### PPDC Worker Safety Regul ation Change Subgroup Summary of PREP and PPDC Comments

Issue Paper IA: Expand Scope of Users ...........................................................1

Issue Paper IB: Under the Supervision ..............................................................2

Issue Paper IC: Restricted Use Product Dealer Competency .............................3

Issue Paper IIA: Minimum Age for Applicators ...................................................4

Issue Paper IIB: Exams for Applicator ................................................................5

Issue Paper IIC: Set Standard Requirements for Testing ...................................6

Issue Paper IID: Competency Requirements Commensurate with Risk .............7

Issue Papers IIE & F: Period and Gauge for Re-Certification .............................8

Issue Paper IIIA: Develop Standard Certification Categories .............................9

Issue Paper IIIB: Update Federal/State/Tribal Certification Plan Requirements ............................................................................................................................10

Issue Papers IIIC and VIB: Assure Program Accountability .............................11

Issue Paper IVA: Hazard Communication ........................................................12

Issue Paper IVB: Require Timely Training ........................................................13

Issue Paper IVC: Require Trainers to Demonstrate Competency .....................14

Issue Paper IVD: WPS Recordkeeping ............................................................15

Issue Paper IVE: Children in Fields ..................................................................16

Issue Paper IVF: Expand WPS Training ...........................................................17

Issue Paper VA: Clarify Vague WPS Provisions ...............................................18

Issue Paper VB: Clarify WPS Entry Exceptions ................................................19

Issue Paper VC: Exempt Certified Crop Adviso rs and Aerial Applicators from WPS ....................................................................................................................20

### 1

Issue Paper IA: Expand Scope of Users - Ensure that occupational users of potentially harmful pesticides have the appropriat e competence to use them safely

Options considered:

1. Establish competency gauge appropriate to risk for all occupational users, including those who use pesticide incidentally in their job 2. Establish competency gauge appropriate to risk for occupational users in intensive pesticide-using industries or where sensitive populations may be affected

PREP Comments:

3⁄4 Overall, significant support for so me level of expansion to non-RUP users 3⁄4 Public has expectation of safety from pesticide risks 3⁄4 States have gone beyond RUP use certif ication with a variety of specifics 3⁄4 Need more specifics to describe who w ould be covered; relationship to other regulations 3⁄4 Needs definitions of occupational and intensive use, sens itive groups, etc 3⁄4 Concern for workload impacts 3⁄4 Concern for impact on farmers 3⁄4 Unique industries want specific exams for applicators – expensive for states to develop and keep current. 3⁄4 For consideration:

o Require only training for certain segments;

o Increase hazard communication for occupational applicators;

o Restrict to only those who must wear PPE;

o Eliminate direct supervision;

o Rely on FDA for health care uses;

o Consider other divisions: by industry, product, site, method of application

o Consider narrowing the scope;

o Consider a process for exemptions;

o Evaluate state requirements and use as model;

o Consider narrowing the scope;

o Consider a process for exemptions;

o Consider burden to re-certification

PPDC Comments:

General support for expansion, but need additional detail; including better development of scope Concerns for expansion: Antimicrobial industry

o FIFRA language in which Congress in tended to exclude antimicrobial users from training requirements

o Expansion is redundant with OSHA HAZCOMM

o “All occupational” users too large a scope; exclude incidental users

o Rationale/need for additional regulation unclear Some comment in support of expansion of competency gauges

o for antimicrobial industry,

o in public areas (schools or airliners), and

o in areas where infectious disease spread is a concern (crime scene cleanup, cruise liners, daycare)

o Incident data used to support rationale are flawed

### 2

Issue Paper IB: Under the Supervision: Protect public health and the environment by ensuring adequate supervision of non-cert ified users of rest ricted use products

Options considered:

1. Development of a more precise def inition of “under the supervision:” a. Maximum number to be supervised b. Maximum number of applications that may be supervised c. Maximum distance between supe rvisor and uncertified applicator d. Maximum travel time between supervisor and uncertified applicator e. Require appropriate communication between supervisor and uncertified applicator f. Define “guidance for applying the pesticide properly” g. Establish a standard for the demonstration of competency for the uncertified RUP applicator

PREP Comments:

