Revised - October 17, 2003

Issue Paper

Requiring Written Examinations for Approval of State Certification Programs

The pesticide applicator certification program is undergoing an assessment through the

cooperative effort of the Cooperative Extension Service, State Lead Agencies, and the EPA to

determine what changes should be considered to improve professionalism of certified applicators

(Certification and Training Assessment Group, CTAG). One recommendation is to require

proctored, written, closed-book examinations for both private and commercial applicators of

restricted use pesticides. Proctored, written, closed-book exams would become a

requirement for approval of state certification plans.

Background:

Most states currently require exams to ensure competency. A survey was conducted for this

assessment by the CTAG with all but one state responding. The results show that 78% of states

require exams for private certification and 90% of states require exams for commercial

certification. Those requiring closed-book exams were: 64% for private and 90% for

commercial certification; respectively, 76% and 82% required written exams.

It is a common misconception that Section 11 of the Federal Insecticide, Fungicide, and

Rodenticide Act (FIFRA) prohibited testing of private applicators. Under section (a)

CERTIFICATION PROCEEDURE (1) FEDERAL CERTIFICATION – In any State for

which a State plan for applicator certification has not been approved..., the Administrator,...

shall conduct a program for the certification of applicators of pesticides. Such program shall

conform to the requirements...under the provisions of subsection (a)(2) of this section and shall

not require private applicators to take any examination to establish competency in the use

of pesticides. (emphasis added)

Because this requirement falls under the federal certification portion of FIFRA, states can require

examinations of private applicators when not prohibited by state law. Requiring a proctored,

written, closed-book exam will facilitate consistency across the country and more effectively

help to ensure competency of applicators. A proctored exam will help to minimize cheating,

improve exam security and preserve the integrity of the exam; a written exam will help to

standardize and document competency testing; and a closed book exam will help to ensure that

those who pass the exam are able to demonstrate a good grasp of the competency standards.

Several issues need resolution should mandatory testing become a requirement for state

certification plan approval.

1. Will making a proctored, written, closed-book exam part of the requirements for an approved

state certification plan, require changes in federal regulations? If not, how will this be done?
Revised - October 7, 2003

2. Should a state be unwilling or unable to implement such a requirement, is the EPA willing to

step in? What other options are available?

3. What problems are created for those states (16%) that currently do not require proctored,

written closed-book exams for private applicators? What should be the time frame for

implementation of this requirement? What tools are available to help those states develop a

quality exam and the associated study materials?

This issue paper was discussed at the 2003 North American Pesticide Applicator Certification

and Safety Education Workshop in Hawaii. It was the consensus of Workshop participants that

the phrase closed-book should be defined. As used in this paper “closed-book” means not

allowing an exam candidate to bring in any reference materials as an aid to the exam. Allowing

candidates to bring into the exam session their own reference materials potentially destroys

exam security since a candidate could both bring in “cheat sheets” and other prohibited

materials and take away from the exam session details of exam questions. Any state that wishes

to test the knowledge, skill, or ability with the aid of reference materials can simply supply the

required reference materials to candidates during the exam and still maintain the integrity and

security of the exam. Such reference materials may include pesticide labels, pest damage or

other specimens, or other materials necessary to test a desired knowledge, skill or ability.

Candidates should not be allowed to remove such reference materials from the exam room.

Reference materials should not include information that should be committed to memory, such as

the core knowledge requirements.

Recommendation:

The EPA should implement proctored, written, closed-book exams as a requirement for approval

of a state plan for the certification of private and commercial pesticide applicators. This should

be implemented over a three to four-year period to allow those states that currently do not require

proctored, written closed-book exams to implement the requirement. The national core exam

and associated training materials (EPA/PMRA Pesticide Applicator Core Examination and

National Core Manual) will be available for use by all states, including those states that do not

currently require proctored, written, closed-book exams.