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CTAG
August 2003Pesticide Applicator Certification and
Safety Education Workshop
Tim Drake and Bill Tozer
Pesticide Classification &
Applicator, Dealer, Consultant Certification and Training
Tiered-Classification Workgroup
Carol Ramsay (WA) Co-Chair Tim Drake (SC) Co-Chair Candace Bartholomew (CT) Debbie Danford (TX) Gina Davis (MI) Kevin Keaney (EPA) Sandra McDonald (CO) Karen Ryan (NF) Bill Tozer (AFPMB) Murray Walton (TX)
Goal 1.0 Reduce Risks to the Public from Pesticide Use:
Proposal 1.2 Expand the regulatory scope of the program
Proposal 1.3 Integrate the Worker Protection Standard requirements with a
new applicator training program
Proposal 1.4 Consider a tiered-classification of pesticides
INTRODUCTION:Pesticide Safety for the 21st Century Report -
1999
Brainstorming - 6 Tier System security risk product-specific controls occupational full occupational limited domestic mixable domestic ready to use
Simplicity, tied to label
INTRODUCTION:Certification & Training PREP Course - 2002
INTRODUCTION:Certification & Training PREP Course - 2002
Brainstorming - 6 Tier System Classification for end user
perspective
Tier to be noted on label, as well as requirements for use
Classification directly linked to certification and training requirements
Work group leads identified
INTRODUCTION:CTAG Board - Charge
Use the tiered-classification model developed at C&T PREP Course as a beginning point: occupational and non-occupational
users
product characteristics, including:
level of toxicity or hazard
security risk
level of pesticide education and safety training appropriate or required
INTRODUCTION:CTAG Board - Charge
certification or licensing requirements
application site characteristics
engineering or manufacturing controls
Develop matrix or scoring system that can be used to classify pesticides into the appropriate tier.
Tiered Classification - Overview
Much taken from the Canadian proposal
Primary mechanisms for mitigating potential hazards associated with pesticide use by:
RESTRICTING USE - by specifying the intended use of the product by the registrant
RESTRICTING ACCESS - of occupational and high risk pesticides to only those individuals who are properly trained and certified
RESTRICTING DISTRIBUTION - restricting who can distribute or recommend those products
Tiered Classification - Concept
Short Term Home and Garden - ignore General Use (no unclassified
allowed) Restricted Use - Level 2 Restricted Use - Level 1
Long Term Domestic Low Risk Domestic High Risk Occupational Use Occupational Restricted Use
Tiered Classification - Short Term ConceptKey Points
General Use (GUP)
Restricted Use Level 2 (RUP 2)
Restricted Use Level 1 (RUP 1)
General Use (GUP)
Restricted Use Level 2 (RUP 2)
Restricted Use Level 1 (RUP 1)
EPA must classify pesticides as:
Tiered Classification - Short Term ConceptKey Points
RUP 1 - Super High Risk Types of Products
homeland security risk products
extremely hazardous products
Certified Applicator with
Core and category certification
Product-specific training and certification
Other regulatory controls on access, cradle to grave inventory, recordkeeping, etc.