3⁄4 Proposal is well-supported 3⁄4 Some states have partially or completely eliminated the option to use RUPs “under the supervision” 3⁄4 Require training for private applicators 3⁄4 Consider tiered requirements, based on experience 3⁄4 Strengthening the definition w ould raise the national standard 3⁄4 Elimination of under the supervision would improve enforcement 3⁄4 Consider different options for privat e and commercial “under the supervision” 3⁄4 PREP posed a number of options for improving the federal definition 3⁄4 Concerns for UTS in green industry

PPDC Comments:

Competency measures may suffice – if applicators are trained, UTS is a moot point; or appropriate label language to limit RUP UTS Concern for the enforceability of certai n options; several commenters agreed that UTS is an issue that needs addressing Requirements for maximum travel time or for supervisor to be on-site were of concern to some; support for immediate communication with applicator Concerns remain over the details of the proposal

### 3

Issue Paper IC: Restricted Use Product Dealer Competency: Ensure that dealers of RUPs have appropriate competence to protect human health, the environment, and homeland security

Options considered:

1. Require dealers to become “certified,” pr ovide off-site inventory, and confirm security standards 2. Require dealers to become “certified”

PREP Comments:

3⁄4 This change is worthwhile

o Due to substantial number of violations and other issues

o Improve security of facilities 3⁄4 Need more detail in paper 3⁄4 Shipping across states lines may be problematic 3⁄4 Certified dealer may not always be present – would he be responsible for failures if not there?

o Would license be issued to the place of business or to individual?

o If dealership has multiple locations, how would that work? 3⁄4 Need to consider recertification requirements 3⁄4 “Bad Actor” list for dealers would be useful 3⁄4 Time to obtain license is a barrier to adoption 3⁄4 Offsite inventory

o Should establishments be required to provide this?

o Is this appropriate for C&T? What is benefit to states?

o Homeland security is not relevant here 3⁄4 This applies only to RUP dealers; states could go further

o States could establish requirements beyond core exam 3⁄4 Options for consideration:

o Need to consider internet sales

o An option to train on-site employees

o Consider only for ag sales

PPDC Comments:

Issue paper needs to be more detailed Mixed support for dealer certification programs Positive ID – issues with implementation on internet and phone sales One responder was not supportive of stretching program into homeland security; other agencies have addressed security is sues. Also, many of the safety goals identified in this paper are already addressed. Dealer competence should be limited to heal th and environmental safety; eliminate references to requirements for competency related to product advice.

### 4

Issue Paper IIA: Minimum Age for Applicators: Ensure that children do not endanger themselves and others by occu pationally applying pesticides

Options considered:

1. Establish minimum age of 18 to pur chase, handle, or apply occupationally 2. Establish minimum age of 18 to purchas e, handle, or apply occupationally; with 16 as minimum for children applying on a family farm

PREP Comments:

3⁄4 Overall, the proposed change is considered to be worthwhile

o Better protection of children and the public

o Strengthens ability to enforce

o Promotes national baseline consistency 3⁄4 Include more data on risks and exposure

o Poison Control center data

o Ag Health Study

o Farm Family study 3⁄4 Reinforce risks to public and environment 3⁄4 Scope needs to be clarified 3⁄4 Expand: need to understand PPE use and label directions 3⁄4 Opinions varied on the appropriate age (between 16 and 18) 3⁄4 Range of options were suggested, building on those proposed

PPDC Comments:

Respondents generally agreed with 18 as minimum, with limited exceptions Definitions for handling and certification need to be better defined Paper should better justify need Distinction needs to be made between agricultural and non-agricultural pesticides Limiting purchase to 18 or older would rest rict use of personal insect repellents and 25(b) pesticides Concern expressed for compliance on farms

### 5

Issue Paper IIB: Exams for Applicators: Protect by ensuring that occupational pesticide users are determined to be competent through use of a reliable competency gauge

Options considered:

1. Require competency exam s for all occupational users a. Language in FIFRA limits the agency’s authority with respect to requiring examinations for private applicators. 2. Require competency exams for all comme rcial users; outline extensive alternative competency regimen for private applicators

PREP Comments:

3⁄4 The proposal is worthwhile 3⁄4 Burden to states could be significant 3⁄4 Other considerations include optional exams for handlers and private applicators 3⁄4 PREP participants made suggestions for gauges of competency 3⁄4 Handler examinations too difficult to administer (language issues, etc) 3⁄4 Gauge for private applicators needs to be reasonable

