Options and Issues Related to Applicator Training
For State and Tribal Agencies
EPA requires important 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 information in the sections below about the certified applicator training requirement is intended mainly to assist state and tribal pesticide regulatory agencies, and may also be helpful to soil fumigant applicators and others.
Fumigant users will need to comply with the certified applicator training requirement. 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.
The topics covered in this document are:
- Training for Pesticide Applicators
- State and Tribal Lead Agency Roles
- Fumigation Categories and Subcategories Training Options
Pesticide applicators products have two ways to comply with the certified applicator training requirement on the label of soil fumigant products: Registrant Programs or State Programs.
If you are an applicator who is already certified in a soil fumigation category or subcategory, your certification is current, and the state where you are certified is listed under “State Programs” below, you do not have to complete the registrant training program.
- Soil Fumigation Manual (A National Pesticide Applicator Certification Study Guide) (PDF) (128 pp, 16.1 MB, About PDF)
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.
State programs that are approved by EPA to fulfill the label-required training requirement can be found on the soil fumigant training Web page. Applicators should always contact their state lead agency for information about applicable requirements in their state and options for meeting certification and/or the label-required soil fumigant training requirements.
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?
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 maintains a list of 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).
How will the state or tribal lead agency know whether an applicator has fulfilled label-required training provided by registrants?
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.
As an SLA, if my state has a fumigation combination category/subcategory, (e.g., soil plus commodity, and/or space fumigation) can I still use the manual and/or exam?
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. Contact Richard Pont, email@example.com, if you have questions about your state plan or existing fumigant categories/subcategories.
I want to create a new or revised category or subcategory for soil fumigation for certified applicators. What does EPA consider when it reviews such changes to a state's certification rules or standards?
The main subject areas of the exam blueprint document (listed below) would be a good basis for a new category/subcategory. We would be looking for inclusion of these topics in a proposal. SLAs could also work together on developing content. Subject areas 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.
Contact Richard Pont, firstname.lastname@example.org, if you have questions about your state plan or existing fumigant categories/subcategories.