As pesticide applicators and educators around the country become aware of proposed changes by the EPA to pesticide applicator certification and recertification training requirements, there is concern that the increased requirements will break the training systems in place and unintentionally result in decreased pesticide safety. Recently Dr. Mary Ann (Mimi) Rose, coordinator of the OSU Extension pesticide safety education program, provided the following brief synopsis of the proposed rule changes:
The Environmental Protection Agency (EPA) has proposed a minimum age (18) and stricter standards for certifying applicators of restricted use pesticides (RUPs). For commercial applicators in Ohio, there is no distinction between RUP and non-RUP users, hence these new proposals potentially affect the certification and recertification of all licensed commercial pesticide applicators in Ohio whether or not they actually use restricted use pesticides. Private applicators are only required to be licensed in Ohio if they use RUPs.
Much of what is proposed for the stricter federal standard is already required by Ohio Law; for example, Ohio pesticide applicators already take closed book exams, must recertify on a three-year schedule, and keep pesticide records. The proposed changes would however significantly increase the recertification requirements for Ohio pesticide applicators. The EPA has proposed that all applicators will be required to take six units ( one unit is defined as equal to 50 minutes) of core plus three (private) or six (commercial) units per category every three years. An Ohio commercial applicator licensed in one category who is now required to take five hours of recertification would have to attend twelve 50-minute sessions every three years. An Ohio private applicator licensed in one category who now needs 3 hours of training to recertify would have to attend nine 50-minute sessions every three years. Applicators would be required to present identification at exams and recertification programs. For private applicators, the fumigation category would be split into soil and non-soil fumigation categories. There also would be an annual training requirement and minimum age of 18 for trained service persons, who under current Ohio law only require a single, verified training prior to occupational exposure to pesticides.
The public may comment on the EPA’s proposal through November 23, 2015; there have been formal requests for an extension to the deadline. Comments may be submitted to the EPA at http://www.regulations.gov in docket number EPA-HQ-OPP-2011-0183. Learn more about the proposal and certification for pesticide applicators at: http://ow.ly/TN9HH.
Looking at the proposed private applicator recertification requirement from the perspective of providing training education, I can say that many applicators in Wayne and Holmes Counties carry 3 categories on their license. That means that they would have to attend 15 units of recertification training, which equals 750 minutes or 12.5 hours. The current 3 hour requirement is doable in an afternoon class, obviously the proposed requirement would not be. In addition, there is a limited amount of new information and technology generated that provides new teaching material. The EPA proposed increased requirement will bring about an increase in the use of repetitive material, never a good thing to inspire learning or to keep the attention of the pesticide applicator. I believe the hope is that Department of Agriculture officials, pesticide education program coordinators and pesticide applicators provide enough comments to the EPA to result in more practical and realistic changes, but time will tell.