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

Current Unclassified or General Use Restricted Use

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

Any Questions?