{1014.004 / 111 / 00100826.DOC 5}

Soil Fumigant Applicator Training Program

Protocol for Registrant In-Person Training Programs

1. Availability and Notice of Programs: Each soil fumigant registrant may choose on an 

individual basis to deliver the required applicator training in person in any location that 

the registrant desires to do so. These in-person programs may be done on an individual 

registrant basis or may be done jointly among registrants of the same active and by 

registrants of different actives. Each such program will be organized by the individual 

registrant or registrants holding the training program and will be advertised by their 

standard methods. The notice or advertisement of the training program should include 

which active ingredient(s) will be offered in that particular training program. Registrants 

are encouraged to include in any generally directed emails regarding large group 

upcoming in-person training programs appropriate state pesticide contacts with 

responsibility for training programs, but are not required to do so; however, if state 

continuing education credit is sought, then notification to appropriate state contacts must 

be provided for that particular in-person training session in accordance with the state 

rules. 

2. Program Content: Each in-person training program must include the content of the 

online training program for the general fumigation modules and for the active ingredient 

modules that are offered in that particular training session. During the training session, 

this content can be delivered via computer, or can be delivered using a copy of the slides 

with an in-person presentation of the on-line training program script for the modules 

offered at that session. When the content is delivered via computer, it can be played 

through a projector or a sound system, or in some other manner that allows attendees to 

see the slides and hear the script. Questions and answers, and related discussion, are 

permitted during the delivery of the training program, as long as all of the training 

program content for the modules being offered is provided. If any hard copies of the 

slides are circulated, those hard copies would be collected after the training session.

3. Exams: Registrants may offer attendees at in-person training sessions the opportunity to 

take a written paper exam. Generally the exam will be offered at the end of each module 

presentation. Anyone who attends an in-person training may choose to take the on-line 

training and take the test on-line.

a. Exam version: Trainers will be provided with three versions of the exam for each 

module being offered at the training for this purpose by a designated registrant 

representative. The versions are of equal difficulty and all questions are drawn 

from the same exam bank used for the on-line training. The different versions are 

provided so that those sitting next to each other will not have the same version of 

the exam. 

b. Information required from applicators taking hard copy exams: Applicators 

taking the hard copy exams must provide to the trainer the following information, 
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and this information must be recorded on the exam paper for the exam to be valid 

for credit towards meeting the applicator training requirement: (1) a valid state 

certified applicator license number; and (2) a photo identification. In addition, the 

applicators will be required to complete a registration form. 

c. Signed terms of use required: Applicators taking the exam in-person must also 

sign the terms of use provisions below and must include their valid state certified 

applicator license number on that signed terms of use document. The terms of use 

provisions for in-person training are:

Terms of Use

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

and that (1) the certified applicator license information shown on 

the registration form is my unique license number issued by the 

state or states indicated or (2) I am a state regulator, grower 

advisor, or fumigant distributor and I am accessing this program 

for informational purposes only in connection with my duties as 

such an employee. I acknowledge that it is a violation of the 

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to 

apply a pesticide in a manner inconsistent with its label including 

the requirements regarding a state certified applicator license and 

soil fumigant training.

This program is provided on the condition that the user is 

accessing it for the purposes of compliance with the label 

directions for soil fumigant pesticides in the United States and the 

user agrees that he/she will not knowingly allow another person to 

claim that they have been trained based on the user accessing this 

program. Moreover, the user acknowledges that he/she 

understands that information regarding his/her successful 

completion of this training program will be provided upon request 

to the USEPA and to state or tribal pesticide regulatory agencies, 

who may in turn release the information in accordance with the 

agencies’ policies and by participating in the training program the 

user grants permission to the release of his/her name, state certified 

license information and training program completion information 

to these regulators. No information will be used for marketing or 

advertising purposes and information will not be shared with 

anyone other than the registrants who are sponsoring this training 

program and the USEPA and state and tribal regulators noted 

above. 
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d. Grading of hard copy exams:

i. Exams will be graded by representatives appointed by each registrant to 

have the exam answer keys. These registrant representatives with access 

to the exam keys are strictly prohibited from disseminating or otherwise 

conveying the exam keys to persons not employees of, contractors to, or 

attorneys for the individual registrant and who have not been designated 

by that registrant to have the exam answer key. 

ii. Some training sessions may offer exam grading on-site, and others may 

grade remotely after completion of the training session. This will be 

decided on an individual registrant and individual training program basis. 

e. Before providing the exam documents to applicators at the training session, 

trainers must convey the following to those taking the exam:

i. Applicators may ask, and trainers may answer, non-substantive questions, 

such as how much time is available for the exam, when the exam is being 

taken. Trainers may not answer any substantive questions while exams 

are being taken.

ii. Applicators must provide valid state license numbers on the exam paper 

and on the terms of use. Contact information that will allow exam results 

and Proof of Completion documentation to be delivered must be provided. 