PPDC Comments:

Mixed responses

o Applicators under the supervision should take core exam

o Support for high-risk applicators taking exams

o Incidental users, others should not need exam

o Paper needs clarification on relationsh ip to the “under the supervision” topic

o Concern for costs related to training and testing an increased number of applicators

o Needs definition of occupational user

o Trained and competent users may not pass test – language barrier

o Prefer option to demonstrate competency w/o exam

### 6

Issue Paper IIC: Set Standard Requirements for Testing: Standardize exam development and exam administration to ensure consistently tested applicators

Options Considered:

1. Define and require minimum standards fo r a secure and content-relevant exam a. Written, closed-book, proctored, require positive ID b. Content-relevant exam development process 2. Define and require minimum standards for a secure exam a. Written, closed-book, proc tored, require positive ID

PREP Comments:

3⁄4 The proposed change is worthwhile:

o improve credibility; decre ase reciprocity issues

o increase applicator professionalism and competency

o improve accountability with public

o needed applicators would be avail able in emergency situations 3⁄4 Both options received some support 3⁄4 Assure consistency 3⁄4 Basic support for content-relevant exams;

o exam development varies across the states 3⁄4 Manual development should be a consideration 3⁄4 Category or core – which to standardize? 3⁄4 Rationale supports the proposal 3⁄4 Needs more detail and definitions

PPDC Comments

Positive ID is necessary Mixed opinions on whether reciprocity would be improved Concern for burden to states; both initially and for exam re-writes Mixed opinions on closed book exams One responder felt exams should be available in Spanish Option 1 preferred by commenter, also believe EPA should develop national exams

### 7

Issue Paper IID: Competency Requirements Commensurate with Risk: Ensure that applicators have appropriate competence to protect human health and the environment from higher-risk applications

Options Considered:

1. Establish additional protections throug h specific exams for applicators making higher-risk applications 2. Establish additional competency gauges for higher risk exams, for example, practicum or apprenticeship

PREP Comments:

3⁄4 Proposal is worthwhile: there are gaps in protections for high-risk situations:

o presented by application method

o or compound 3⁄4 Protections could be based on

o label requirements for training

o more categories and exams 3⁄4 For unclassified products, change classification to RUP 3⁄4 Use state program profile as model for high-risk categories 3⁄4 Concern added burden to states 3⁄4 Clarification needed in issue paper, “high-risk” needs to be defined 3⁄4 CTAG should finalize their tiered approach paper

PPDC Comments:

Mixed support for proposal

o Unnecessary - products which pose additional risk should be addressed through mandatory stewardship provisions on labels; existing requirements adequate

o Necessary – additional or different exams for higher risk uses needed

o More detail on proposal is needed Concern for added burden of exam development

o Consider replacing exams with additional training

o Develop national, standardized exams to make requirements for certification standard

### 8

Issue Papers IIE & F: Period and Gauge for Re-Certification: Better protect human health and the environment by establishi ng national standards for recert ification that cover core competencies as well as the changing field of pesticide application

Options Considered:

1. Establish a minimum retesting period, and national standards for continuing education programs 2. Establish a minimum recertification peri od to help maintain core competency, and establish guidelines for states to approve continuing education programs

PREP Comments:

3⁄4 States have established a variety of re-certification requirements in the absence of a federal baseline 3⁄4 Option 2 was preferred 3⁄4 Burden to states in developing and maintaining separate tests 3⁄4 Consider evaluations and exit surveys to value training 3⁄4 Would standard be the same for re cert as for initial certification? 3⁄4 Minimum standard for recertification is needed. 3⁄4 Consider retesting every 5 years with CEUs in between 3⁄4 Change is needed and worthwhile

PPDC Comments:

Support expressed for Option 1 with option for CEUs/testing Support also expressed for Option 2

o With a national review board for program approval Allow federal government to require retest ing for specific products/uses/categories. Establish federal standards to ensure app licators stay current with their area of certification Allow states to decide if recert ification is by exam or CEUs Support for a maximum re-certification interval with a one-time retest Concern for burden and cost Issue needs additional detail Reciprocity would not be facilitated – iss ue still comparability of state requirements

### 9

Issue Paper IIIA: Develop Standa rd Certification Categories: Establish national consistency in applicator certification categories and improve and expand program administration and scope

This Issue Paper received only limited comment from the PPDC. We would like to encourage our stakeholders and partners to comment on this proposal.

