U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

On December 12, 2016, EPA issued revisions to the existing Certification of Pesticide Applicators rule (40 CFR 171). These revisions provide assurance
that certified applicators and noncertified applicators under their direct supervision are competent to use restricted use pesticides (RUPs) in a manner
that will not cause unreasonable adverse effects on human health or the environment.

Note that this document provides general guidance to EPA, certifying authorities, certified applicators, and the public. This document is not binding on
EPA or any outside parties, and EPA may depart from the guidance where circumstances warrant and without prior notice. The full text of the revised
regulation and more information on the final changes to the regulation are available at: www.epa.gov/pesticide-worker-safety/revised-certification-
standards-pesticide-applicators.

Item

Final Requirement

Proposed Revision

Existing Rule

Enhance Private
Applicator
Competency
Standards

Private applicators must demonstrate
competency in pest control in the production of
agricultural commodities in regard to topics
similar to those in the core competency
standards for commercial applicators (i.e., label
and labeling comprehension; safety;
environment; pests; pesticides; equipment;
application techniques; laws and regulations;
responsibilities for supervisors of noncertified
applicators; stewardship).

Private applicator competency must include
ability to read and understand pesticide
labeling.

Eliminate the proposed competency standard
that required candidates to identify specific
pests.

171.105(a)

Private applicators must demonstrate
competency in pest control in the production of
agricultural commodities in regard to topics
similar to those in the core competency
standards for commercial applicators (i.e., label
and labeling comprehension; safety;
environment; pests; pesticides; equipment;
application techniques; laws and regulations;
responsibilities for supervisors of noncertified
applicators; stewardship).

Private applicator competency must include
ability to read and understand pesticide
labeling.

Private applicators must be certified as
competent on 5 general topics:
recognizing pests, reading and
understanding labeling, applying
pesticides in accordance with the
labeling, recognizing environmental
conditions and avoiding contamination,
recognizing poisoning symptoms and
procedures to follow in the case of a
pesticide accident.

December 20, 2016

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Strengthen

Private

Applicator

Competency

Gauge

Private applicators must either attend a training
program covering the mandatory competency
standards or pass a written exam.

Private applicators must either attend a
training program covering the mandatory
competency standards or pass a written exam.

Private applicator certification can be
done by written or oral exam, or other
method approved as part of the State
certification plan.

Eliminate Non-
Reader

Certification for

Private

Applicators

No "non-reader" option for persons who cannot
read to obtain certification to use specific RUPs.

No "non-reader" option for persons who
cannot read to obtain certification to use
specific RUPs.

States can offer an alternative, product-
specific certification process for persons
who cannot read.

Pollinator
Issues

No specific requirements related to pollinator
protection added to regulation.

Applicators in categories likely to affect
pollinators should receive information on
protecting pollinators in competency standards
under "avoiding harm to non-target organisms"
and under reading and understanding labeling
requirements.

Add "presence of pollinators" as topic under
"Environment" heading in proposed general
private applicator competency standards and
commercial core competency standards.

Requested comment on whether to add
pollinator protection to proposed training
program for noncertified applicators.

No specific competency standards
related to pollinator protection.

December 20, 2016

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Establish

Additional

Categories for

Private and

Commercial

Applicator

Certification

Establish categories for private and commercial
applicators performing: aerial application, soil
fumigation, and non-soil fumigation.

No concurrent certification required.

Certifying authorities are not required to adopt
these categories if a category is not needed in a
particular jurisdiction.

Allow certifying authorities to combine soil
fumigation and non-soil fumigation into a single
certification category.

171.101 (m)-(o), 171.103(d)(13)-(15),
171.105(d)-(f)

Establish categories for private and commercial
applicators performing: aerial application, soil
fumigation, and non-soil fumigation.

For commercial applicators, require concurrent
certification in at least one pest control
category to be eligible for certification in
application method-specific category.

No additional certification required to
use certain application methods that
may present higher risks if not
conducted properly.

