REPORT 

OF THE -EPA/SFIREG · 

CERTIFICATION 

· ·

. AND 

TRAINING 

-TASK FORCE 

-----~-------------

AUGUST 30, 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 , State Cooperative 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 of State Lead Agencies and 

State Cooperative 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 p r o vi de ! or per i o d 1 c _r en ew a 1 o! c e r t i ! i cat i on : 

continuing education should be a key element in this 

renewal pro~ess. 

14) FIFRA should be amended to make it unlawful !or anyone to 

recommend the use of a pesticide inconsistent with its 

labe 1 or labe 1 i 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 

Jim Wells- 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 

Fred Woods -U.S. Department of Agriculture 

Dave Combs - EPA Region 8 

Harold Kazmaier - EPA Region 1 

Anne Lindsay -Office of Pesticide Programs, EPA 

John Seitz -Office of Compliance Monitoring, EPA 

A more complete listing is attached to this report (At-tachment 

'1) • 

Four meetings of the Task Force were 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 

f 011 ows : 

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 

A sixth 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 Pesticide Control 

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, the Task 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 also makes 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 State Cooperative 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. OVERVIEW AND ACXXNPLISBM!MTS 

Amendments to the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA) in 1972 gave EPA the authority to restrict 

uses of pest i cides, 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 in March 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 Pesticide Applicator 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 Pesticide Applicator Certification and Tralalag Program. 

A. Over 2 million private and commercial pesticide applic~tors have been trained to become certified to use 

r e s tr i c t e d us e pes t l c i des , r e s u 1 t i n g i n abo u t 1 • 2 m 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 State Cooperative Extension Services have · greatly in~reased their efforts in pesticide education. 

G. The program has 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 Pes t ic i de Applicator Training Program, 

people who had not prev i ously 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 evaluation was concluded in 1979 on the 

North Carolina Pesticide Applicator Training Program by 

the Educational Testing Service, Princeton, New Jersey. 

Th i s 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 

pestic i de 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 posit i ve impact o~ the· grow~s' awareness about the personal and environmental 

s a f e t y i s s u e s r e 1·a t e d· t o t he us e and h a n d 1 i n g o C 

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 i nd i cating 

"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 State Cooperative Extension Services' 

efforts. 

0. The program has resulted in an improvement of state 

regulatory programs and enhanced the cooperation and 

coordination between the State Cooperative 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 State Cooperative 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 USE CLASSIPICATION AND 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 pesticide may 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 (40 CFR 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 Program Policy 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 application methods 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 to make 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)). In many 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 technic i ans, 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 

direcl i ons and precautions. Applicators should maintain 

verifiable records of the tra i ning provided (an expansion 

of 40 CFR 171 . 6) . 

B. · For private applicators. the supervisory certified 

applicator ~hould enBu r e tha t appropriate train i ng· ~nd 

current label use directions and precaut i ons are provided 

to all persons work i ng under his/her supervision and 

s hould main t ai n 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 TRAINING MATERIALS 

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 ) En v i r o nm en t 

(4) Pests 

( 5) Pesticides 

( 8.) Eq u l pmen t 

(7) Application Techniques 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) Dealing with public concerns relating to the 

use of pesticides 

B. State Lead Agencies and State Coopeerative 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 percen t 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, State Cooperative Extension Services and 

State Lead Ag.encies, in cooperation wi"th industry 

and trade association groups, should establish or 

update national core training manuals 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 State Cooperative 

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 testing materials 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 State Cooperative 

Extension Services should meet periodically (at a minimum 

every two years) to review existing Certification 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 allow maximum 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 in i tial approval. Since that time a number of changes have 

occurred, including a new emphasis on classifying pesticides as 

restr i cted 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 combination with 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 

State Cooperative Extension Services to provide initial 

and continuing certification and training of pesticide 

applicators in developing regulatory solutions to 

potential pest i cide problems . 

B. EPA should review all state pesticide applicator 

cert i fication and training plans to determine if they are 

in compliance with 40 CFR 171 regulations. State plans 

should b~ amended to b..r·i ng 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 tra i ning 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 ~ 

or i entation, more senior level management involvement , and increased funding to the states and reg i onal offices 

commensurate wi:th the need to strengthen the 

certification and training programs. 

