CTAG

1. CTAG Pesticide Classification &Applicator, Dealer, Consultant Certification and Training August 2003 Pesticide Applicator Certification and Safety Education Workshop Tim Drake and Bill Tozer

2. 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)

3. INTRODUCTION:Pesticide Safety for the 21st Century Report - 1999 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

4. INTRODUCTION:Certification & Training PREP Course - 2002 • Brainstorming - 6 Tier System • security risk • product-specific controls • occupational full • occupational limited • domestic mixable • domestic ready to use • Simplicity, tied to label

5. 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

6. 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

7. 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.

8. 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

9. Tiered Classification - Concept Current • Unclassified or General Use • Restricted Use

10. 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

11. Tiered Classification - Short Term ConceptKey Points EPA must classify pesticides as: • General Use (GUP) • Restricted Use Level 2 (RUP 2) • Restricted Use Level 1 (RUP 1)

12. 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.

13. Tiered Classification - Short Term ConceptKey Points • 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 NoChange

14. Tiered Classification - Short Term Concept General Use (GUP) • 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

15. Tiered Classification - Short Term Concept Restricted Use Level 2 (RUP 2) • 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

16. Tiered Classification - Short Term Concept Restricted Use Level 1 (RUP 1) • Description • Products considered extreme risk due to concerns for homeland security, human health, the environment, or sensitive use sites

17. Tiered Classification - Short Term Concept Restricted Use Level 1 (RUP 1) • User/Consultant Requirements • Mandatory product-specific training and certification of all users orconsultants • No supervision allowed • Additional regulatory controlsmay 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

18. Tiered Classification - Long Term Concept Key Points EPA must classify pesticides as: • Domestic Low Risk • Domestic High Risk • Occupational Use • Occupational Restricted Use

19. Tiered Classification - Long Term Concept Key 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.

20. Tiered Classification - Long Term Concept Key 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

21. Tiered Classification - Long Term Concept Domestic Low Risk (DLR) • 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

22. Tiered Classification - Long Term Concept Domestic High Risk (DHR) • 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

23. Tiered Classification - Long Term Concept Occupational Use • 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

24. Tiered Classification - Long Term Concept Occupational Restricted Use • Description • Super High Risk - due to concerns for homeland security, human health, the environment, or sensitive use sites

25. Tiered Classification - Long Term Concept 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

26. Tiered Classification - Long Term Concept Other New Occupational Use Categories • 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

27. 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

28. Any Questions?