Pesticide Applicator Certification and Training for Soil-Fumigation Category/Subcategory
Current as of November 2012
EPA is requiring important new safety measures for soil fumigant pesticides to increase protections for agricultural workers and bystanders -- people who live, work, or otherwise spend time near fields that are fumigated. These measures are for the soil fumigants chloropicrin, dazomet, metam sodium/potassium, and methyl bromide.
The Certified Applicator Training requirement is being implemented during the second of two phases of mitigation implementation. When new Phase 2 fumigant labels begin appearing in the market place in late 2012, fumigant users will need to comply with this new requirement.
Note that compliance with the label-required training is a condition of product use. Because soil fumigants are Restricted Use Products, only certified applicators may purchase them. Contact the registrant about additional requirements they may have for persons purchasing their products.These Questions and Answers about the new certified applicator training requirement are intended mainly to assist State and Tribal Lead Agencies, and may also be helpful to soil fumigant applicators and others.
- The topics covered in this document are:
- The NASDARF National Soil Fumigation Exam
- The NASDARF Soil Fumigation Manual
- State Lead Agencies
NASDARF (National Association of State Departments of Agriculture Research Foundation) NATIONAL SOIL FUMIGATION EXAM
- How many exam questions (i.e. "items") are in the databank?
There are 111 questions.
- As a State Lead Agency (SLA), can I review the exam questions before I decide whether or not I want a copy?
No, but you can review the exam blueprint document that shows the subject areas covered in the exam questions. To get a copy of the blueprint, contact Jeanne Kasai at firstname.lastname@example.org.
- As an SLA, how can I obtain a copy of the exam item databank?
- As an SLA, can I add some of my own questions to the exam item databank?
- Will EPA approve my SLA certification exam as meeting the label required “training requirement” for pesticide applicators if I mix my own questions with questions from the exam item databank?
- Can I use the exam questions for a private applicator exam?
- Does an applicator have to take an exam even if he/she takes training?
- Does an applicator have to take training even if he/she can pass an exam?
- Can an SLA offer a “challenge exam” as opposed to a certification exam based on the NASDARF National Soil Fumigation Exam Blueprint and Test Item Bank?
- As an SLA, where/how can I see the Soil Fumigation Manual before I order copies?
- How do I order copies of the manual?
- Can I use the manual if I intend to delete information from it?
- Can I use the manual if I intend to add more material to it?
- Can I incorporate parts of the manual into our state’s own Fumigation Manual?
- Can I use the manual for private applicators? Yes, the manual is appropriate for both private and commercial applicators.
- If an SLA (or a Cooperative Extension Service working through the SLA) wants to offer a state-sponsored or state-approved training course on soil fumigation that applicators can take to meet the label requirement for training, would it have to be approved by EPA?
- Who should I contact for approval of a course that will meet the label requirement?
- Will recertification courses be approved by EPA?
- Do pesticide State Lead Agencies have to approve the registrant training for continuing education units in their state?
- When will the registrant's training be available to applicators?
- Have state training experts been involved in review of the registrants’ training programs?
- How will the applicators know what options are available to them to fulfill the label-required training in their state?
- If an applicator is already certified in my state in a soil fumigation category or subcategory, does he/she have to take the registrant training to comply with the label requirement for training? No, as long as your state soil fumigation category certification is listed on the EPA soil fumigant Web page as an approved option for meeting the label-required soil fumigant training, and if the applicator is current on his/her recertification requirements, he/she does not have to take the registrant training. To be listed on the EPA website, the state certification category/subcategory must be up-to-date and have been verified by EPA to include information on the new requirements.
- How will the State or Tribal Lead Agency know whether an applicator has fulfilled label-required training provided by registrants?
The databank will only be available to State Lead Agencies that have their EPA-approved state plans entered in the Certification Plan and Reporting Database (CPARD) maintained by EPA and are up-to-date with the associated reporting requirements. You will have to sign a form before it can be released to you. Contact Jeanne Kasai at email@example.com.
Yes, you can use some or all of the exam items from the databank in your exam. You will have the exam blueprint document to help guide you on which subject areas you'll have covered with the items you've chosen from the databank.
Yes, however EPA needs to review the exam before approving it and posting a notification on the EPA soil fumigant Web page (http://www.epa.gov/fumiganttraining/) that it meets the training requirement in lieu of registrant-sponsored training. Using questions only from the NASDARF (National Association of State Departments of Agriculture Research Foundation) databank will expedite EPA’s review and approval process. Contact Jeanne Kasai at firstname.lastname@example.org for information concerning exam approval.
Yes, the exam questions are appropriate for both private and commercial applicators.
Yes, applicators who take EPA-approved label-required training will have to demonstrate that they have successfully completed it. For example, the registrant-sponsored training program will have quiz questions throughout the training modules as well as an exam at the end of each module. Applicators will have to correctly answer a certain percentage of the exam questions to successfully complete the training and receive documentation of completion. (Note that the registrants’ exam and training is not based on the NASDA manual.)
It depends. Applicators would not have to take label-required training in a state that has a soil fumigation (certification or challenge) exam approved by EPA as an alternative to label-required training. (Note that this does not refer to state recertification training requirements for pesticide applicators.)