Options Considered:

1. Require all states to adopt an expanded list of federal categories for pesticide users/all occupational users. States ma y not add categories or subcategories. 2. Require all states to adopt an expanded list of federal categories for pesticide users/all occupational users. States may establish additional categories under limited circumstances.

PPDC and PREP Comments:

Significant reciprocity issue PREP had less concern for reciprocity; supported Option 2 PPDC supported Option 2 Commenter did not support the tiered, risk-based system for applicators described in Option 1; instead supporting a single license through a valid national exam.

### 10

Issue Paper IIIB: Update Federal/State/Tri bal Certification Pl an Requirements: Improve the efficiency and operation of the pesticide appl icator program by updating the regulatory requirements for federal, state, and tribal plans

This Issue Paper was not reviewed at the PREP meeting, and received only one comment from the PPDC. We would like to encourage our stakeholders and partners to comment on this proposal.

Options Considered:

1. Improve efficiency and operation of the pest icide applicator certification program by making the needed regulatory revisions to part 171 to address the policy, regulatory, and program implementation

PPDC Comments:

Agree that consistent requirements are needed

### 11

Issue Papers IIIC and VIB: As sure Program Accountability: The absence of consistent reporting inhibits EPA’s ability to manage the program, establis h priorities, and meet new program accountability obligations.

This topic area is primarily for program as sessment, and we would not expect the range of comments we received for other topics. We do reco gnize that our co-regulators in the states and our partners in cooperative extension may be im pacted by these decisions, and look forward to their comments.

Options Considered:

1. Add to the rule a requirement for states to report needed data; rule will reference a document describing those data needs 2. Add specific reporting requirements to the rule 3. Encourage voluntary reporting

PPDC Comments:

Support expressed for both Options 1 and 2 Reporting requirements need to be meani ngful, reasonable, and clearly stated as requirements

### 12

Issue Paper IVA: Hazard Communication: Protect the health of Agricultural Workers by providing them pesticide specific hazard information

Options Considered:

1. Add requirements for pesticide-specific hazard communication to the agricultural worker protection regulation

PREP Comments:

3⁄4 Change is worthwhile 3⁄4 Important for worker safety 3⁄4 More detail needed 3⁄4 Assurance that EPA has coordinated with state and federal OSHA 3⁄4 Rationale needs to be stronger

o Why existing WPS protections are not considered adequate 3⁄4 Include results from pilot studies 3⁄4 Stress that hazard communication is for pesticide specific information 3⁄4 Discuss MSDS and their ad vantages and disadvantages 3⁄4 Discuss handler Hazcomm 3⁄4 Stress risk basis for proposal, not equivalency to OHA 3⁄4 Need to discuss implementation 3⁄4 Consider labeling to convey pesticide specific information to handlers 3⁄4 Consider options to central display, wh ich is not useful and is high maintenance 3⁄4 Hazcomm would need to be addressed in training 3⁄4 Pesticide-specific Hazcomm would need to be site-specific 3⁄4 Concern for resources – all WPS material would need changing 3⁄4 Long implementation schedule needed

o Design of pesticide specific sheets

o Retraining of inspectors

o Statute and regulations in states may need changing

PPDC Comments:

Worthwhile proposal Why aren’t existing WPS protections adequate?

o PPE, REIs, and handling of clothing are keys to protections

o Concern for extended training Some support for MSDS Consider specific recommendations for Hazcomm product Hazcomm product should not include MSDS or those from 1992 proposal Hazcomm product should be paid for by registrants Consider an 800-number for reference information instead of crop sheets or MSDS Share results of EPA’s pilot

### 13

Issue Paper IVB: Require Timely Training: Improve Timing and Frequency of Pesticide Safety Training to help agricultural workers protect themselves

Options Considered:

1. Eliminate the grace period and option for brief training; require annual retraining to ensure workers have an adequate understanding of the risks and protective

measures 2. Eliminate the grace period and option for brief training; require annual retraining every two years to ensure workers hav e an adequate understanding of the risks and protective measures

PREP Comments:

3⁄4 Change is worthwhile 3⁄4 In some states, the primary violation is training 3⁄4 Review state programs that have implemented this, see if training has made a difference 3⁄4 Brief training is required; shouldn’t be a problem to replace with full PST 3⁄4 Eliminating grace period simplifies inspections 3⁄4 Two-year retraining was preferred option; some advocated three-year

o States can be more stringent

PPDC Comments:

