drti pnA United States
Environmental Protection
M %Agency
WPSTrain-The-Trainer
Programs
Approval Process and Criteria
8/1/2017
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EPA's Process and Criteria for Approving WPS Train-The-Trainer Programs
Background: EPA's revised Worker Protection Standard (WPS) was published as a final rule on
November 2, 2015. The 2015 revision requires persons seeking to become trainers of workers and
handlers through completing a Train-the-Trainer program to qualify by completing an EPA-approved
Train-the-Trainer (TTT) program. This requirement becomes effective on January 2, 2017, meaning
that a person must complete an EPA-approved program to qualify as a WPS pesticide safety trainer
for workers and/or handlers before they train in 2017. EPA has prepared this guidance material to
facilitate the development of programs that meet EPA requirements.
1. How do I request EPA's approval of my WPS TTT program?
You may request approval for a Train-the-Trainer program by email. The email submission to EPA
should include:
	the requester's name, affiliation, contact information (email, telephone number),
	the materials in English,
	whether the program covers trainers of workers, handlers, or both,
	method of delivery (in-person, online, audiovisual, other media),
	non-English language translations planned & how translation will be verified as accurate,
	and if documentation of trainer's successful completion of the course will be provided, list
the contents and, if possible, provide an example form.
Format - The materials should be in an electronic draft form to allow for editing based on EPA
comments. A script and thorough description of content and key points will get a quicker review
than a video alone.
Language - The materials should be submitted in English.
Link between TTT materials and WPS requirements - The materials should indicate how each
point or section corresponds with required training elements for workers and handlers. Appendix
A contains a numbered list of the training elements for workers. Appendix B contains a
numbered list of the training elements for handlers. An example of a script (with annotations) for
a training video follows:
Scene X - "How Pesticides Can Get into the Body"
Video script text: "Workers can come into contact with pesticides when they touch a plant that
has been treated with a pesticide. Most contact is with the skin, but pesticides can enter the
body through the eyes, nose and mouth, as well. Other ways to encounter pesticides would be
by touching equipment that was used to apply a pesticide, or using water that has been used
for irrigation and that has pesticides in it. If a worker is in an area near a person applying a
pesticide, they may come into contact with the pesticide as it drifts, or even through direct
contact with a spray."
Training Components Covered:
	From APPENDIX A: Worker 4c.,4f.,4e.
	From APPENDIX B: Handler 4c., 4f., 4e., 6 (same as the worker citations)
Updates to TTT materials complying with 1992 WPS requirements - An existing program
designed to prepare trainers to deliver content from the 1992 rule can be submitted with an
updated section that addresses the training administration requirements of the 2015 revisions.
The program must meet the requirements under "Requirements for administering worker or
handler training" outlined in this document. Certain training elements were changed in the
revisions and must be addressed in the update as they are presented in the 2015 rule.
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2. To whom do I send my TTT program information?
All submissions should be sent electronically by email to:
	Kathy Davis, at ^yjsJtathy@fina.novand
	the EPA Regional WPS Coordinator, listed in Appendix C.
3. What are the minimum requirements for a TTT program?
The following listed components will satisfy the minimum requirements for a program under the 2015
revised WPS rule.
Training content - The materials should provide instruction on providing training that covers the
worker training content (170.401 (c)(3)(i)-(xxiii)) and/or handler training content (170.501 (c)(3)(i) -
(xiv)) required by the new rule which published on November 2, 2015. Please refer to Appendices
A and B for the training points.
Requirements for administering worker or handler training - The materials should inform the
trainers to present the training as follows to the worker (40 CFR 170.401(c)(1)) and/or handler (40
CFR 170.501(c)(1)) so that the training will meet the WPS requirements:
	Training must be provided either orally from written materials or audio-visually.
	Training must be provided in a manner the worker or handler can understand.
The following training administration requirements apply starting January 2, 2017:
	The training location must be reasonably free from distractions and be conducive to
training.
	Training materials for workers or handlers must be approved by EPA.
	Training for workers may be conducted only by certified applicators, state-, tribal-, or
EPA- designated trainers of applicators, handlers or workers, or persons who have
completed a TTT program. Training for handlers may be conducted only by certified
applicators, state-, tribal-, or EPA-designated trainers of certified applicators or
handlers, or persons who have completed a program. State law or tribal ordinance may
supersede these requirements and may require trainers to complete a state- or tribal-
specific program.
	The TTT program used to qualify as a trainer of worker or handlers must be EPA approved.
	Training must be provided annually. Handlers or workers who have not been trained
within the last 12 months must receive pesticide safety training.
	Workers must be trained before they enter an area that has been treated with a
pesticide or where an REI has been in effect within the last 30 days. Handlers must be
trained before they perform any handling task.