Email and hard copy address are preferred; at least one is required.

iii. Cell phones must be turned off by trainees upon entering the examination 

area and not turned back on until they have turned in examination answers 

and leave that area. 

iv. Pens and/or pencils will be provided to those taking hard copy exams. 

Notes and calculations may be made on the exam paper itself; no other 

paper will be provided. No documents furnished during the training and 

examination may be taken from the training/examination area at any time 

except with the permission of the registrant's representative.

v. After December 1, 2012, hard copies of approved representative product 

labels may be provided, but are not required to be provided, by the 

registrant offering the training program. Whether such label copies are 

available, and how many are available, will be a decision made 

individually by each registrant for each training session at the registrant’s 

sole discretion. If such labels are provided, the trainer should let the 

applicators at the training session know that they are available. 
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vi. Trainers should state that all testing materials will be collected at the 

conclusion of the exam. A passing score of 70 is required for each 

module. 

vii. Trainers should notify participants that the exams will be graded and the 

results sent to Achieva for inclusion in the Achieva database. They should 

also discuss the likely length of time before their testing scores for the 

modules will be available in the Achieva database. This length of time 

should be estimated by the registrant giving the training program based on 

that registrant’s process for grading exams for that particular training 

session. In no event should it exceed four weeks.

viii. Next steps if a notice regarding the exam scores and/or Proof of 

Completion documentation is not received by four weeks following the 

training session should be discussed. Trainers should state that applicators 

who have not received such notice four weeks after completing the 

training session should contact the registrant sponsor of the training and/or 

the Achieva help desk at [phone number].

ix. The ability to take additional active ingredient modules on-line should be 

discussed. This discussion should provide the site name where the 

training can be taken and should note that new Proof of Completion 

documentation will be issued when additional active ingredient modules 

are separately completed, but that these new Proof of Completion 

documentations will expire three years from the date of the completion of 

the initial training (completion of the four general modules plus at least 

one active ingredient specific module), regardless of how many additional 

active ingredient modules are added or when they are added. 

4. Proof of Completion Documentation: Registrants must obtain from each person taking 

the hard copy in-person exam contact information that will allow the exam results and 

Proof of Completion documentation to be provided to that person. If possible, both hard 

copy address and email information should be obtained, and at least one of these must be 

obtained. For those participants who provide email information and who pass the test, 

Achieva will email the Proof of Completion documentation to them shortly after Achieva 

enters that information in its system after receiving it from the registrant representative 

who graded the exam. For those who do not have an email address, the Proof of 

Completion documentation will be mailed via United States Postal Service regular mail 

delivery. There will likely be a two to four week length of time between the close of the 

training session and the issuance of the Proof of Completion documentation. Applicators 

who have not received Proof of Completion documentation four weeks after completing 

the training session should contact the registrant sponsor of the training and/or the 

Achieva help desk. 
SFATP In-Person Training Protocol

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Trainers should explain that the Proof of Completion documentation includes the 

following statement: “This document serves as proof of completion of the U.S. EPA 

required training for soil fumigant applicators. A copy may be attached to applicable 

FMPs to comply with the label requirement for documentation of completion.” The 

Proof of Completion documentation that the student will receive from Achieva will have 

two pages. One will be an 8.5 x 11 sheet that can be attached to a Fumigation 

Management Plan (FMP). The second page can be trimmed to a wallet sized card. 
1 Attachment 

Rick --

Appended is the protocol for the registrant in-person training program. As always, please let us know if there are 

any questions or if discussion would be helpful.

LISA M. CAMPBELL

B E R G E S O N & C A M P B E L L P C

2200 Pennsylvania Avenue, N.W. Suite 100W | Washington, D.C. 20037

T: 202-557-3802 | F: 202-557-3836 | M: 703-302-0491 | lawbc.com

Soil Fumigants: Registrants' Applicator Training Program -- Protocol for Registrant InPerson Training Program 

Lisa M. Campbell 

to: 

Richard Keigwin 

09/26/2012 10:19 AM 

Cc: 

John Leahy, Cathryn Britton, Steven Weiss, "'Sara Beth Watson, Esquire'", "'Tracy A. 

Heinzman, Esquire'", "'Roger H. Miksad, Esquire'", "'David E. Barnekow '" 

Hide Details 

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

To: Richard Keigwin/DC/USEPA/US@EPA 

Cc: John Leahy/DC/USEPA/US@EPA, Cathryn Britton/DC/USEPA/US@EPA, Steven 

Weiss/DC/USEPA/US@EPA, "'Sara Beth Watson, Esquire'" <swatson@steptoe.com>, 

"'Tracy A. Heinzman, Esquire'" <theinzman@wrf.com>, "'Roger H. Miksad, Esquire'" 

<rmiksad@wileyrein.com>, "'David E. Barnekow '" <debarnekow@dow.com> 

00101089.PDF

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