Yes, some states may choose to offer a “challenge exam” apart from the state applicator certification program. A challenge exam would be administered to determine whether an applicator has acquired competency in the key aspects of soil fumigant application, independent of certification in soil fumigation or other training offered by the state. States offering the challenge exam option may use the NASDARF exam or develop their own. If they develop their own exam, EPA would review the exam to verify that it covers the required content before approving it and posting a notification on the EPA soil fumigant website that it does so. If using the NASDARF exam, the SLA would notify EPA and provide a brief description of how the exam will be administered before EPA posts a notice on the soil fumigant website.
The manual is available at http://www.ctaginfo.org/pdf-documents/Fumigation_low.pdf .
For a copy or copies of the manual, representatives of SLAs and state Pesticide Safety Education Programs (PSEPs) should contact Carol (Ramsay) Black at email@example.com. Pesticide applicators seeking a copy of the manual should contact their SLA and/or PSEP.
Yes, as long as the deletion is due to active ingredients and labeling that are not used in your state. Trying to simplify the content would not be allowable. Make your request to Carol (Ramsay) Black at firstname.lastname@example.org.
Yes, you can add information that pertains to your state, region, or area of the country. You can add an addendum, or request a copy of the InDesign™ version of the publication. Make your request to Carol (Ramsay) Black at email@example.com.
Yes, you can choose to update a broad-category Fumigation Manual with the new text. However, EPA would have to approve the manual and accompanying certification exam would if it were to be used for meeting the label-required training.
Yes, EPA will review and approve all soil fumigant training programs submitted by SLAs that are designed to meet the label-required training. However, the program needs to be approved by the SLA before it is submitted to EPA. EPA will list on the website all state programs that meet the label-required training. The training providers will have to provide documentation to the applicator to indicate successful completion of the training course. If a course is not listed on the EPA website as approved, a pesticide applicator cannot use it to satisfy the label requirement (in lieu of taking the registrant training).
No. That responsibility remains with the state.
The training courses provided by the registrants are not meant to serve as pesticide certification or recertification courses. They are only meant to satisfy the requirement that will be on the label for pesticide applicator training on soil fumigant products. An SLA can decide whether to approve the registrant training courses for recertification credits or units in their state.
Training programs developed by the registrants and approved by EPA are available in the Soil Fumigant Toolbox [http://www.epa.gov/pesticides/reregistration/soil_fumigants/] on EPA’s website. These training programs became available in early October 2012, well before December 1, 2012 when the pesticide applicator training requirement is due to appear on labels of soil fumigant products in the marketplace.
Yes, representatives from the American Association of Pesticide Safety Educators (AAPSE) and the Certification & Training Assessment Group (CTAG) reviewed and provided comments on registrant training modules for on-line training. The registrants have come together to provide one training package that includes modules on soil fumigation in general as well as information specific to each active ingredient. A registrant-developed training program is also available for certified applicators using dimethyl disulfide (DMDS).
On the soil fumigant training [http://www.epa.gov/fumiganttraining/] Web page, EPA is identifying states with training programs and exams that are approved to fulfill the label-required training. Applicators should always contact their SLA for information about applicable requirements in their state and options for meeting certification and/or the label-required soil fumigant training requirements.
The registrants will provide documentation to applicators who successfully complete the training. Enforcement personnel can verify the documentation presented by applicators in the field as follows:
- For products containing methyl bromide, chloropicrin, metam sodium, metam potassium, and dazomet, contact Achieva by phone at 888-828-0788. Achieva is the registrants' contractor that administers the training for these active ingredients.
- For products containing dimethyl disulfide (DMDS), an up-to-date list of applicators who have completed the registrant’s training is available by contacting firstname.lastname@example.org. Arkema, the DMDS registrant, is also developing an online database that can be accessed by enforcement personnel and will be announced when available.
- For applicators who have utilized one of the state options, the state will provide the documentation to applicators.
Yes, besides registrant training, SLAs may offer an applicator certification in a soil fumigation category or subcategory, a training option, or a “challenge exam” offered apart from the state applicator certification program (see question and answer #9).
No, SLAs do not have to take any action to have registrant training provided for applicators in their state.
No, SLAs only have to enter in CPARD changes to their state plan for certification of applicators such as revising a category/subcategory or addition of a new category/subcategory.
Yes; however, it would be less confusing if soil fumigation was its own category/subcategory when it comes to exams, recertification courses, and study materials. Consult with EPA’s Certification and Worker Protection Branch if you have questions about your state plan or existing fumigant categories/subcategories (contact Richard Pont at email@example.com).
SLAs might consider using the main subject areas of the exam blueprint document (listed below) as the standards for a new category/subcategory. SLAs could also work together on developing such standards, to include:
- Basic knowledge of soil fumigants
- General label and regulatory requirements
- Soil fumigant characteristics
- Soil and pest factors that influence fumigant activity
- Personal protective equipment, in particular respirators
- Protection of certified applicators, fumigant handlers and bystanders
- Site assessment and weather
- Fumigant management plans and post-application summaries
- Buffer zones and posting requirements
- Application methods and soil sealing
- Calculations and calibration
- Safe handling (transport, storage, disposal, spills) and emergency response
Consult with EPA’s Certification and Worker Protection Branch if you have questions about your state plan or existing fumigant categories/subcategories (contact Richard Pont at firstname.lastname@example.org).