December 20, 2016

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Allow Certifying
Authorities to
Develop a
"Limited Use"
Category

Allow certifying authorities to adopt a limited
use category. A limited use category covers a
small number of applicators engaged in a use
that does not clearly fit within any of the
commercial applicator categories, and allows
only the use of a limited set of RUPs by specific
application methods. See Unit VII. B. of the
preamble for more details.

Certification plans must include the following
elements for each limited use category:

•	A definition of the limited use category,
specifying the RUPs, use sites, and specific
application methods permitted

•	An explanation of why it is not practical to
include the limited use category in any of the
existing commercial categories

•	A requirement that candidates for certification
in a limited use category pass the core exam
and demonstrate competency to use RUPs
covered by the limited use category

•	Specific competency standards for the limited
use category

•	Process for applicators to demonstrate
competency to use the RUPs covered by the
limited use category; does not have to be
accomplished by a written examination

•	A description of the recertification standards for
the limited use category

•	A description of the limited use certification
credential (must clearly only authorize purchase
and use of specific RUPs)

171.303(a)(4)

No change proposed; requested comments on
whether to allow certifying authorities to
develop/adopt "limited use" category to certify
commercial applicators.

All commercial applicators must certify
by passing written exams covering core
and category competency standards.

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Establish
Predator
Control
Categories for
Private and
Commercial
Applicator
Certification

Add categories for private and commercial
applicators: sodium fluoroacetate (Compound
1080) in livestock protection collars and
sodium cyanide delivered through M-44
devices.

Certifying authorities are not required to adopt
these categories if a category is not needed in a
particular jurisdiction.

171.101 (k)-(l), 171.103(d)(l 1 )-(12),
171.105(b)-(c)

Add categories for private and commercial
applicators: sodium fluoroacetate (Compound
1080) in livestock protection collars and
sodium cyanide delivered through M-44
devices.

No predator control categories
established in rule. Registration
decisions and labeling for sodium
fluoroacetate (Compound 1080) used in
livestock protection collars and sodium
cyanide delivered through M-44 devices
include specific competency standards
and require applicators to be
competent.

Identification of
Candidates for
Certification
and

Recertification

Require all candidates for initial certification
(exam or training) and recertification by exam

to present a government-issued photo
identification OR other similarly reliable form of
identification approved by the certifying
authority.

171.103(a)(2)(iii), 171.105(h)(1), 171.105(h)(2)(i)

Require certifying authorities to verify
successful completion of each recertification
course/event (e.g., training, workshop,
continuing education), including the identity of
candidates for recertification. No specific
requirement to verify identity based on
government-issued photo identification.

171.107(b)(l), 171.107(b)(2)(iii)

Require candidates to present identification

for initial and recertification exams and training
sessions.

No requirement to present identification
at exam or training sessions.

December 20, 2016

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Establish Exam
Standards

All exams must be proctored. Only materials
approved by the certifying authority, provided
and collected by the proctor, may be used
during exams (final rule does not use the term
"closed-book exams").

Requires certifying authorities to adopt specific
exam administration standards; allows certifying
authorities to establish standards that meet or
exceed federal standards.

171.103(a)(2), 171.303(a)(5)-(6)

Codify policy requiring all exams to be closed
book and proctored.

Impose specific requirements for exam
administration and security on the proctor.

Competency for commercial applicators
must be determined on the basis of
written examination. EPA policy
requires that all certification exams be
closed book and proctored.

Enhance
Competence of
Noncertified
Applicators of
RUPs

Qualify as a noncertified applicator of RUPs by
any of the following:

•	Completing training outlined in the rule
at 171.201(d).

•	Completing training as a handler under
the Worker Protection Standard (WPS)
(40 CFR 170).

•	Holding a valid applicator certification in
an unrelated category or from another
jurisdiction.

•	Satisfying the requirements for
noncertified applicators established by
the certifying authority that meet or
exceed federal standards.

Training requirements must be satisfied
annually.

171.201(c)

Noncertified applicators must receive annual
training on safe pesticide application and
protecting themselves and others from
pesticide exposure (similar to WPS handler
training).

