In 2018 EPA finalized a rule for certification for commercial and private applicators of Restricted Use Pesticides (RUPs), and any non-certified applicators working under their direct supervision.
Certification Rule — General Details
- Specialized certification requirements for aerial application, soil fumigation, and non-soil fumigation.
- Persons must be at least 18 years old to qualify as a non-certified applicator using RUPs (Exception: persons under the supervision of an immediate family member and applying non-commercially must be at least 16 years old.)
- Certifications are now valid for a maximum of five years,
- Required pesticide certification at least once every five years through either written exams for each certification or by completing specific training in a continuing education authority for commercial applicators.
- Requires states to adopt Continuing Education Unit (CEU) criteria for the quantity, content, quality assurance of CEUs, and verification of completed CEU coursework.
- Allow states to choose between requiring recertification by exam or completion of CEUs.
- States must require commercial applicators to maintain application records for a minimum of two years; records must include:
- the name and address of the person for whom the pesticide was applied;
- The location and size of the pesticide application area
- Time and date of application
- Product name and EPA registration number of RUP applied
- Total amount of the pesticide applied
- The name and certification number of the certified applicator that made or supervised the application, and if applicable, the name of any non-certified applicator(s) that made the application under the direct supervision of the certified applicator.
- Requires State certification plans to address reciprocity with other states.
- Defines “use” as in “to use a pesticide” to include any pre-application activities (including arranging for application and mixing and loading), applying the pesticide or supervising use by non-certified applicator, transporting or storing pesticide containers that have been opened, cleaning equipment, disposing of excess pesticides, spray mix, equipment wash waters, pesticide containers, and other pesticide-containing materials.
Certification Rule — Required Aerial Applicator Exam Knowledge Areas
- Labeling – Label requirements specific to aerial application including:
- Spray volumes
- Buffers and no-spray zones
- Weather conditions specific to wind and inversions
- Application equipment – Understanding of how to choose and maintain aerial application equipment including:
- The importance of inspecting equipment prior to use
- Selecting the proper nozzles
- Knowledge of the components of an aerial application system including hoppers, tanks, pumps and nozzles
- Interpreting a nozzle flow rate chart
- Determining the number of nozzles for intended pesticide output using nozzle flow rate chart, aircraft speed and swath width
- How to ensure nozzles are placed to compensate for uneven dispersal due to uneven airflow from wingtip vortices, helicopter rotor turbulence and aircraft propeller turbulence
- Where to place nozzles to produce the appropriate droplet size
- How to maintain the application system
- How to calculate the required and actual flow rates
- How to verify flow rate using fixed timing, open timing, known distance or a flow meter
- When to adjust and calibrate equipment
- Application considerations – The applicator must demonstrate knowledge of factors to consider before and during application, including all the following:
- Weather conditions that could impact application by affecting aircraft engine power, takeoff distance and climb rate or by promoting spray droplet evaporation
- How to determine wind velocity, direction and air density at the application site
- Potential impact of thermals and temperature inversions on aerial pesticide application
- Minimizing drift – The applicator must demonstrate knowledge of factors to consider before and during application, including all of the following:
- How to determine drift potential using a smoke generator
- How to evaluate vertical and horizontal smoke plumes to assess wind direction, speed and concentration
- Selecting techniques that minimize pesticide movement out of the area to be treated
- Documenting special equipment configurations or flight patterns used to reduce off-target pesticide drift.
- Performing aerial application – The applicator must demonstrate competency in performing an aerial pesticide application, including all the following:
- Selecting a flight altitude that minimizes streaking and off-target drift
- Choosing a flight pattern that ensures applicator and bystander safety and proper application
- The importance of engaging and disengaging spray precisely when entering and exiting a predetermined swath pattern
- Tools available to mark swaths such as GPS and flags
- Recordkeeping requirements for aerial pesticide applicators including application conditions if applicable
Certification Rule — Status
In November 2023, EPA announced final approval of 67 updated plans from state, territory, tribal and federal agency certifying authorities.
Recent Updates
NAAA is planning on surveying the state ag aviation association directors to determine how the EPA approved plans for each state deal with the requirement for the specialized certification requirements for aerial application.