	A qualified trainer must be present during the training session to respond to any questions.
	Employers are responsible for maintaining records of worker and handler training. The
record must include:
o The trained handler's or worker's printed name and signature,
o Date of the training.
o Information identifying which EPA-approved training materials were used,
o Trainer's name and qualification to train (e.g., certified applicator license
number, TTT course information),
o Worker or handler employer's name.
	Employers must provide a copy of the training record to each worker or handler upon
his or her request.
4. Are there other elements that should be included in a TTT program?
Additional elements recommended but not required include:
 Documentation provided to qualified trainers. EPA recommends that the Train-the-Trainer
provider also keep records of trainers qualified through their training programs.
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	Provide an emphasis on training techniques for adult audiences.
	Provide an emphasis on providing information to low-literacy audiences.
	Include information about how to recognize and respond to cultural differences or sensitivities
	Incorporate state and local requirements and information into the training.
	Describe how to schedule trainings for farmworkers and handlers.
	Include pre- and post-training evaluation of the training to assess knowledge gained and for
course improvement.
5. Can I continue to train using my existing state-approved or state-developed TTT materials
until they are updated to satisfy the 2015 WPS rule content?
Yes. Until January 2, 2018, the TTT program is not required to cover the updated training content in
the 2015 rule. An existing state- or tribal-approved TTT program can be used to train trainers, but
those trainers can provide training on the old content only until the new training content is required on
January 2, 2018.
The existing training program must cover all the worker and/or handler training points from the 1992
rule, which can be found in the revised rule under 40 CFR 170.401(c)(2) for workers and 40 CFR
170.501 (c)(2) for handlers. However, the manner and administration of the training must be updated
to meet the 2015 requirements outlined above in section #3, "minimum requirements for a TTT
program" and "requirements for administering worker or handler training".
6.	What is the process for obtaining approval to use existing state- or tribal-developed or
state- or tribal-approved TTT programs until the new requirements must be in place?
An existing program designed to prepare trainers to deliver content from the 1992 rule can be
submitted with an updated section that addresses the training administration requirements of the
2015 revisions. The program must meet the requirements outlined in this document under
"Requirements for administering worker or handler training." Certain training elements were
changed in the revisions and must be addressed in the update as they are presented in the 2015 rule
The email submission to EPA seeking approval of an existing state- or tribal-developed TTT program
should include:
	submitter's name, state affiliation, email and physical address, telephone number;
	whether the program covers workers and/or handlers;
	updated section that addresses the 2015 requirements for administering worker or handler
training; and
	materials that will be used in the program.
The expiration date for the approval for these programs is January 1, 2018.
The EPA staff will promptly notify the submitter by email of EPA's receipt and decision on its
approval. Upon approval, an EPA approval number, as described above, will be provided, authorizing
the train-the-trainer program to add the following statement to the approved training materials: "EPA
has approved this interim Train-the-Trainer program as meeting the requirements of the WPS (40 CFR
170) for training (worker and/or handler) trainers. The approval number is EPA Interim Train-the-
Trainer XX."
7.	How will EPA determine if the TTT program is acceptable?
The EPA HQ staff and the relevant Regional staff will jointly review the program. If deficiencies are
identified, EPA will communicate with the submitter to address deficiencies. A program will be
determined to be acceptable if it meets the minimum criteria identified above. EPA will promptly
notify the requester, by email, of EPA's final decision on the material.
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EPA approval of a program does not address any state or tribal specific requirements for a program.
The provider is responsible for ensuring that programs also meet the requirements of states or tribes
with laws, regulations and/or ordinances that address pesticide safety. Some states and tribes may
require state or tribal approval of the program prior to its use in the jurisdiction.
8. How will EPA keep track of approved TTT programs? Will EPA require a statement on the
materials to show that it is approved?
EPA will assign a unique tracking number to each program and will record the submitter name and
contact information. Upon EPA's approval of the program, EPA will email the approval, including the
unique tracking number, to the requester. The assigned tracking number should be included on the
final program materials with the following language: "EPA has approved this Train-the-Trainer
program. It meets the requirements of the WPS (40 CFR 170) for training (worker and/or handler)
trainers. The approval number is EPA Train-the-Trainer XX."
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APPENDIX A: Worker Pesticide Safety Training Topics
Please use the reference numbers (and where appropriate, sub-letters) in the text of the TTT materials to
indicate where each point is covered. EPA will use the last two columns to review the TTT material.
Citation
Worker Training topic
Check
Cross reference to location
to