Exemption from training requirement for those
with valid WPS handler training and those who
have passed the commercial core exam.

Noncertified applicators must be
competent to use RUPs. No specific
training requirements. For specific
applications, the certified applicator
must provide verifiable instructions
including detailed guidance for applying
the pesticide.

December 20, 2016

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Establish
Qualifications
for Trainers of
Noncertified
Applicators

Noncertified applicator training outlined in the
rule at 171.201(d) can only be provided by one
of the following: a currently certified
applicator, a certifying authority-designated
trainer of certified applicators or handlers, or a
person who has completed an EPA-approved
train-the-trainer course under the WPS.

171.201(d)(2)

Noncertified applicator training can only be
provided by one of the following: a currently
certified applicator, a certifying authority-
designated trainer of certified applicators or
handlers, or a person who has completed an
EPA approved train-the-trainer course under
the WPS.

The certified applicator provides
required instructions. No qualifications
required other than certification.

Establish

Qualifications

for Certified

Applicators

Supervising

Noncertified

Applicators

Supervising applicators must:

•	Be certified in the category in which they
supervise applications.

•	Ensure noncertified applicators under their
supervision are qualified under
171.201(b)(2) and (c), including the
minimum age requirement.

•	Ensure the noncertified applicator has
access to applicable labeling during use
and provide specific instructions related to
the application.

•	Ensure noncertified applicator has PPE and
wears it properly for the intended purpose.

•	Ensure equipment is in proper operating
condition.

Ensure a means for immediate communication

between the supervisor and supervisee is

available.

171.201(b)

Supervising applicators must:

•	Be certified in the category in which they
supervise applications.

•	Ensure noncertified applicators under
their supervision have satisfied the
training requirement.

•	For specific applications, provide a copy of
all applicable labeling to the noncertified
applicator and provide specific instructions
related to the application.

Ensure a means for immediate communication

between the supervisor and supervisee is

available.

Supervising applicators must
demonstrate practical knowledge of
supervisory requirements. For specific
applications, supervising applicator must
provide detailed guidance for applying
the pesticide properly and provisions for
contacting the certified applicator.

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Expand

Commercial

Applicator

Recordkeeping

to Include

Noncertified

Applicator

Training

Require commercial applicators to verify the
existence of and have access to records
documenting noncertified applicators'
qualification. Record content depends on
method of qualification.

Must have access to records for 2 years from
date of RUP use.

171.201(e)

Require commercial applicators to maintain
records of noncertified applicators' training

that include: the trained noncertified
applicator's printed name and signature, the
date of the training, the name of the person
who provided the training, and the supervising
commercial applicator's name.

No commercial applicator recordkeeping
required related to providing verifiable
instructions to noncertified applicators.

Establish a
Minimum Age
for Certified
Applicators

Persons must be at least 18 years old to be
certified as a commercial or private applicator.

171.103(a)(1), 171.105(g)

Persons must be at least 18 years old to be
certified as a commercial or private applicator.

No minimum age requirement.

Establish a
Minimum Age
for Noncertified
Applicators

Persons must be at least 18 years old to qualify
as a noncertified applicator using RUPs under
the direct supervision of a commercial or private
applicator.

Exception: Persons using RUPs under the
supervision of a private applicator who is an
immediate family member must be at least 16
years old. The exception does not apply if the
RUP is a fumigant, sodium cyanide, sodium
fluoroacetate, or an RUP to be applied aerially.

171.201(b)(2)(iii)

Persons must be at least 18 years old to qualify
as a noncertified applicator using RUPs under
the direct supervision of a commercial or
private applicator.

No minimum age requirement.

Establish a
National
Certification
Period

Require all applicators to renew their
certification (recertify) at least everv 5 vears.

171.107(a)

Require all applicators to renew their
certification (recertify) at least every 3 years.

States must ensure that applicators
maintain a continuing level of
competency and ability to apply
pesticides safety and properly.

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Recertification
Requirements

Recertification must include satisfactory
completion of continuing education or exam.
Establish performance standards for certifying
authorities to develop and administer
recertification programs.

