division =apitol Square Room 304

**~tlanta.** 

### GA 30334 104-656-4958

**~rt** 

### G. Losey, Assistant Director Vashington

**Departme~t** 

### of Agriculture 106 

### General Administration
.Building, AX-41 

### )lympia, WA 98504 Z06-753-5062 

### (Representing SFIREGWorkingCommittee Enforeement/Certi!ieation) L.O. Nelson, PesticideAdministrator Office of 

### the StateChemist Department of Biochemistry Purdue University West Lafayette. IN 47907 317-494-1587 

### Ken Kadlec, Director Department of Agriculture and Environmental Sciences P.O. Box 12847 

### Austin, TX 78711 512-463-7534

., 0

### I I 

### Representatives from USDA

s Parochettl, ProgramLeader icideApplicator Trainlni nd Weed Sciences nsion Service

Department of Agriculture
1

### 3347 South Building

.ington, DC 20250

·447-6506

·les Smith

·dinator, Pesticides and Pesticide

**~~**

### sessment

..Department of Agriculture

**~**

### AdminlstratlonBuilding 1ington, DC 

### 20250 -447-4751 

### FredWoods Actini Deputy Administrator for Airlcultural Programs Extension Service U.S. Department of Agriculture Room 3849 South Building Washiniton, DC 

### 20250 202-447-6283
.

Representatives from EPA Regional Offices

eCombs, State ProgramManager • EPA Region 8

Denver Place

- Suite 1300 18th Street v e r l CO 

### 802o ·2-2413 -293-1744 HaroldKazmaier, Pesticide Enforcemen1 Officer U.S. EPA· Region 1 APT 

### 2311 John F. Kennedy Federal Bldg. Boston,

### MA 02203 617-223-5785 Representatives from EPA Headquarters

1

### Davis, Special Assistant :ice of Pesticides and Toxic Substances ;• EPA l MStreet S.W. TS

-788 ihington, DC 20460 Z-382-2892 ,e Lindsay, Chief, Policy

and Special Projects Office !ice of Pesticide Programs S. 

### EPA 1 MStreet S.W. TS-766C shington, DC 20460 3-557-7102 John Seitz, Chief ExecutiveOfficer Office o!ComplianceMonitoring U.S. EPA 401 MStreet S
.W
. EN

-342 Washington, DC 20460 202

-382-7830



### ..