if in
of information in document
reference

text
(e.g., line number, page
number, topic heading)
1 .a.
The responsibility of agricultural employers to provide
workers and handlers with information and
protections designed to reduce work-related pesticide
exposures and illnesses. This includes ensuring
workers and handlers have been trained on
pesticide safety,


1.b.
That the employer must provide pesticide safety and
application and hazard information,


1.C.
decontamination supplies and


1.d.
emergency medical assistance,


I.e.
notification to workers of restrictions during
applications,


1.f.
notification to workers of restrictions to treated areas,


1.g.
and that a worker may designate a representative to
request, on their behalf, pesticide application and
hazard information


2.
How to recognize and understand the meaning of the
posted warning signs used for notifying workers of
restrictions on entering pesticide treated areas on the
establishment.


3.
How to follow directions and/or signs about keeping
out of pesticide treated areas subject to a restricted-
entry interval and application exclusion zones.


4.a.
Where and in what forms pesticides may be
encountered during work activities, and potential
sources of pesticide exposure on the agricultural
establishment. This includes exposure to pesticide
residues that may be on or in plants,


4.b.
on or in soil,


4.c.
tractors, application and chemigation equipment,


4.d.
used Personal Protective Equipment (PPE),


4.e.
and that pesticides may drift through the air from
nearby applications, or


4.f.
Be in irrigation water.


5.a.
Potential hazards from toxicity and exposure that
pesticides present to workers and their families,
including acute effects,


5.b.
chronic effects,


5.c.
delayed effects, and


5.d.
Sensitization.


6.
Routes through which pesticides can enter the body
(e.g., dermal, eye, nose, oral)


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7.
Signs and symptoms of common types of pesticide
poisoning


8.
Emergency first aid for pesticide injuries or
poisonings


9.a.
Routine and emergency decontamination
procedures, including emergency eye flushing
techniques, and


9.b.
if pesticides are spilled or sprayed on the body to use
decontamination supplies to wash immediately or
rinse off in the nearest clean water including streams,
springs, lakes, or other sources if they are more
readily available than decontamination supplies,


9.c.
and as soon as possible, follow up with wash or
shower with soap and water, shampoo hair, and
change into clean clothes


10.
How and when to get emergency medical care


11.a.
When working in pesticide treated areas, wear work
clothing that protects the body from pesticide
residues and


11.b.
Wash hands before eating, drinking, using the toilet,
or using chewing gum or tobacco.


12.a.
As soon as possible after working in pesticide-treated
areas, wash or shower with soap and water,
shampoo hair,


12.b.
and change into clean clothes


13.
There are potential hazards from pesticide residues
on clothing


14.a.
Wash work clothes before wearing them again and


14.b.
wash them separately from other laundry


15.
Do not take pesticides or pesticide containers used
at work home with you


16.
Safety Data Sheets (SDS) provide information about
hazards, emergency medical treatment and other
information about pesticides that are used on the
establishment


17.a.
The employer must display SDS for all pesticides
used on the establishment that you may come in
contact with,


17.b.
he must tell workers and handlers where the SDS
are located, and


17.c.
Allow workers and handlers access to the SDS
during normal working hours.


18.
Agricultural employers are prohibited by the rule from
allowing or directing a worker to mix/load/or apply
pesticides or assist in their application unless trained
as a handler


19a.
Agricultural employers must provide specific
information to early-entry workers before directing


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them to perform early-entry activities


19.b.
Early-entry workers must be 18 years of age or older.


