AAPCO Worker Protection Committee 

State Lead Agency Comments

August 29, 2007 

C&T 1: Expand scope of applicators subject to regulation 

California Comments:

The purpose of proposing a change to federal regulation of certification and training and 

worker protection is to raise the minimum federal standards that many states have already 

moved beyond. Certifying occupational “for-hire” and “not-for-hire” pesticide users as 

described in Option 1, goes far beyond raising the baseline standard and moves to a level 

of pesticide use certification that is more of an ideal goal. Setting interim objectives or 

standards seems more achievable and more appropriate in setting minimum federal 

standards. C&T 1 would also be more compelling if it included illness or exposure 

statistics to help justify the need to establish competency requirements for occupational 

“for-hire” and “not-for-hire” pesticide users. Implementing Option 3 “Review state 

regulations and certification plans for applicators and consider their approaches as a 

model for a national baseline.” may be the best approach because it provides working 

examples of standards that are being implemented and can work today. 

Certifying occupational “for-hire” and “not-for-hire” pesticide users as described in 

Option 1 would likely result in a program requiring a significant increase in resources 

currently devoted to C&T. For example, California certifies approximately 24,000 

commercial applicators operating in agricultural and landscape environments (non 

structural) and oversees certification of private applicators at the local level that number 

slightly less than 20,000. All pest control businesses must have a certified applicator 

whether they apply restricted or general use pesticides and the applicator may supervise 

non-certified applicators in the use of RUPs. California also requires employers to have a 

written training program for all employees handling any pesticide (exceptions include 

users of certain vertebrate pest control baits, antimicrobials and pool chemicals who must 

comply with a set of industrial safety regulations enforced by a different agency). 

Currently, the population of pesticide users that include private applicators doesn’t 

require certification when using general use pesticides. Although private applicators are 

required to maintain the written training program described above for any employees, 

there is no exam as a competency gauge for using general use pesticides. Establishing a 

competency requirement, such as an exam for all production and non-production 

agricultural users (owners or operators of property) would be a significant improvement 

in establishing competency of pesticide users. The exam would test for competency of 

general pesticide safety and label comprehension. This would allow the competent 

pesticide user (owner or operator) to supervise others involved in pest control just as 

certification does. Even this step would require significant resource commitment and 

would likely increase the tested applicators significantly. This expansion of competency 

testing in combination with the requirement for a training program is a significant 

improvement and does not require measuring competency at the “hose level” with an 
exam. Effectiveness of the training program would be determined through State and 

local enforcement programs. 

California has taken the training and outreach approach into the urban pesticide use arena 

as well. The School IPM program is reaching out statewide to school district 

maintenance representatives through workshops that describe and demonstrate reduced 

risk and pest prevention practices. A similar effort is underway to train social services 

workers that interface with child day care facilities in basic pest prevention and safe 

pesticide use practices. 

Indiana Comments:

Indiana believes the agency can’t rely on “industry and private sources” for training 

materials, exams or other competency gauges. Several industry sectors may not be 

prepared to develop such items. 

While some additional expansion may be warranted, I do not believe there is data to 

support the assumption that ALL occupational users need certification. 

Support item 4 (page 12): Improve pesticide labeling to address risks from occupational 

users. 

Page 13, Other questions for consideration: 

A- Indiana has difficulty in reconciling the fact that the agency was dissuaded by states 

that were concerned handlers could not pass an exam and the fact the agency wants to 

certify occupational users. While being able to pass an exam and competency do not 

always go hand in hand, the inability to pass an exam is reason enough not accept 

someone as being minimally competent. 

B-Easy is better. Indiana is opposed to requiring the occupational user be fully certified 

to the standard they have for “for hire’ applications. 

North Carolina Comments:

Option 4 Improve pesticide labeling to address risks from occupational users 

EPA must consider revisions to 40 CFR 171 to reflect the widened scope of current 

programs. EPA should provide an official recognition of the need to ensure that all 

persons who apply pesticides (not just RUP’s) as part of their occupational 

responsibilities or activities have received pesticide education and safety training. 

