ENTFACT-801: Supervision and Training Requirements for Non-Certified Applicators  |  Download PDF

by Ric Bessin, Extension Specialist
University of Kentucky College of Agriculture

With recent changes to the EPA Certification and Training rule, a new category of agricultural pesticide applicator has been created: The Non-Certified Applicator under Supervision of a Certified Applicator. This has been adopted in Kentucky for non-certified applicators to apply restricted or general use pesticides under the supervision of a certified private applicator. With this new designation there are very specific requirements for minimum qualifications, annual training, responsibilities of the supervising private applicator, and recordkeeping. This factsheet outlines the requirements of the program. 

Supervising Private Applicator

1. Must understand the applicable regulatory and label-specific requirements to supervise non-certified applicators (NCA); and
2. Must be licensed in each category applicable to the supervised pesticide use.

Non-certified Applicator

1. Must have been trained as a NCA within the last 12 months;
2. Must have been instructed in the safe operation of any equipment he or she will use for mixing, loading, transferring, or applying pesticides; and
3. The NCA is at least 18 years old, except that a NCA may be at least 16 years old the NCA is using the pesticide under the direct supervision of a private applicator who is an immediate family member.

Use-specific conditions

1. Supervising private applicator (SPA) shall ensure that the NCA has access to the applicable product labeling at all times during its use;
2. That all required personal protective equipment (PPE) is properly worn for mixing, loading, application, or any other use activities. The SPA must ensure that the NCA has clean, labeling-required PPE in good condition;
3. Provide to each NCA instructions specific to the site and pesticide used. These include labeling directions, precautions, and requirements applicable to the specific use and site, and how the characteristics of the use site (e.g., surface and ground water, endangered species, local population) and the conditions of application (e.g., equipment, method of application, formulation) might increase or decrease the risk of adverse effects. The SPA must provide this information in a manner that the NCA can understand;
4. SPA must ensure that before each day of use, equipment used for mixing, loading, transferring, or applying pesticides is in proper operating condition, and can be used without risk of reasonably foreseeable adverse effects to the NCA, other persons, or the environment;
5. SPA must ensure that a means to immediately communicate with the SPA is available to each NCA using pesticides under his or her direct supervision; and
6. SPA shall be physically present at the site when required by the product labeling.

Annual Training Program

General training information shall be presented in a manner that NCAs can understand, such as through a translator. The person conducting the training shall be present during the entire training program and must respond to the NCAs’ questions. The person who conducts the training shall be currently licensed as a private applicator or in an appropriate certified category. The training materials must include the information that NCAs need in order to protect themselves, other people, and the environment before, during, and after making a pesticide application. The training materials shall include, at a minimum, the following: 

1. Potential hazards from toxicity and exposure that pesticides present to NCAs and their families, including acute and chronic effects, delayed effects, and sensitization;
2. Routes through which pesticides can enter the body;
3. Signs and symptoms of common types of pesticide poisoning;
4. Emergency first aid for pesticide injuries or poisonings;
5. Routine and emergency decontamination procedures, including emergency eye flushing techniques. NCAs must be instructed that if pesticides are spilled or sprayed on the body, to immediately wash or to rinse off in the nearest clean water;
6. How and when to obtain emergency medical care;
7. After working with pesticides, wash hands before eating, drinking, using chewing gum or tobacco, or using the toilet;
8. Wash or shower with soap and water, shampoo hair and change into clean clothes as soon as possible after working with pesticides;
9. Potential hazards from pesticide residues on clothing;
10. Wash work clothes before wearing them again and wash them separately from other clothes;
11. Do not take pesticides or pesticide containers used at work to your home;
12. Potential hazards to children and pregnant women from pesticide exposure;
13. After working with pesticides, remove work boots or shoes before entering your home, and remove work clothes and wash or shower before physical contact with children or family members;
14. How to report suspected pesticide use violations to the Kentucky Department of Agriculture;
15. Format and meaning of information contained on pesticide labels and in labeling for safe use of the pesticide, including the location and meaning of the restricted use product statement, how to identify when the labeling requires the SPA to be physically present during the use of the pesticide, and information on PPE;
16. Need for, and appropriate use and removal of, PPE;
17. How to recognize, prevent, and provide first aid treatment for heat-related illness;
18. Safety requirements for handling, transporting, storing, and disposing of pesticides, including general procedures for spill cleanup;
19. Environmental concerns such as drift, runoff, and wildlife hazards;
20. Restricted use and general use pesticides may be used only by a licensed operator, a licensed applicator, a private applicator or by a NCA working under the direct supervision of a licensed operator or licensed applicator;
21. SPA’s responsibility to provide to each NCA instructions specific to the site and pesticide used. These instructions must include labeling directions, precautions, and requirements applicable to the specific use and site, and how the characteristics of the use site (e.g., surface and ground water, endangered species, local population, and risks) and the conditions of application (e.g., equipment, method of application, formulation, and risks) might increase or decrease the risk of adverse effects. SPA must provide these instructions in a manner the NCA can understand;
22. SPA’s responsibility to ensure that each NCA has access to the applicable product labeling at all times during its use;
23. SPA’s responsibility to ensure that required PPE be worn for mixing, loading, application, or any other use activities, each NCA has clean, labeling-required personal protective equipment in proper operating condition and that the PPE is worn and used correctly;
24. SPA’s responsibility to ensure that before each day of use equipment used for mixing, loading, transferring, or applying pesticides is in proper operating condition, and can be used without risk of reasonably foreseeable adverse effects to the NCA, other persons, or the environment;
25. SPA’s responsibility to ensure that a means to immediately communicate with the SPA is available to each NCA using restricted use pesticides under his or her direct supervision.

Recordkeeping

The SPA must have records documenting that a NCA has the qualifications required. The SPA must maintain training records for the NCAs that must contain all of the following information: 

1. The non-certified applicator’s printed name and signature;
2. The date the training requirement was met;
3. The name of the person who provided the training; and
4. The title and a description of the training provided.

SPA must have records containing this information before allowing the NCA to use any pesticides under his or her direct supervision. SPA must maintain these records the for 3 years from the date the NCA used the pesticide. 

Issued: 10/22