Download presentation
Presentation is loading. Please wait.
1
CTAG Issues Written Exam and Age Requirement SLA Funding Worker Protection Integration Certified Pesticide Dealers and Vendors Certified Consultants Occupational Applicators and Handlers Positive Identification and Test Security Web-Based C&T Plan and Reporting August 2003 http://pep.wsu.edu/ctag
2
Session One Written Exam and Age Requirement SLA Funding Worker Protection Integration
3
North American Pesticide Applicator Certification and Pesticide Safety Education Workshop CTAG: Age and Written Exam Requirements Jack Peterson - August 12, 2003
4
White Paper - Requiring Minimum-Age Requirement for Approval of State Certification Programs Background: Many states do not currently require a minimum age for certification. Federal labor laws are in effect prohibiting certain agricultural employment depending upon age. Two surveys were conducted to assess age requirements for certification. FIFRA and subsequently 40 CFR part 171, do not impose an age restriction. United States Department of Labor (DOL) rules 29 CFR 570.71 prohibits the agriculture employment of children below the age of 16 if the job encompasses handling or applying (including cleaning or decontamination equipment, disposal or return of empty containers, or serving as flagman for aircraft applying) agricultural chemicals with signal words, “Poison”, “Skull and Crossbones” and “Warning”. Further, the Fair Labor Standards Act (FSLA) also has minimum-age requirements for children working in agriculture under the age of 17.
5
AGE RESTRICTION SURVEY RESULTS All states responded. 44% of states have no minimum age limit for private appl. 40% of states have no minimum age limit for commercial applicators. For those with certification minimum-age limits: Private applicator (56%) age 15--1 state, age16--10 states, age 17--1 state, age 18--15 states Commercial applicator (60%) age16--6 states, age 18--20 states SPC may be different N=48P N=50C No territories included here
8
SURVEY II 53 responses - 98% recommend a minimum-age requirement. Twenty six responders indicated the minimum age should be 18; twelve indicated it should be 16; a few others indicated it should be lower. When asked if the minimum age should be different for commercial versus private applicators, 26 (49%) of the 53 responded yes; all others took no position. Private applicator – age 16—18 agree Commercial applicator – age 18—19 agree Other responses – 7 responses No position – 30 responses
9
Requiring an age restriction facilitates consistency across the country. Several issues need to be considered should mandatory age restrictions become a requirement for approval of a state certification plan. 1.Given DOL rules already in place, should such a requirement be proposed? 2. Several states still have family-operated farms; will states be allowed exemptions to a minimum-age requirement for immediate family? 3. How would certification age restriction rules impact the states? 4. A FIFRA-mandated minimum-age requirement, which is an industry- supported change, should remove impediments and bring about improvements in the C&T program. 5. A FIFRA-mandated minimum-age requirement will help change public perception and demonstrate how C&T protects the public and does not merely exist to license more people as a means to increase sales of pesticides.
10
Recommendation: The EPA should implement a minimum-age restriction as a requirement for approval of a state plan for the certification of private and commercial pesticide applicators. This should be implemented over a three to four-year period to allow those states that lack the authority to build alliances and to implement the necessary authority or legislation.
11
Ideas/Comments/Questions
12
White Paper - Requiring Written Examinations for Approval of State Certification Programs Background: Most states currently require exams to ensure competency. A survey was conducted for this assessment by the CTAG with all but one state responding. The results show that 84% of states require exams for private certification and 94% of states require exams for commercial certification. Those requiring closed-book exams were: 67% for private and 96% for commercial certification; respectively, 83% and 90% required written exams. N=48P N=50C No territories included
13
It was a common understanding that Section 11 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) prohibited testing of private applicators. Under section (a) CERTIFICATION PROCEEDURE (1) FEDERAL CERTIFICATION – In any State for which a State plan for applicator certification has not been approved…, the Administrator,… shall conduct a program for the certification of applicators of pesticides. Such program shall conform to the requirements…under the provisions of subsection (a)(2) of this section and shall not require private applicators to take any examination to establish competency in the use of pesticides. (emphasis added)
14
Because this requirement falls under the federal certification portion of FIFRA, states can require examinations of private applicators when not prohibited by state law. Requiring a written closed-book exam will facilitate consistency across the country as well as ensuring competency. Several issues need resolution should mandatory testing become a requirement for state certification plan approval, 1. Will making a written closed-book exam part of the requirements for an approved state certification plan, require changes in federal regulations? If not, how will this be done? 2. Should a state be unwilling or unable to implement such a requirement, is the EPA willing to step in? What other options are available? 3. What problems are created for those states (17%) that currently do not require written or closed-book exams for private applicators? What would be the time frame for implementation of this requirement? What tools are available to help those states develop a quality exam and the associated study materials?