EPA’s label improvement program is the cornerstone for educating the non-RUP user 

homeowners, and other non-traditional C&T program persons and should be utilized to 

this end. State resources are limited. Program expansion to include the non-traditional 

C&T program person would diminish our already strained program capabilities to meet 

EPA goals due to limited resources. 
Option 7 Emphasize Hazard Communication training 

Again Hazard communication training can also be provided on the labeling of products. 

In occupational situations, the owner generally provides application, equipment training, 

and other safety training required by DOL OSH. Educational and training programs 

should be conducted by the employer. 

Florida Comments:

Other questions for consideration: 

A. Should agricultural handlers be required to demonstrate competency? The 

Agency considered this option, but were dissuaded by concerns raised by the 

states for their ability to pass an exam. The same states felt that the handlers were 

competent. 

In Florida with a Hispanic Trainer doing a bilingual review of the exam material 

prior to the Handlers taking the exam we have approximately a 25% success rate of 

Hispanic Handlers taking exams (based on 95 exams taken within the last 12 months 

given by Cesar Asuaje who is coordinating this training program). 

Considering those results, it would appear that the time and expense that an 

Employer would have to spend on a Handler, that may or may not be a permanent 

employee, would be a huge burden. Based on violation rates, it would appear that 

Handlers are competent. (That is based on possible violations that would involve an 

incompetent handler, including reported exposures to other workers by 

misapplication, etc.) If it was documented that Handlers are not competent then, 

reviewing the training material, the amount of required training, and frequency of 

training versus demonstrating competency through exams might be a more realistic 

approach. 

B. How to best identify occupational pesticide applications that have the potential to 

impact sensitive populations or environments? 

For sensitive environments, one source of information to determine what would be 

considered sensitive would be the Endangered Species Act; another source would be 

the EPA Clean Water Act. So all surface water could be considered sensitive, and 

Natural areas where Endangered Species are listed would be another possibility. In 

those situations, using the Primary Categories, categories that would include 

applications to either surface water or areas most likely to have endangered species 

such as the Aquatic Category, or the Natural Areas Weed Management category 

would be obvious choices for consideration. Other areas that would be impacted by 

the Endangered Species or the Clean Water Act such as Right-of-Way and Private 

Applicators would be dependent on the location of the applications and the labeled 

products they are using. 
At this time there are no Restricted Use Pesticides registered for aquatic application 

sites in Florida. However, because of the Aquatic Industry’s initiative we have 

approximately 2200 applicators licensed in the Aquatic category. It would appear 

that to have some type of license, whether a certified RUP applicator or a 

credentialed applicator for GUP applications would be extremely cost prohibitive 

for the state lead agencies as well as the Extension offices that assist with the 

training and in some cases exam proctoring. This would appear, at least for the 

aquatic applicators, to be unnecessary. Providing funding to assist the industries, 

such as the aquatic applicators, to increase training would be a more useful use of 

funds. Other industries in Florida that might be impacted by the environmental 

sensitive areas, such as Natural Areas Weed Management and Right of Way would 

also benefit with a partnership promoting industry initiatives in training and 

licensing. Currently Florida has 1858 certified Right of Way Applicators and 680 

certified Natural Areas Weed Management, with the Natural Areas Weed 

Management being the fastest growing category in Florida. 

For Sensitive Human Populations, pest control applications would be an obvious 

choice. In Florida, all persons making applications to or around homes or businesses 

are already licensed through competency demonstration. Therefore, this would be a 

redundant regulation in Florida. 

C&T 2: Protect human health and the environment by ensuring that occupational 

applicators of potentially harmful pesticides pass a reliable certification exam that 

determines their competency to use pesticides safely 

California Comments:

Option 3 comes closest to an appropriate baseline standard. However, a program that 

tests and certifies private or commercial supervisory or responsible- level staff and 

requires an enforceable training program for all handlers should be considered adequate. 

If there is evidence of failure of the training program and the program can’t be improved, 

testing would be one option to consider. Testing of all for hire applicators would pose a 

significant resource burden, notwithstanding the statement made in the issue paper’s cost 

analysis. It would likely triple the demands on DPR’s Licensing and Certification unit. 

Indiana Comments:

Agree that written exams are our best method for determining competency. However, I 

am not convinced that all applicators need full certification. Additionally I am 

unconvinced that the agency can adequately define sensitive versus non-sensitive sites. 