20.
There are hazards to children and pregnant women
from pesticide exposure.


21.
Keep children and nonworking family away from
pesticide-treated areas.


22.a.
After working in pesticide-treated areas, remove
boots or shoes before entering your home and


22.b.
remove work clothes and wash or shower before
physical contact with children or family members


23.
How to report suspected use violations to the State
or Tribal agency responsible for pesticide
enforcement


24.
Agricultural employers are prohibited from
intimidating, threatening, coercing or discriminating
against any worker or handler for complying with or
attempting to comply with the requirements of this
rule, or because the worker or handler provided,
caused to be provided, or is about to provide
information to the employer or the EPA or its agents
regarding conduct that the employee reasonably
believes violates this part, and/or made a complaint,
testified, assisted, or participated in any manner in an
investigation, proceeding, or hearing concerning
compliance with this rule.


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APPENDIX B: Handler Pesticide Safety Training Topics
Please use the reference numbers below to reference in the text of the submitted TTT materials indicate
where each point is covered. See Appendix a (Worker Pesticide Safety Training Topics) for citations to
numbers 1-24. To the specific handler training points. EPA will use the last two columns to review the
TTT material.
Citation to
Handler Training topic
Check if
Cross reference to
reference

in text
location of information
in document (e.g., line
number, page number,
topic heading)
1-24.
Refer to citations 1. To 24. from worker training
topics


25.
Information on proper application and use of
pesticides.


26.
Handlers must follow the portions of the labeling
applicable to the safe use of the pesticide.


27.
Format and meaning of information contained on
pesticide labels and in labeling applicable to the
safe use of the pesticide.


28.
Need for and appropriate use and removal of all
personal protective equipment.


29.
How to recognize, prevent, and provide first aid
treatment for heat-related illness.


30.
Safety requirements for handling, transporting,
storing, and disposing of pesticides, including
general procedures for spill cleanup


31.
Environmental concerns, such as drift, runoff, and
wildlife hazards.


32.
Handlers must not apply pesticides in a manner
that results in contact with workers or other
persons.


33.a.
The responsibility of handler employers to provide
handlers with information and protections
designed to reduce work-related pesticide
exposures and illnesses. This includes
providing, cleaning, maintaining, storing, and
ensuring proper use of all required personal
protective equipment,


33.b.
providing decontamination supplies; and


33.c.
Providing specific information about pesticide use
and labeling information.


34.
Handlers must suspend a pesticide application if
workers or other persons are in the application
exclusion zone.


35.
Handlers must be at least 18 years old.


36.a.
The responsibility of handler employers to ensure
handlers have received respirator fit-testing,


36.b.
medical evaluation, and


36.c.
Respirator training, if a respirator is required by
the product labeling.


37.
The responsibility of agricultural employers to post
treated areas as required by this rule.


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APPENDIX C: Regional WPS Coordinators
Region 1:
Andrea Szylvian email: Szvlvian.Andrea@epa.gov
Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont
Region 2: Tara Glynn email: Glvnn.Tara@epa.gov
New Jersey, New York, Puerto Rico, US Virgin Islands
Region 3: Magda Rodriguez-Hunt email: Rodriguez-Hunt.Magda@epa.gov
Delaware, Maryland, Pennsylvania, Virginia, Washington DC, West Virginia
Region 4: Pat Livingston email: Livingston.Patricia@epa.gov
Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee
Region 5: Donald Baumgartner email: Baumgartner.Donald@epa.gov
Illinois, Indiana, Ohio, Michigan, Minnesota, Wisconsin
Region 6: Eugene Thilsted email: Thilsted.Eugene@epa.gov
Arkansas, Louisiana, New Mexico, Oklahoma, Texas
Region 7: Shawn Hackett email: Hackett.Shawn@epa.gov
Iowa, Kansas, Missouri, Nebraska
Region 8: Suzanne Stevenson email: Stevenson.Suzanne@epa.gov
Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming
Region 9: Katy Wilcoxen email: Wllcoxen.Katv@epa.gov
Arizona, California, Hawaii, Nevada
Region 10: Derrick Terada email: Terada.Derrick@epa.gov
Alaska, Idaho, Oregon, Washington
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