15
Recommendation: The EPA should implement written closed-book exams as a requirement for approval of a state plan for the certification of private and commercial pesticide applicators. This should be implemented over a three to four-year period to allow those states that currently do not require written closed-book exams to implement the requirement. The national core exam and associated training materials (EPA/PMRA Pesticide Applicator Core Examination) should be available for use by those states not currently requiring testing.
16
Ideas/Comments/Questions
17
Session Four Written Exam and Age Requirement SLA Funding Worker Protection Integration
18
Change 50-50 to 85-15 “Administration” of C&T Program = SLA FIFRA language states 50/50 match Inconsistent with other FIFRA match requirements at 85/15 50/50 creates hardships for C&T Programs Due to regulatory climate at time of provision enactment Can not be overridden since FIFRA supercedes Must revise FIFRA language
19
Change 50-50 to 85-15 CTAG Recommendation Supports revision of FIFRA to eliminate statutory requirement for 50/50 match Supports efforts to bring about change through a statutory amendment Keep on burner until door opens
20
Ideas/Comments/Questions
21
WPS Integration Improved Risk Mitigation Improved Pesticide Security Robust Handler Training Infrastructure Handler Competency Assessment Pesticide Handler Identification
22
WPS Integration Propose Minimum Standards Forward Recommendations Evaluate Potential Impacts
23
Proposed Minimum Standards Pesticide Handlers Aerial Applicators Crop Consultants Researchers
24
Recommendations Aerial Applicators Crop Advisors Researchers Pesticide Apprentices Trainers
25
Potential Impacts Growers Employers Cooperative Extension State Lead Agencies
26
Ideas/Comments/Questions
28
Session Two Certified Pesticide Dealers and Vendors Certified Consultants Occupational Applicators and Handlers
29
Review Harmonized Concept for Pesticide Classification Current Unclassified General Restricted Use Short Term General use RUP-2 RUP-1** Long Term Occupational Use Occupational Restricted Domestic Low Risk Domestic High Risk **very few products Certification - by passing monitored, closed-book written examination.
30
Pesticide Dealer Short-Term General Use No change RUP-2 products Licensed Establishment Certified Dealer Can supervise sale RUP-1 products Licensed Establishment Certified RUP-1 Dealer (mandatory product specific training) Supervision not allowed Long-Term Occupational Use Licensed Establishment Certified Dealer Can supervise sale Occupational Restricted Licensed Establishment Certified Occupat. Restricted Dealer (mandatory product specific training) Supervision not allowed
31
Pesticide Vendor Short-Term (sales) No change Long-Term (sales) Market must be declared Personal use in and around the dwelling Domestic Low Risk No Change Domestic High Risk Licensed Vendor Establishment Certified Vendor Available for consultation
32
Pesticide Consultant Short-Term General Use and Home and Garden No change RUP-2 products Certified Consultant RUP-1 products Certified RUP-1 Consultant (mandatory product specific training) Long-Term Domestic Use No change Occupational Use Certified Consultant Occupational Restricted Certified Occupational Restricted Consultant (mandatory product specific training)
33
Pesticide Occupational Applicator Short-Term General Use and Home and Garden No change RUP-2 products Certified Private Certified Commercial RUP-1 products Certified RUP-1 Applicator (mandatory product specific training) No supervision Long-Term Occupational Use, or Domestic High Risk-if for non-personal use Certified Occupational Applicator Occupational Restricted Certified Occupational Restricted Applicator (mandatory product specific training) No supervision Other controls
34
Pesticide Occupational Handler Short-Term General Use WPS Agricultural Handler RUP-2 products WPS Agricultural Handler Long-Term Occupational Use, or Domestic High Risk-if for non- personal use Trained Occupational Handler Must work under supervision of certified Occupational Applicator
35
New Categories Pest Control Long Term Sewer Root & Pipeline Wood Preservation Marine Paint Due to EPA restricted use status - create national consistency Recognize additional workload Application Method Long-Term Chemigation Mist-Blower or Airblast Sprayers Aerial Application Increase hazard to the public and environment - create national consistency Recognize additional workload
36
Open Discussion on Certification and Training Dealers (short and long-term) Vendors (long term) Consultants (short and long-term) Occupational Applicators (long term) Occupational Handlers (long term) New Categories (pest control or application method)
38
Session Three Positive Identification And Test Security
39