North Carolina Comments:

Matrix Option 2 ensures that a level of pesticide safety training will be provided for 

applicators of pesticides. This option takes into consideration the wide variety of job 

assignments which dictates the risk exposure potential. 

While it is apparent that testing the “not for hire applicator to non-sensitive sites” 

(handlers) would not demonstrate competency, EPA should consider a pre- and post- 
evaluation instrument that to be used by the handler’s employer to better assess 

information retention and material acceptability similar to the private applicator option. 

Consideration here should be given to the fact that a handler has a higher probability of 

pesticide exposure based upon a given job assignment. 

By EPA’s measure, approx. 78% of states require competency exams for the private 

applicator. Consideration by EPA to support and strengthen SLA’s efforts by 

“implementing control elements such as a minimum time devoted to each competency 

standard, etc.” falls short of several existing SLA certification/recertification programs 

for private applicators. And, with the testing limitations set by FIFRA, EPA should 

consider addressing additional resources to the states for program expansion. 

Florida Comments:

Additional Questions for Consideration: 

1. Are there other gauges of competency in addition to written or practical 

examinations? If so, please provide examples, data on how they might be 

administered, anticipated burden and any other relevant information. 

I have no suggestions for additional gauges of competency. I do feel that time in 

class room can be a substitute in some situations for determination of competency. 

For example recertification of licensure, in that they have already demonstrated 

competency. 

2. Should different (more specific) CORE exams be developed for certain segments 

of applicators, such as not for-hire in sensitive sites and for-hire technicians? 

No, I believe that having one basic CORE for all exams sets the base of the gauge of 

competency. It is also simpler and more stream line, and therefore minimizing 

confusion and mistakes. 

If for these new categories you chose to include additional questions, not specifically 

a separate exam, but additional questions that could be included for the credential 

applicators with information specific to their applications that would be more 

appropriate then having more then one CORE exam. 

Suggested adjustments to be made to CORE exams would be appropriate along the 

lines of developing the Nation Pesticide Applicator Certification CORE Manual and 

Exam. Because pesticide applications are not the same across the 50 states and the 

holdings, and based on the requirements mandated to use the National CORE and 

Manual, Florida has opted not to use the National CORE Manual or Exam for our 

certification program. However, in updating our CORE exam and manual we did 

use the National Model as a resource. 

However, without significant additional funding for training, exams (preparation, 

printing and resources to provide/proctor the exams), and licensing, Florida would 
be unable to handle the additional applicators. Also in Florida part of this 

regulation would be redundant with our Entomology and Pest Control Program. 

3. Do you see any benefits or drawbacks to allowing all for-hire users of pesticides 

to be able to purchase, use and supervise the use of RUPs after they have 

demonstrated competency? Why? 

By requiring everyone who uses a pesticide (GUP or RUP) to be licensed would be 

the most cost effective, simplistic version that would ensure that everyone 

purchasing a pesticide (GUP or RUP) be competent. 

However, without significant additional funding for training, exams (preparation, 

printing and resources to provide/proctor the exams), and licensing, Florida would 

be unable to handle the additional applicators. Also in Florida part of this 

regulation would be redundant with our Entomology and Pest Control Program. 

C&T 3 Improve standards for the use of restricted use pesticides by uncertified 

applicators working under the direct supervision of a certified applicator 

Indiana Comments:

Not opposed to option 3, as IN currently requires examination and that supervisors 

provide specific information to the applicator (technician). 

Have strong reservations about creating “levels of supervision”. Disagree strongly with 

“base the required level of supervision o the specific pesticide applied and use the 

pesticide labeling to establish the level of supervision.” The agency has never 

demonstrated the ability to write a label that can be comprehended by the applicator or 

that is enforceable. To use the already poorly written label as a guide to supervision 

would be building one problem upon another problem. The pesticide label is the quick 

sand foundation of the agency. Do not build upon it. 

Having levels of supervision compounds the difficulty in trying to interpret and enforce a 

regulation. To have any chance of success, a regulation must be simple. 

North Carolina Comments:

Minimum training requirements for the uncertified applicator working under the direct 

supervision must be established. Training for this individual to at least the WPS handler 

level lessens the possibility of pesticide exposure. This individual is more likely to be in 

work situations where the certified pesticide applicator (supervisor) is not immediately 

available during an emergency. 