For recertification by continuing education,

states must adopt criteria for:

•	quantity of continuing education required to
maintain certification

•	content covered by the continuing education
program and how the certifying authority
ensures the required content is covered

•	process the certifying authority uses to
approve continuing education courses or
events, including how any continuing
education courses or events verify the
applicator's successful completion of the
course or event

•	how the certifying authority ensures the on-
going quality of the continuing education
program

For recertification by exam, states must
establish:

•	the process for reviewing, and updating as
necessary, the written examination(s) to
ensure that they evaluate whether a certified
applicator continues to demonstrate
competency

No requirements for when training must occur
during the 5-year period.

171.107(b), 171.303(b)(4), 171.305(b)(3)

One continuing education unit (CEU) is 50
minutes of active training time.

To renew their certification, commercial
applicators must earn 6 CEUs covering core
content and 6 CEUs per category of
certification, or they must pass written exams
for core and each category of certification.

To renew their certification, private applicators
must earn 6 CEUs covering the general private
applicator certification requirements and 3
CEUs per category of certification, or they
must pass written exams for general private
applicator certification and each category of
certification.

Applicators must earn at least half of the
required CEUs in the 18 months preceding the
expiration of their certification.

States must ensure that applicators
maintain a continuing level of
competency and ability to apply
pesticides safety and properly.

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

State Plan
Modification to
Implement
Changes

Certification plans must meet or exceed new
standards and requirements.

171.303,171.305

Certification plans must meet or exceed new
standards and requirements.

Certification plans must meet or exceed
existing standards and requirements.

Noncertified
Applicators/Use
of RUPs under
the Supervision
of a Certified
Applicator

Certifying authorities may adopt standards for
noncertified applicators that meet or exceed
the federal standards, or prohibit the use of
RUPs by noncertified applicators under the
direct supervision of certified applicators.

171.303(b)(5), 171.305(b)(4)

States, tribes, and territories may either adopt
the proposed standards for noncertified
applicator training or prohibit the use of RUPs
by noncertified applicators working under the
direct supervision of certified applicators.



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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Program
Reporting and
Accountability

Certifying authorities must report:

•	For private and commercial applicators -
new, recertified, and total number of
applicators holding certifications, by
category and subcategory (if applicable).

•	Any changes to the certification plan not
previously evaluated by EPA.

•	Any planned changes to the certification
plan.

•	A summary of enforcement activities
related to the use of RUPs.

171.303(c), 171.305(c)

Reporting must include:

•	For private and commercial applicators -
new, recertified, and total number of
applicators holding certifications, by
category and subcategory (if applicable).

•	Any changes to the certification plan not
previously evaluated by EPA.

•	Any planned changes to the certification
plan.

•	Number, description and narrative
discussion of enforcement actions taken
for incidents involving RUPs.

Reporting must include:

•	Total number of applicators, private
and commercial, by category,
currently certified; and number of
applicators, private and commercial,
by category, certified during the last
reporting period.

•	Any changes in commercial
applicator subcategories.

•	A summary of enforcement activities
related to use of restricted use
pesticides during the last reporting
period.

•	Any significant proposed changes in
required standards of competency.

•	Proposed changes in plans and
procedures for enforcement
activities related to use of restricted
use pesticides for the next reporting
period.

•	Any other proposed changes from
the State plan that would
significantly affect the State
certification program.

Civil and
Criminal
Penalty
Authority

States must have authority to assess civil and
criminal penalties for commercial and private
applicators. Tribes and federal agencies must
have other specified means of enforcing
compliance.

171.303(b)(7)(iii), 171.305(b)(5), 171.307

States must have authority to assess civil and
criminal penalties for commercial and private
applicators.

States must have authority to assess civil
and/or criminal penalties for commercial
and private applicators.