• • 
D. The State Lead Agencies and State Cooperative 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 be able 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 

pes t 1 c i des u n d.e r t he d i r e c t s up e r v i s i on· o f 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, 

State Cooperative Extension Services and industry, as 

appropriate, should develop and implement "Train the 

Tra i ner" programs for individuals providing the actual 

training ,to pesticide applicators. 

V. CONTIMUIMG CXNPETEHCY AHD MAIMTEMAMCE OF APPLICATOR 

CE.RTIFICATIOM 

Although a system of init i al 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 precise word has 

resulted in a weakness in the certifi cation program. Each state 

was given the responsibility to show in i~s state plan how i t 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, State Cooperative Extension Services 

should review, revise and update the training port i on 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 State Cooperative 

Extension Services 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 timely manner 

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 quantify i ng training programs and othe·r 

educational opportunities so that there is · consistency 

among states. This wi ll require planning and negotiating 

until a workable format is established. 

P. As a cooperative effort, the Cooperative Extension 

Service and Lead Agency in each sta t e shou l d. reevaluate 

the jurisd i ctional 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 State Cooperative 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 universally maintained. 

This will enable pesticide applicators to adjust to 

changing situatl·ons of the most rigorous nature, thus 

assuring a sound basis for restricted use application. 

J. In eonsidering training materials and programs for 

eontinulng competency and maintenance of eertifleation, 

states should utilize not only those developed by EPA and 

State Cooperative Extension 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, working with both 

the State Le~d Agencies and the State Cooperative .. Extension Services, in seeking a widely acceptable unit. 

Other approaches may alsol)e desirable for certain minor 

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 

information which 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 approved methods as an ·adjunct requirement where 

appropriate. The option of recertification by 

examination must, of course, be retained for use when 

other options have not been met 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 State Regulatory Agencies, the . State Cooperative Extension Services, the using industry 

and EPA ("Guidance for Developing Programs of Continuing 

Certification for Pesticide Applicator 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. Pesticide Administrator 

rfice of the State Chemist 

!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 Pesticide Coordinator 

epartment of Entomology 

01 LSW 

klahoma State University 

tillwater. OK 74078 

05-624-5531 

John Osmun. Pesticide Training : 

Coordinator 

Purdue University 

Pesticide Training Office 

Entomology Ba 11 

West Lafayette, IN 47907 

317-494-4565 

Representatives from State Lead Agencies 

'im Wells. Branch Chief 

tivision of Pest Management 

:alifornia Department of Food 

and Agriculture .220 N Street 

lacramento ; CA 95814 

116-445-5 343 

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 SFIREG Working Committee 

Enforeement /Certi!ieation) 

L.O. Nelson, Pesticide Administrator 

Office of the State Chemist 

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, Program Leader 

icide Applicator Trainlni 

nd Weed Sciences 

nsion Service 

Department of Agriculture 

1 3347 South Building .ington, DC 20250 ·447-6506 

·les Smith ·dinator, Pesticides and Pesticide ~~ s es smen t .. Department of Agriculture ~ Adminlstratlon Building 

1ington, DC 20250 

-447-4751 

Fred Woods 

Actini Deputy Administrator for 

Airlcultural Programs 

Extension Service 

U.S. Department of Agriculture 

Room 3849 South Build i ng 

Washiniton, DC 20250 

202-447-6283 . 

Representatives from EPA Regional Offices 

e Combs , State Program Manager 

• EPA Region 8 

Denver Place - Suite 1300 

18th Street 

v e r l CO 8 0 2 o·2- 2 413 

-293-1744 

Harold Kazmaier, Pesticide Enforcemen 1 

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 M Street S.W. TS - 788 

ihington, DC 20460 

Z-382-2892 

,e Lindsay , Chief, Policy 

and Spec i al Projects Office 

!ice of Pesticide Programs 

S. EPA 

1 M Street S.W. TS-766C 

shington, DC 20460 

3-557-7102 

John Seitz, Chief Executive Office r 

Office o! Compliance Monitor i ng 

U.S. EPA 

401 M Street S.W. EN - 34 2 

Washington, DC 20460 

202 - 382-7830 

..