Special training emphasis may need to be placed on certain aspects of training based 

upon the job/tasks, for example drift management and emergency spill cleanup and 

containment procedures. 
Consideration should be given by EPA to design a pre- and post training assessment tool 

to gauge competency based upon job responsibilities, general pesticide safety and 

emergencies procedures. 

Florida Comments:

Questions for review 

1. Private versus commercial applicators 

Some States currently have different “under the supervision” requirements for private and 

commercial applicators. Uncertified applicators in the agricultural setting applying the 

“under the direct supervision: are handlers applying UTS of private applicators. The 

WPS currently requires that handles receive training in 40 CFR 170.230 “Pesticide safety 

training for handlers.” 

Is this adequate? The agency is gathering information from the state plans and 

regulations related to these questions. 

Yes, it would appear that based on violation rates, pesticide safety training and UTS 

is working. We are not noting significant violations in areas that would 

demonstrate that the Handlers are not receiving appropriate training or supervision 

of applications. Violations that might demonstrate a lack of competency of the 

Handlers or an inadequate supervision would include significant rate of worker 

and/or handler exposure to pesticides or label rate violations. These are not the 

largest percentage of violations being noted in Florida. During a routine or for 

cause inspection in Florida a percentage of workers are interviewed, with all efforts 

being made to interview the workers in their native language. We are not reporting 

workers stating that they have been exposed to pesticide applications. During every 

pesticide use inspection conducted in Florida a minimum of one Handler is 

interviewed, and we are not documenting violations that would demonstrate that 

training or UTS is not working. Rather, it would appear that it is working, 

especially in the areas involving restricted use pesticides, in that the applicator 

understands that they have a level of liability for all RUP applications made under 

their license. 

In Florida the Cooperative Extension Agency in connection with the University of 

Florida and the Florida Department of Agriculture are making efforts through 

hiring a bilingual WPS coordinator (employed by FDACS) to work with the three 

agencies, and UF/IFAS employing bilingual trainers to work with the industries 

assisting in training Workers and Handlers and have a program training Handlers 

in bilingual programs to attempt to increase the Handler’s comprehension of 

English so that they can pass their exams to obtain certification for the application 

of RUPs. In conjunction with the WPS requirement for safety training, this will 

hopefully minimize the need for UTS through education and licensing, as well as 

increasing the number of licensed applicators to be available in situations where 

UTS will be needed. 
At this time we have a low rate of successful passage of these Handlers 

(approximately 25%), however, this program is only a little over a year old at this 

point. However, based on the WPS requirements for training of all Handlers and 

the new bilingual studies we have seen an increase of Handlers attempting to take 

the exams for certification. 

2. Tiered requirements 

Under the 1990 C&T proposed revisions, the proposal to amend “application under direct 

supervision” was for tiered requirements, based on EPA review of the uses and their 

risks. Again, further review of state regulations should inform this option. 

Should experience be considered as a component of competency? For example, an 

applicator with 5 years experience may require less supervision than a new hire. If 

different levels of competency are acknowledged, appropriate levels of supervision could 

be assigned. 

Yes, experience should be considered as a component of competency. A business is 

not going to continue to employ people to work with pesticides that do not continue 

to demonstrate competency. So, the market itself has a self regulating aspect to it. 

In Florida we have a growing number of Handlers that are now working with 

FDACS, UF/IFAS to attend bilingual trainings to prepare to take their RUP license. 

Most of these are Handlers that often have 5 years or more experience (usually 

much more then 5 years). Using experience as one of the tools for a tiered 

requirement for direct supervision would be a useful tool to the agriculture industry 

in that it would assist the owners and licensed applicators to focus more of their 

supervision on those Handlers with the least amount of experience. It would also 

assist in promoting the industry to support those Handlers with 5 or 10 or more 

years of experience to attend trainings to assist to prepare the Handlers in passing 

their exams and becoming licensed applicators, minimizing the need for direct 

supervision. 

