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Dicamba Training Requirements — Frequently Asked Questions

Certain dicamba formulations can be used to control weeds in cotton and soybean plants that are genetically engineered to resist dicamba. In 2017, EPA announced new requirements for “over-the-top” dicamba applications (for use on growing plants) to further minimize the potential for drift to damage neighboring crops.

This page has some common questions and answers to help states understand the dicamba product training requirements, including for over-the-top soybean and cotton uses.

  1. What are the additional training requirements for dicamba products? Are these different from certified applicator training requirements?
  2. Which products are impacted by the dicamba training requirement?
  3. Are state personnel required to give the dicamba-specific training themselves?
  4. Are states authorized to approve or mandate changes in the registrant’s dicamba training program? Can states restrict registrant-conducted training?
  5. If my state relies on industry to provide the dicamba-specific training, how will applicators receive training on use elements that appear on special local needs [FIFRA section 24(c)] labeling for these products?
  6. Because the dicamba products registered for over-the-top soybean and cotton uses are now restricted use, does the certified applicator training need to be taken or repeated before applying these products?
  7. Who must take the dicamba-specific training?
  8. All applicators must attend the training for the dicamba products that include over-the-top soybean and cotton uses. However, do all applicators need to obtain their certified applicator license to apply these products, or can they continue to operate under someone who already has their license?
  9. Are there components that the dicamba-specific training must include?
  10. May the state-required or the registrant-provided training be conducted online?
  11. One of the recordkeeping elements for Restricted Use Products is to maintain a record of the completed training. How will applicators show proof that they completed the required training?
  12. Who is responsible if an applicator overlooks a label requirement, even if the dicamba-specific training material covered that point?
  13. Do applicators need to take part in required training if they intend to use a generic form of dicamba for over-the-top application to dicamba-tolerant soybean and/or cotton?
  14. There is no change to the Enlist label at the federal level. For those who plan to use only Enlist Herbicide, do they need to attend the training again if they were trained last year?

1. What are the additional training requirements for dicamba products? Are these different from certified applicator training requirements?

In response to the unacceptably high number of reports of crop damage related to the use of dicamba in 2017, EPA, in cooperation with state lead agencies and registrants, implemented changes to dicamba products registered for over-the-top application to dicamba-tolerant soybean and cotton.

These changes include a requirement for applicators to be trained specifically for application of these products to ensure better label compliance and stewardship. Product-specific training must be completed prior to applying in 2018.

The dicamba trainings are different from and do not take the place of the certified applicator training, which is required as part of the state applicator certification requirements. Some states permit the dicamba training to be included as part of the continuing education unit (CEU) requirements for certified applicators.

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2. Which products are impacted by the dicamba training requirement?

The training requirements apply to the only three dicamba products that are registered for over-the-top application to soybean and cotton. They include:

  • Xtendimax with Vapor Grip Technology (EPA Reg. No. 524-617);
  • Engenia Herbicide (EPA Reg. No. 7969-345); and
  • DuPont FeXapan Herbicide (EPA Reg. No. 352-913).

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3. Are state personnel required to give the dicamba-specific training themselves?

No, state employees are not required to give training. States may authorize third parties, including registrants or extension experts, to do the training. At the state’s discretion, states may decide to rely exclusively on registrant-sponsored training.

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4. Are states authorized to approve or mandate changes in the registrant’s dicamba training program? Can states restrict registrant-conducted training?

If a state decides to regulate the registrant’s training program, the state would do so through its regulatory system. In states where these questions are relevant, EPA is relying on the state and the registrants to work through any issues in the training.

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5. If my state relies on industry to provide the dicamba-specific training, how will applicators receive training on use elements that appear on special local needs [FIFRA section 24(c)] labeling for these products?

EPA encourages states to work with the registrants to ensure applicators receive training on state-specific considerations and/or special local needs labeling (state-issued FIFRA section 24(c) labeling). Applicators are responsible for reading and following the label(s) in their entirety, including special-local-needs labeling.