Support for both options voiced Support for eliminating the grace period

o Also consider reducing the grace period Coupled with other improvements to traini ng, consider a longer retraining interval than proposed Array of training materials would need to be expanded Some preferred refresher training to full retraining May be impractical for some growers Need impact analysis/benefit analysis for retraining interval

### 14

Issue Paper IVC: Require Trainers to Demonstrate Competency: Ensure that safety trainers are competent to provide needed safety training to farm workers

Options Considered:

1. Establish verification of competency fo r trainers of field workers by requiring certification under the pesticide a pplicator certification regulation 2. Require that trainers successfully co mplete an approved train-the-trainer (TTT) workshop to advance their skills in teac hing to this difficult-to-reach population

PREP Comments:

3⁄4 Worthwhile proposal 3⁄4 Concern for costs 3⁄4 Rationale adequately supports proposal 3⁄4 Certification is too high a hurdle/certification is appropriate 3⁄4 Need a national TTT program 3⁄4 Need to establish a re-training interval for trainers 3⁄4 Have state program with exam but not certify 3⁄4 Consider other ideas:

o Use CEUs to encourage participation

o Add trainer category to Applic ator certification regulation

o Keep handler trainers in mind

PPDC Comments:

Support voiced for both Options, and combination Support for no change - current requirements are adequate Alternative proposal: national registry of certified trainers and develop an industry standard National program must be flexible to allow states to address unique situations Proposed changes are too burdensome TTT programs do not ensure quality training Consider accepting appropriate training education and experience Improving training is one of better ways to improve protections Have a nationwide registry for trainers Revise issue statement to focus on the goal of improved training

### 15

Issue Paper IVD: WPS Recordkeeping: Protect agricultural workers’ health by verification of pesticide safety training

Options Considered:

1. Require employers to keep records of workers who receive WPS safety training for two years 2. Require employers to keep and submit records to the state lead agency

PREP Comments:

3⁄4 Change is worthwhile 3⁄4 Some prefer Option 1 with option for states to decide to issue verification cards 3⁄4 Some states require recordkeeping already 3⁄4 One of top three violations 3⁄4 Important to verify training; paper trail needed for enforcement actions 3⁄4 Burden of change not significant to states 3⁄4 If handlers aren’t moved into C&T same requirements should apply 3⁄4 Other options:

o Make card mandatory

PPDC Comments:

Change is worthwhile; compelling case is made Important for enforcement Nationwide tracking system Some preferred Option 1

o Records maintained to match re-training interval

o Recommend elimination of requirement for trainers to use EPA-approved materials, instead have trainer certify that all training topics covered

o Option 2 too bureaucratic and costly; solution is more frequent training, and verification of same Some preferred Option 2 (states receive records)

o Tracking system would discourage use of fraudulent cards

o Would be costly but worth the trouble Cards should be issued by trainers as proof of training

o Growers may be leery of cards as proof of training Workers without cards cannot be discriminated against for hiring Workers should be paid for time spent in training

### 16

Issue Paper IVE: Children in Fields: Protect agricultural workers’ children from pesticidetreated fields

Options Considered:

1. Require employers to restrict field access, prohibiting farm worker children under the age of 12 from being in the field 2. Enhance farm worker training requirements to include the effects of pesticides on children and provide additional information fo r farm workers to protect their families

PREP Comments:

3⁄4 This change is worthwhile 3⁄4 Issue paper needs to clarify issue of authority and discuss enforcement 3⁄4 Label language (outside Ag Use Box) option would make applicator responsible 3⁄4 Concern for impact from Option 1 on farm workers without options for daycare 3⁄4 Address other youths who may cross through fields 3⁄4 How would inspectors determine child’s age? 3⁄4 Paper doesn’t address housing located in treated fields 3⁄4 Option 2 preferred: ex pand training prudently

o Encourage advocacy to support this effort in the field

o No enforcement hook from this option 3⁄4 Other options:

o Use aggregate risk assessment and set REIs for children

o Have day care centers provided by employing facilities

o Include spouses in training, engage ag employers

PPDC Comments:

Those who prefer Option 2 felt more practical approach; empowers parents to make informed decisions Support also voiced for Option 1 Consider adding language to WPS to prohibit children in covered areas Observe state requirements and model on them Consider leaving some decision-making up to parents Support for additional protective information It is parent’s responsib ility to supervise children Support for regulatory requirements that would make parents responsible for children’s access to fields Has EPA/state authority to prohibit access?