Working in conjunction with the agriculture industry in these areas would be a 

more cost effective way to increase safety and bring about compliance versus 

mandating licenses, that at this time, many of our Handlers are unable to pass. To 

attempt to mandate that everyone using a pesticide be licensed would be cost 

prohibitive without significant increase in funding. However, providing a portion of 

that money assisting in funding more programs working with Handlers and other 

unlicensed applicators, especially those with significant experience (5 years or more) 

would be a more cost effective way to achieve compliance. Working with the 

experienced Handlers by giving them an opportunity to increase their knowledge 

along with their experience helps to make them a more valuable employee to the 

owner, which in turn hopefully will promote the industry in supporting their long 
term employees efforts to increase their knowledge and become licensed, which 

should minimize the need for direct supervision. 

C&T 5: Establish a minimum age for occupational pesticide applicators 

California Comments:

Option 1, to establish a minimum age of 18 to purchase, handle or apply pesticides 

occupationally, is the most appropriate option. The issue paper establishes a strong case 

for not allowing minor children to purchase, handle or apply pesticides. Reasons include 

children’s sensitivity to hazardous chemicals, federal labor law that prohibits children 

under 16 working in agriculture from applying Category I or II toxicity pesticides with 

the exception of those working on family farms, and no exception for children under age 

16 involved in non-production agricultural and non- agricultural pesticide applications. 

Children under the age of 18 are not responsible for their actions therefore violations of 

laws and regulations would involve parents or guardians and add a level of complexity to 

enforcement and collection of penalties. 

Indiana Comments:

Have no objection to a minimum age, however I do not want to see multiple ages or 

exemptions for farms, family businesses etc. Again, keep it simple. If an age limit is 

warranted due to toxicological concerns, it is warranted for farms and family businesses. 

If training and testing suffice to assuage concerns regarding exposure, then the age limit 

should be at the lower end of the scale (16), regardless of the chemical. 

North Carolina Comments:

Option 4 provides for the minimum age of 18 to purchase, handle or apply pesticides 

occupationally. It also allows for an exemption allowing private applicators no younger 

than 16 in specific situations. 

The minimum age requirement should be established as a prerequisite for applicator 

certification along with the ability to read and comprehend the English language in 

addition to having related job experiences. Specific guidelines/ definitions for hardship 

exemptions must be clearly stated to assure consistency. 

States must have the ability to develop the exemption process with oversight by EPA and, 

to apply all regulations to the exempted private applicator. 

Florida Comments:

Questions for consideration: 

1. Why would you support or not support an exemption for family farms? 

I would support the exemption for family farms. In most cases it would appear that 

children growing up on the family farm are working in a limited known 

environment. Because they have grown up on the family farm they will most likely 
have experiences in that business that hopefully provides them with more informed 

decision making processes based on that experience. 

Also this will minimize any hardship to the family business, which by definition is 

only made up with immediate family members, and therefore a much smaller pool 

of resources. 

2. Do you have a suggested definition of family farm besides the Fair Labor 

Standards Act definition? 

No, I think keeping the family farm exemption limited to immediate family is the 

best way to ensure that those people who are exempted from certain WPS 

requirements have experience from growing up on the family farm, and would 

therefore the experience, and be in a limited known environment to allow for 

hardships to families, and at the same time provide the most regulation for health 

risks.

3. Should a family exemption extend beyond agricultural use? How would it be 

defined? 

No, by definition this limits pesticide applications to the families own farm 

(property) and would not include for hire applications. Allowing an exemption for 

children to assist in the family farm, takes into account that the child has experience 

working on that establishment and applications will be made in a limited known 

environment. Extending that application to other family businesses that could 

include for hire applications made in all environments would go against the 

documentation for health risks. 

C&T 6: Standard Exam Development and Administration Requirements (Standardize 

exam requirements) 

Indiana Comments:

Supports secure exam requirements (option 1). 

Still maintain that states know what is content relevant, through the process of exam 

development. 

Other questions: 

Support electronic testing, provided adequate security and proctoring is available. 

North Carolina Comments:

Section 11 of FIFRA requires revision to require that competency in the use and handling 

of pesticides will be determined on the basis of a written examination. 

More than 78% of the state programs have testing development and administration 

requirements in place. The agricultural industry and general public have adapted to this 
means of determining competency and credibility to protect human health and the 

environment. If EPA is prepared to standardize exam development and administration 

requirements, then EPA should strongly consider revising the FIFRA to better reflect and 

address the need to meet national competency standards. 