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Commercial

States must require commercial applicators to

States must require commercial applicators to

State plans must include requirements

Applicator

maintain records about RUP use including:

maintain records about RUP use including:

for certified commercial applicators to

Recordkeeping

• Name and address of person for whom

• Name and address of person for whom

maintain for at least 2 years routine



RUP applied

RUP applied

operational records containing



• Location of application

• Location of application

information on kinds, amounts, uses,



• Size of area treated

• Size of area treated

dates, and places of application of RUPs.



• Site to which RUP was applied

• Site to which RUP was applied





• Time and date of application

• Time and date of application





• Product name and EPA registration number

• Product name and EPA registration





of RUP applied

number of RUP applied





• Total amount of RUP applied per

• Total amount of RUP applied per





application and location

application and location





• Name and certification number of certified

• Name and certification number of certified





applicator and name(s) of any noncertified

applicator and name(s) of any noncertified





applicator that made the application under

applicator that made the application under





the direct supervision of the certified

the direct supervision of the certified





applicator.

applicator.





States must require commercial applicators to

States must require commercial applicators to





verify and have access to specific records

maintain records related to the qualifications





related to the qualifications of noncertified

of noncertified applicators working under





applicators working under their direct

their direct supervision.





supervision.









Records are to be maintained for at least 2





Records are to be maintained for at least 2

years.





years.







171.303(b)(7)(vi)





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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

RUP Dealer
Recordkeeping

RUP dealer recordkeeping must include:

•	Name and address of each person to whom
the RUP was distributed or sold.

•	The applicator's certification number,
issuing authority, certification expiration
date, and categories of certification.

•	The product name and EPA registration
number of the RUP(s) distributed or sold in
the transaction, and the State special local
need registration number on the label of
the RUP if applicable.

•	The quantity of the pesticide(s) distributed
or sold in the transaction.

•	The date of the transaction.

Records are to be maintained for at least 2 vears

171.303(b)(7)(vii)

RUP dealer recordkeeping must include:

•	Name and address of each person to whom
the RUP was distributed or sold.

•	The applicator's certification number,
issuing authority, certification expiration
date, and categories of certification.

•	The product name and EPA registration
number of the RUP(s) distributed or sold in
the transaction, and the State special local
need registration number on the label of
the RUP if applicable.

•	The quantity of the pesticide(s) distributed
or sold in the transaction.

•	The date of the transaction.

Records are to be maintained for at least 2

years.

No federal requirement for RUP dealers
to maintain records, except for any State
or area of Indian country where EPA
implements a certification plan.

Certified

Applicator

Credentials

Certifying authorities must describe the
credentials or documents they will issue to
each applicator verifying certification.

171.303(a)(8), 171.305(a)(9)

Certified applicator credentials must include:

•	The full name of the certified applicator.

•	The certification, license, or credential
number of the certified applicator.

•	The type of certification (private or
commercial).

•	The category(ies), including any application
method-specific category(ies) and
subcategories of certification, in which the
applicator is certified, as applicable.

•	The expiration date of the certification.

•	A statement that the certification is based
on a certification issued by another State,
Tribe or Federal agency, if applicable, and
the identity of that State, Tribe or Federal
agency.

No federal requirements for what
information must be included on
documents used to verify an applicator's
certification.

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Reciprocal
Applicator
Certification

Certification plans must specify whether, and if
so under what circumstances, the certifying
authority would issue a certification, based in
whole or in part, on a certification issued by
another certifying authority.

Reciprocal certifications subject to specific
conditions.

No requirement for reciprocal certification to
terminate automatically upon termination of
the original certification.

171.303(a)(9), 171.305(a)(10)

Certification plans must specify whether, and if
so under what circumstances, the state would
issue reciprocal certifications.

Reciprocal certifications subject to specific
conditions.

State plans must describe any
arrangements with other states or
jurisdictions relating to reciprocity.

No requirements for states to provide
specific information on their
requirements and procedures for issuing
reciprocal certification.

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

State Plan
Maintenance,
Modification,
and Withdrawal

Codify policy that substantial modifications

include:

•	Addition or deletion of a mechanism for
certification and/or recertification.

•	Establishment of a new private applicator
subcategory, commercial applicator
category, or commercial applicator
subcategory.