Positive ID and Test Security Roger Flashinski Carl Martin
40
CTAG Workgroup on C&T Plans Workgroup on Pesticide Safety Workgroup on Tiered Classification
41
Workgroup on Pesticide Safety Integrate WPS Training Requirements Consistency for Certification Standards Positive ID Online Testing Language Standards Pesticide Security for Transport/Storage
42
Subgroup Charge Take an applicator exam Attend a recertification training session Purchase a RUP Determine the implications of requiring positive ID for ALL applicators before they:
43
Subgroup Members Roger Flashinski, CES, WI (Chair) Dave Duncan, SLA, CA Rick Hansen, SLA, MN Win Hock, Emeritus CES, PA Al Muench, EPA Consultant
44
Why the Concern? No national standards Policy rather than rule making Therefore: Surrogate substitute for real applicator Unqualified person could buy RUPs
45
Advantages Person taking the exam is for real Person buying RUPs is competent Only qualified applicators supervise others Stronger pesticide security Verifying an applicator’s identity assures:
46
Advantages Driver’s license Passport Military ID Immigration green card Existing U.S. issued photo ID documents:
47
Advantages Cause little inconvenience for the proctor Incur minimal cost to states Take minimal effort for retail dealers to confirm buyer’s identity Positive ID verification will:
48
Limitations Some religious groups prohibit pictures Large group meetings may require additional staff Internet and telephone sales more problematic
49
Recommendation: Certification and Recertification Exams Verify the positive ID of all individuals Use existing photo ID documents Exception: Legitimate religious groups (two forms of non-photo ID documents required)
50
Recommendation: Purchasing RUPs Verify the positive ID of all certified applicators Use existing photo ID documents Exception: Legitimate religious groups (two forms of non-photo ID documents required)
51
Recommendation: Recertification Training Sessions Attendance roster signed by all attendees Written monitoring plan to ensure applicator competency and program integrity
52
Open Discussion on Positive Identification Appropriate and/or Practical for Examinations? Appropriate and/or Practical for Training Guidance document helpful?
53
Examination Security-- Internal Testing Center Access Control Closed Book Exams Test Blue Print Distribution Periodic Exam Item Replacement Shuffling Item and Answer Order Policy & Procedures SOP Trained Proctors
54
Examination Security-- External Blueprint is the “challenge” document No Test or Item Review Separate Application/Testing Procedure Periodic External Auditing Money Handling Procedures Scheduling
55
Examination Security-- Challenges Cheating Copying Materials Training Content Access Inventory Scratch Paper Calculators/Computers
56
Examination Security-- Challenges Physical Threats Intimidation Too Helpful Clear Instructions Posted Standards Grading Score Disbursement
57
Open Discussion on Security
59
Session Four Web-Based C&T Plan and Reporting
60
Web-Based C&T Plan and Reporting Development Colleen Hudak-Wise and Carol Ramsay Beta-test Rick Hansen & Colleen Hudak-Wise EPA review Allan Welch Show and Tell What are the Next Steps?
61
Web-Based State Plan and Reporting - GOAL C&T Plan and Report website http://cru.cahe.wsu.edu/candt/logon.cfm http://cru.cahe.wsu.edu/candt/logon.cfm Plan meets FIFRA and 40CFR171 Administration, authority, conformity, categories, examinations, supervision, reciprocity Reports exceeds FIFRA and 40CFR171 Applicator totals, category totals, certification/license cycles, recertification, regulatory activities, and participation, monitoring, enforcement related to certification
62
Web-Based State Plan and Reporting Development Team Debbie Danford (TX) Carol Ramsay (WA) Co-Chairs Gina Davis (MI)Donnie Dippel (TX) Colleen Hudak (NC) Jack Peterson (AZ) Randy Rivera (TX)Allan Welch (EPA-10) Kevin Keaney (EPA) Jeanne Heying (EPA) Richard Pont (EPA) Monte Johnson (USDA )
63
C&T Plan/Reporting Project Development All on the same template Once entered, only need to update Plan web page sections where changes occurred and enter annual report Convenient, streamlined tool for submitting and assessing of Certification and Training Plans Meets all 40CFR171 requirements Identied additional elements
64
C&T Plan/Reporting Project Development Satisfy annual reporting requirements Current Form, Old 5700-33H form, 40CFR171 requirements Eliminate quarterly reporting Strive to achieve more consistent reporting Comparable among states Web database “rolls” forward data that does not change
65
C&T Plan/Reporting Project Development Facilitate annual review by EPA Consistent format among states Changes to plan Reporting items Noted EPA review dates Deadlines Information gathering by EPA
66