Most states attempt to include the subject matter listed in 40 CFR 171 in the exam. This 

inclusion is not required. Certification exams should reflect, at a minimum, the content 

matter of the CFR. Training should better reflect CFR content subjects. Training 

materials should be developed when new categories are established or additional 

conditions are placed on certain pesticide use and definitely as the technology changes. 

With that stated, training materials and certification exams should be updated 

simultaneously. This would require close coordination between agencies, but it would 

assure that exams accurately test topics that are covered by training manuals and sessions. 

Implementation of this validation process tests knowledge in tasks necessary to perform 

as an applicator. 

Training materials and programs produced by independent organizations must also be 

considered here. EPA should give consideration to develop a process that allows for 

consistent review and oversight of such materials. In doing so, states, pesticide trainers 

and educators would more likely accept the materials. 

Reciprocity agreements would be more readily accepted nationally if the ground rules for 

certification are established with similarities. 

Florida Comments:

Additional Questions for Consideration: 

1. Are there other options to standardize exam development and administration that 

were not considered? 

Another option then the one presented is to allow states to use the National Pesticide 

Applicator Certification Core Manual and Exam as a basis to be adjusted on an as 

needed basis per state to adjust as regulations and pesticide applications vary per 

state. By requiring the National Manual and Exam to be used as is or not at all, 

forced Florida to opt for the not at all. 

2. Why would you support or not support electronic testing at remote sites, such as 

departments or mother vehicles? Are there controls that should be implemented if 

this option is considered? 

I would not support electronic testing at remote sites because of ease of access to the 

applicator. Using a site such as a motor vehicle office would be a great hard ship on 

the applicator, in that they would have to make an appointment to the convenience 

of the motor vehicle office, not the grower. In Florida these offices are already 

beyond maximum capacity, and therefore, even with an appointment, an applicator 

wishing to take an exam would be looking at loosing a complete day to try and get 
an opportunity to take the exam. I can not name any agency in Florida that would 

be able to handle the additional burden of providing computers and staff for testing 

of applicators. 

At this time we are still using paper tests and contract UF/IFAS to proctor the 

exams. Using the Extension Offices, the grower is able to attend training programs 

to review materials to assist with taking the exam as well as follow up training to 

renew their license. They have the resource of the Extension Agent and in most 

cases an extensive library of material related to their industry for assistance in all 

aspects of the applicators business. And finally is a familiar location that is usually 

in the general area as the agriculture establishment. If the extension office had the 

availability of computers, then I would support a choice to growers for a paper 

exam or an electronic exam. However, without significant additional funding for 

computers, software, etc. this would not be feasible. 

C&T 7: Better Protect Human Health and the Environment by Establishing National 

Standards for Recertification that Cover Core Competencies as well as the Changing 

Field of Pesticide Application (Period and gauge for recertification) 

Indiana Comments: 

Disagree that both core and category requirements are necessary for recertification. A 

recent Indiana work group concluded that core material was routinely covered in nearly 

all recertification programs. 

Oppose agency requirements for recertification (class content, number of hours etc.). 

Agree that positive identification should be required for participants. Online certification 

permitted only if identification can be verified (live web casts with proctor, for example). 

Support a 5-year certification cycle. 

North Carolina Comments:

Consideration for revising the 40 CFR 171 to address a recertification period would 

better support EPA’s goal to protect human health and the environment. 

Option 1: Set a federal recertification period... 

Implementing federal standards for recertification would ensure that all pesticide 

applicators meet national competency standards, raise the standards of applicators, 

mitigate exposure risks, and increase the public’s confidence. This standard should 

establish an acceptable range for any national certification period with clearly stated 

recertification options, in order to take into account the disparities among State program 

resources throughout the Nation. At a minimum, prerequisites for recertification could be 

established as suggested below. 

Continuing education program is value added to the competency of applicators by 

allowing them to select courses that specifically target educational needs pertaining to the 

safe use of pesticides, technology, application techniques, and industry networking. 
Applicators would be required to obtain a specific number of category-specific credits 

and core credits to satisfy the requirements of recertification during the recertification 

period. Continuing certification credit cannot roll over into the next period. Failure to 

obtain the appropriate number of credits must retest. 