Dealer Certification - required for RUP 2 or RUP 1 distribution and sales
Consultant Certification - required for RUP 2 or RUP 1 technical advice
WPS Handler Requirement - for non-certified agricultural applicators or handlers
This is not a change
Tiered Classification - Short Term ConceptKey Points
NoChange
Description Products considered low risk to humans,
domestic animals, or the environment when handled and applied in accordance to the product label
Uses may be intended for non-home and garden or home and garden
User/Consultant Requirements None
Sales Requirements None for sales None for consultants
NoChange
Tiered Classification - Short Term Concept
General Use (GUP) General Use (GUP)
Description Products considered moderate risk due to
concerns for human health, the environment, or sensitive use sites
User/Consultant Requirements Mandatory certification of all users,
supervisors, or consultants Trained WPS handler for agricultural
establishments
Sales Requirements Certified Dealer must be employed by a
Licensed Dealer Establishment
Tiered Classification - Short Term Concept
Restricted Use Level 2 (RUP 2) Restricted Use Level 2 (RUP 2)
Description Products considered extreme risk
due to concerns for homeland security, human health, the environment, or sensitive use sites
Tiered Classification - Short Term Concept
Restricted Use Level 1 (RUP 1) Restricted Use Level 1 (RUP 1)
User/Consultant Requirements Mandatory product-specific training and
certification of all users or consultants No supervision allowed Additional regulatory controls may be
implemented, such as product-specific training, permits, engineering controls, inventory tracking, record keeping
Sales Requirements Certified Dealer must be employed by a
Licensed Dealer Establishment Inventory tracking
Tiered Classification - Short Term Concept
Restricted Use Level 1 (RUP 1) Restricted Use Level 1 (RUP 1)
EPA must classify pesticides as:
Domestic Low Risk
Domestic High Risk
Occupational Use
Occupational Restricted Use
Tiered Classification - Long Term ConceptKey Points
Occupational Restricted Use - Super High Risk
Types of Products
• homeland security risk products
• extremely hazardous products
Certified Applicator
• Core and category certification
• Product-specific training and certification
• Other regulatory control on access, cradle to grave inventory, recordkeeping, etc.
Tiered Classification - Long Term ConceptKey Points
Dealer Certification - required for any occupational use product sale
Consultant Certification - required for any occupational use product
Handler Requirement - for any non-certified applicators or handlers
Vendor Certification - for any domestic high risk product sale
Commercial Applicator Certification - required for any non-personal use of domestic product
Tiered Classification - Long Term ConceptKey Points
Description Consumer use in and around a dwelling Products present little or no risk to human health or
the environment Ready-to-use products Designed for spot treatment Package size designed to last one season only No persistence exhibited in the environment after
application User or Sales Requirements
None Sales Requirements
None
Tiered Classification - Long Term Concept
Domestic Low Risk (DLR) Domestic Low Risk (DLR)
Description Consumer use in and around a dwelling Mandatory certification for any non-consumer use. Products do not fall within hazard criteria range for
Low Risk Products intended to be diluted or mixed, or
require calibration of dispersal equipment Designed for broadcast treatment Product does not degrade in a single season
Sales Requirements Vendor certification
User Requirements None
Tiered Classification - Long Term Concept
Domestic High Risk (DHR) Domestic High Risk (DHR)
Description Low to high risk due to concerns for human
health, the environment, or sensitive use sites
User/Consultant Requirements Mandatory certification of all users, supervisors,
or consultants
Trained handler for private or commercial use
Sales Requirements Certified Dealer must be employed by a
Licensed Dealer Establishment
Tiered Classification - Long Term Concept
Occupational Use Occupational Use
DescriptionSuper High Risk - due to
concerns for homeland security, human health, the environment, or sensitive use sites
Tiered Classification - Long Term Concept
Occupational Restricted Use Occupational Restricted Use
User/Consultant Requirements Mandatory basic & product-specific training Certification of all users No supervision allowed Additional controls: permits, engineering
controls, inventory tracking, record keeping. Sales Requirements
Certified Dealer must be employed by a Licensed Dealer Establishment and be physically present
Additional Controls: inventory tracking
Tiered Classification - Long Term Concept
Occupational Restricted Use Occupational Restricted Use
New Certification Categories Wood Preservation Sewer Root & Pipeline Pest Control Marine Paints (Anti-fouling paints)
New Application Method Categories Aerial Application Mist Blower (Air Blast) Application Chemigation
Tiered Classification - Long Term Concept Other New Occupational Use
Categories Other New Occupational Use
Categories
Where we are:
Workgroup developed concept Initial float of concept at Nat’l Meeting Continue discussion of concept at
CTAG Board Meeting Possible outcomes
proceed with development of idea discuss with EPA administration form new CTAG workgroup
want to volunteer? include wider stakeholder involvement