### 17

Issue Paper IVF: Expand WPS Training: Enhance safety training to better protect agricultural workers and their families

Options Considered:

1. Enhance the existing pesticide safety tr aining for agricultural workers by including all of the recommendations m ade by the assessment workgroup 2. Enhance the existing pesticide safety tr aining for agricultural workers by including points on hazard communication s and on protecting families

PREP Comments:

3⁄4 Change is worthwhile/ change is unnecessary 3⁄4 Some states have already enhanced their training 3⁄4 Concern for details about reporting incidents and complaints 3⁄4 No concerns raised for additional info rmation about take-home exposure and protecting families 3⁄4 Consider expanding handler training as well 3⁄4 Paper supports proposals, needs clarif ication – we need to see regulatory language to fully comment 3⁄4 Prefer Option 2 3⁄4 Potentially costly and bur densome to all involved

PPDC Comments:

Option 1 preferred, consider

o Guarantee of confidentiality for r eporting illnesses or complaints

o Include NPIC 800#

o HazComm training Concern for burden – cost of changing materials Concern for length/complexity of training resulting in lost message

o Consider providing examples of new training materials for review Support for expanding training scope, consider

o Only needed if other reg change s proposed are not implemented

o Potentially shift burden to OSHA

### 18

Issue Paper VA: Clarify Vague WPS Provisions

Options Considered:

1. Make needed changes to regulations to clarify vague provisions and address other regulatory problems

PREP Comments:

3⁄4 Need more detail on proposals and options 3⁄4 Look to ASAE for assistance in devel oping definitions/per formance standards 3⁄4 Consider DoL for retaliation concerns 3⁄4 Proposed changes are worthwhile 3⁄4 Concern for burden

PPDC Comments:

Option 1 supported;

o clarity in regulation important for compliance

o reminds the agency that some critic al crop monitoring must be done under the REI

### 19

Issue Paper VB: Clarify WPS Entry Exceptions

This Issue Paper was not reviewed at the PREP meeting, and received only one comment from the PPDC. We would like to encourage our stakeholders and partners to comment on this proposal.

Options Considered:

1. Clarify exceptions

PPDC Comments:

Clarify and simplify – improve compliance Administrative exceptions may still be nec essary, particularly if exceptions are listed specifically

### 20

Issue Paper VC: Exempt Certified Crop Ad visors and Aerial Applicators from WPS

Options Considered:

1. Remove all references to crop advisor s and aerial applicators from the agricultural worker protection regulation and inclu de them in the pesticide applicator certification regulation 2. Amend WPS to reference C&T regulation as exemption for crop advisors and remove provisions to allow them to det ermine appropriate PPE fo r their employees. Amend the WPS to exempt certified aeri al applicators from the PPE provisions under 40 CFR 170 for pilots except as required by product labels. 3. Amend WPS to reference C&T regulation as exemption for crop advisors and revise the training provisions to require general occupational use certification under the revised 40 CFR 171. Amend the WPS to exempt certified aerial applicators from the PPE provisions under 40 CFR 170 for pilots except as required by product labels.

PREP Comments:

3⁄4 Rationale does not adequately support proposal 3⁄4 Need clarity on coverage of CCAs; co verage of non-certified crop advisors 3⁄4 Need to focus on protections 3⁄4 Discussion of CCAs in Applicator certif ication program, without being applicators 3⁄4 Aerial should be a separate discussion 3⁄4 Justification for aerial is not clear 3⁄4 Provide differentiation about protections for applicators/pilots vs M/L and other handlers 3⁄4 Discuss how states would implement certification 3⁄4 Consider keeping CCAs in WPS, am end to better protect CCA employees 3⁄4 Not convinced that aerial applicator proposal is needed 3⁄4 Need more information to evaluate options

PPDC Comments:

Support for continuation of the Crop Advisor Exemption under the WPS

o or assurance that exempt ions for existing crop advisor programs are retained Support for enhanced training Concern for overly-stringent option 2 and burden Support also voiced for moving aerial applicators and CCAs to the applicator certification program