Another feasible alternative would be to require that any program approved for 

continuing certification credit should cover both “core” and “category specific” 

information. States should be given this as an option.

Florida Comments: 

Questions for Stakeholder Consideration 

1. What do you think is an appropriate recertification period? Why? 

Four years. I also think that the certification period and expiration of the license 

should be the same. Some states certify Applicators for one time period but then 

their licenses expire every 12 months. This is extremely difficult to deal with in the 

cases of reciprocal licenses, so Florida set our policy that a reciprocal license will 

only be good as long as the license expiration date. 

I think 4 years is reasonable length for an applicator to hold a certificate for the use 

of RUPs. Generating licenses once a year could bring in more income to the state, 

but would be an onerous burden on the applicator as well as the certification staff. 

Two years is the same situation. Five years is getting onto the long side if you need 

to take action against an applicator. Four years also seems like a fairly standard 

time period, and also relates well into those states that have cooperative agreements 

with Universities. 

2. Should private & commercial applicators have the same recertification period & 

Requirements? Why or why not? 

Yes, Reasoning behind this, is because we have applicators that may hold more then 

one category in their commercial license. For example, we have many applicators in 

Florida who hold Aquatic, Right of Way, Natural Areas, Forestry and Ornamental 

& Turf Categories. Having different recertification periods for different categories 

would be onerous on both the applicator and the certification staff in trying to 

recertify licenses. I agree that some categories such a fumigation have the potential 

to pose a higher risk to humans, and Aerial, Aquatic or Natural Areas have the 

potential to pose a higher environmental risk, but this is a certification to apply and 

supervise the application of Restricted Use Pesticides, and by holding all applicators 

to the same high standard will help us to assure that we do all we can through 

licensing and education to minimize the potential of human hazard and 

environmental hazards. 
3. Do you support separate requirements for recertification in core competencies 

versus category-specific information? Why or why not? 

No, I feel that testing initially to issue a certification/license allows us to set 

minimum standards for competency. However, once an applicator has 

demonstrated that competency, I believe that promoting an applicator to take CEU 

courses so that they are exposed to the newest and most up-to-date information 

concerning their industry is a better way to protect the applicators, the industry and 

the environment. Technology is a driving force allowing the industry to provide 

safer chemicals, application/mixing equipment and provide quicker feed back on 

potential problems. Through CEU programs it assists the applicators to take the 

time from their business to attend programs and to learn this information. In 

Florida applicators have the choice to renew through re-testing (which is the same 

test they may have taken when they obtained their license) or obtaining CEUs. By 

far the majority of our recertification of applicators is through CEUs. Because this 

is not a perfect world and we are working with industries that are affected greatly 

by natural as well as man made forces, it may not always be possible for an 

applicator to obtain all of the needed CEUs to renew, and in those cases it is 

important that they are able to continue their license and maintain their business by 

retesting. The concept of testing to demonstrate minimum competency in core 

information as well as in category exams should exist for both initial certification as 

well as for recertification. First reaction is to require a different test and a higher 

level of competency for those recertifying, however, everyone who is certified to 

apply RUPs should be able to demonstrate the same high level of competency. 

Because our certification period is 4 years, it is possible that they will be taking a 

new test if they choose to recertify by testing. It is also highly unlikely that because 

they passed the test 4 years earlier, that they would necessarily have any advantage 

in retaking the test, and again. 

4. Should positive identification be required of participants in recertification 

programs? 

Yes, to ensure that the person who is either retesting or attending CEU programs is 

the same person who originally obtained the license. There are many different 

locations in the state where an applicator can attend CEU programs for their 

recertification or to retest, and because of the number of applicators in the state 

every applicator can not be known by the trainers or exam administrators. This 

would assist in minimizing cheating. 

5. Should online recertification programs be permitted? Under what circumstances? 
Yes, because of location, work responsibility, etc., not all applicators have the ability 

to attend enough CEU programs to renew their license with all the categories. Also, 

by allowing online recertification programs, we are allowing our applicators to take 

training to not only recertify their license, but also to promote applicators to keep 

up to date on the latest information in their industry. There are problems with 

online recertification in that there is no way to ensure that the person taking the 

online class is the actual applicator. However, I feel that the benefits of online 

classes outweigh the negative of those who choose to get around the system.