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6. Because the dicamba products registered for over-the-top soybean and cotton uses are now restricted use, does the certified applicator training need to be taken or repeated before applying these products?

The dicamba-specific training is different from the certified applicator training, and does not replace the requirements to become a certified applicator or to maintain a certified applicator’s license.

You must be a certified applicator or be under the supervision of a certified applicator to apply dicamba over-the-top products. It is possible in your state that the certified applicator training could include the dicamba training as well.

For more information, contact your state lead pesticide agency. To find the contact information for your state lead pesticide agency, see the National Pesticide Information Center’s webpage on state pesticide regulatory agencies.Exit

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7. Who must take the dicamba-specific training?

Applicators involved in the application of the three products registered for over-the-top use on soybean and/or cotton are required to complete the training.

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8. All applicators must attend the training for the dicamba products that include over-the-top soybean and cotton uses. However, do all applicators need to obtain their certified applicator license to apply these products, or can they continue to operate under someone who already has their license?

EPA did not require through the label that all applicators be certified if operating under the supervision of a certified applicator, unless a separate license is mandated by the state. For the 2018 use season, these dicamba products have been classified as restricted use pesticides. These products can only be legally applied by a certified applicator or those working under the supervision of a certified applicator.

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9. Are there components that the dicamba-specific training must include?

EPA is not designing these training requirements. However, EPA strongly encourages trainers to address the new labeling requirements and restrictions that are included in the revised product labels. EPA also encourages trainers to focus on the label requirements and recommendations for:

  • Better management practices to avoid conditions that favor drift and/or temperature inversions;
  • Tank cleanout procedures;
  • Application timing; and
  • Any conditions/circumstances that exist in the state that may be relevant to careful applications.

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10. May the state-required or the registrant-provided training be conducted online?

Each state can choose how to implement the required dicamba-specific training and to determine the most effective method for delivering training. Online training is acceptable to EPA unless the state has a policy against it.

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11. One of the recordkeeping elements for Restricted Use Products is to maintain a record of the completed training. How will applicators show proof that they completed the required training?

Once the training is completed by the applicator, a certificate should be provided that the applicator can keep as a record. (One of the recordkeeping elements for these registrations requires the certified applicator to show proof of completing dicamba-specific training.)

Some states have decided to maintain a database of individuals who have completed the training. EPA encourages each state to work with their training coordinators and/or registrants to provide applicators with proof of training, once completed.

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12. Who is responsible if an applicator overlooks a label requirement, even if the dicamba-specific training material covered that point?

The intent of the training is to provide the best understanding of the product labeling possible to ensure careful applications that follow all label restrictions and directions for use. Ultimately, it is the applicator’s responsibility to apply the product in strict accordance with the product labeling.

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13. Do applicators need to take part in required training if they intend to use a generic form of dicamba for over-the-top application to dicamba-tolerant soybean and/or cotton?

There are only three products approved for over-the-top use on dicamba-tolerant soybean and cotton:

  • Xtendimax with VaporGrip Technology (EPA Registration number 524-617);
  • DuPont’s FeXapan Herbicide Plus VaporGrip Technology (EPA Registration number 352-913); and
  • Engenia Herbicide (EPA Registration number 7969-345).

Application of any other dicamba product, not registered for use on dicamba-tolerant soybean and cotton is strictly illegal. This will be considered a misuse and is punishable by law.

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14. There is no change to the Enlist label at the federal level. For those who plan to use only the Enlist herbicide, do they need to attend the training again if they were trained last year?

These requirements do not affect the requirements for the Enlist herbicide when using that product alone. States may have additional requirements that must be followed before applicators can use the Enlist herbicide. Consult your state lead pesticide agency for additional details. To find the contact information for your state lead pesticide agency, see the National Pesticide Information Center’s webpage on state pesticide regulatory agencies.Exit

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