C&T Plan/Reporting Project Development Development Process Assessed FIFRA and 40 CFR 171 documents Assessed annual reporting documents Produced an Excel Spreadsheet Separated major Plan/Report elements Discussed criteria for consistency reported items would be as similar as possible Set limitations for responses
67
C&T Plan/Reporting Project Development Development Process Added web-based ideas to spreadsheet Radio buttons (select one only) Check boxes (select all that apply) Text boxes (for short answers) PDF loads (for extended documentation) PREP Course to discuss
68
C&T Plan/Reporting Project Development Development Process Turned over to Programmer Excel spreadsheet 40CFR171 help button information General help information
69
C&T Plan/Reporting Project Development Development Process Programming Intent for database and files to be on EPA Computer Had to use “older” applications to develop web pages Frames is not really frames
70
C&T Plan/Reporting Project Development Development Process Programmer and states worked together to produce beta- version Andrew Thostenson, Colleen Hudak- Wise, Rick Hansen, Gina Davis, Richard Pont, Allan Welch, Carol Ramsay
71
Web-Based State Plan and Reporting Beta-test Team Colleen Hudak-Wise & James Choate (NC) Rick Hansen (MN)Ed Crow (MD) Andrew Thostenson (ND)Buzz Vance (NE) Randy Rivera (TX)Margaret Tucker (WA Kathy Dictor (VA)Clark Burgess (UT) Allan Welch (EPA-10) Richard Pont (EPA)
72
Beta-Testing Some states completed to this point Others added some information Comments Fairly straight forward to work through Will take several sittings to get all initial data in Adobe Acrobat needed for many SLA’s who do not have software to write PDF files
73
Beta-Testing Comments Since striving for national consistency, a few items are awkward, but doable Web pages not set in stone, open to tweaking in the future General help buttons have been added for clarification and guidance Printed guidance document prepared
74
Beta-Testing Once data is entered, fields are dynamic and can be updated (additions, deletions)
75
EPA Review Web-database does cover all the required items in FIFRA and 40CFR171 Annual reporting, not quarterly All state data within in Region (nationally) will be in the same format Simplification will facilitate EPA Region approvals of C&T Plans Reports can be generated within the web database (further development needed)
76
Show and Tell Overall Look and Navigation Help Menus Check boxes and radio boxes Text Boxes, Number boxes Pulldown menus Loading PDF files Read the DIRECTIONS and REQUESTS carefully!
77
Basic Navigation Navigation Menu Working Page Cookie Trail Header
78
Help
81
Logout Button Two places on page to Logout Cookie Line Logout Button Must Logout if you want immediate access Will lock you out for small amount of time If idle for 20 minutes, it will close
82
Sections Report Year Contact Information Part I - The Plan Part II - The Report Utilities Menu Page
83
Logon State Name-Abbreviation
84
Report Year First Screen
85
Contact Information
86
Part I - The Plan Plan Administration Examinations Agencies Other Certification Legal Authority Certification Personnel State Reciprocity Funding Proposed Changes Conformity Direct Supervision Competency Standards Training
87
Agencies
92
Competency Standards
93
Pulldown Menu
96
Examination per Category
97
Duplicate - Edit - Delete
98
Part II - The Report Applicator Totals Participate/Monitor County by Category Enforcement Applicator Cycles Communication Recertification Additional Info Regulatory Activities
102
Utilities Complete Listing Entry Counts Report Period
104
Menu Page Alternate Navigation Method
105
PDF Files are Key Method to produce PDF files Adobe Acrobat Macintosh OS X Other software Internet sites Encourage attendance to Mike Weaver Adobe Acrobat Talk. Good basics to assist with completing the Plan, plus some other positive attributes of Adobe Acrobat that you will use, if you have it.
106
Troubleshooting Interpretation and Clarification Richard Pont, US EPA Carol Ramsay, Wash. St. University Computer difficulties Carol Ramsay (Kathleen Duncan)
107
C&T Plan/Reporting Project Development Next Phase Reporting items For EPA Headquarters and Regions State sharing of information Public viewing of information *some reports on current system to show and tell what can be done
108
C&T Plan/Reporting Project Development When the Rubber meets the Road CTAG Board Meeting discussions Tweaking a few pages Deadline for first Plan Deadlines for first Annual Report Training opportunities Adobe Acrobat
109
Open Discussion on Web-based Plan & Reporting Benefits of template Impacts on your program Timeline to work on web template EPA anticipation of mandatory reporting Purchase of Adobe Acrobat 6.0 for PDFs Possible workshops or C&T Plan managers and EPA Region review staff.
Similar presentations
© 2025 SlidePlayer.com. Inc.
All rights reserved.