•	Any other changes that the Agency has
notified the State, Tribal or Federal agency
that the Agency considers to be substantial
modifications.

171.309

Codify policy that substantial modifications

include:

•	Deletion of a mechanism for certification
and/or recertification.

•	Establishment of a new private applicator
subcategory, commercial applicator
category, or commercial applicator
subcategory.

•	Any other changes that the Agency has
notified the State, Tribal or Federal agency
that the Agency considers to be substantial
modifications.

States may not make substantial
modifications to their certification plan
without EPA approval.

The regulation does not outline what
constitutes a substantial modification.

EPA policy states that substantial
modifications include:

•	Deletion of a mechanism for
certification and/or recertification.

•	Establishment of a new private
applicator subcategory, commercial
applicator category, or commercial
applicator subcategory.

•	Any other changes that the Agency
has notified the State, Tribal or
Federal agency that the Agency
considers to be substantial
modifications.

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Establish
Provisions for
Review and
Approval of
Federal Agency
Plans

Delete Government Agency Plan option from
the regulation.

Codify existing policy to allow Federal agencies
to develop their own plans for certifying Federal
agency employee applicators.

Federal agency certification plans must meet or
exceed the standards in the regulation.

171.305

Delete Government Agency Plan option from
the regulation.

Codify existing policy to allow Federal agencies
to develop their own plans for certifying
Federal agency employee applicators.

Federal agency certification plans must meet
or exceed the standards in the proposed
regulation.

Option to develop a single, federal
government-wide Government Agency
Plan to certify federal employees
applying RUPs. Government Agency
Plan never developed.

Current EPA policy allows Federal
agencies to develop their own plans for
certifying Federal agency employee
applicators, as long as the plan meets or
exceeds the applicable standards in the
regulation for State plans, and complies
with requirements of the policy.

Clarify Options
for Establishing
a Certification
Program in
Indian Country

Three options for applicator certification

programs in Indian Country:

•	Tribes may enter into an agreement with
EPA (region(s) to recognize certifications
issued under other EPA-approved
certification plans (State, Tribal, or Federal)

•	Tribes may develop and implement a Tribal
certification plan (requires Tribes to
develop and submit a Tribal certification
plan that meets or exceeds the standards)

•	EPA may administer a Federal certification
plan for applicators in Indian country that
meets or exceeds the standards. EPA may
include multiple tribes and geographic areas
under a single plan.

171.307

Three options for applicator certification

programs in Indian Country:

•	Tribes may enter into an agreement with

EPA to recognize certifications issued under
other EPA-approved certification plans
(State, Tribal, or Federal)

•	Tribes may develop and implement a
Tribal certification plan (requires Tribes to
develop and submit a Tribal certification
plan that meets or exceeds the proposed
standards)

•	EPA may administer a Federal certification
plan for applicators in Indian country that
meets or exceeds the proposed standards.
EPA may include multiple tribes and
geographic areas under a single plan.

Three options for applicator certification

programs in Indian Country:

•	Tribes may utilize State certification
to certify applicators (requires
concurrence by the State(s) and an
appropriate State-Tribal agreement)

•	Tribes may develop and implement
a Tribal certification plan (requires
Tribes to develop and submit an
appropriate Tribal certification plan
to EPA for approval)

•	EPA may administer a Federal
certification plan for applicators in
Indian country

December 20, 2016

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U.S. Environmental Protection Agency
Detailed Comparison of Revisions to EPA's Certification of Pesticide Applicators Rule (40 CFR 171)

Item

Final Requirement

Proposed Revision

Existing Rule

Revise

Provisions for
EPA-

Administered
Plans

EPA-administered federal certification plans
must meet the standards for State certification
plans, including RUP applicator certification,
recertification, and noncertified applicator
qualifications, as well as plan reporting and
maintenance requirements.

171.311

EPA-administered federal certification plans
must meet the proposed standards for State
certification plans, including RUP applicator
certification, recertification, and noncertified
applicator qualifications, as well as plan
reporting and maintenance requirements.

The current rule establishes
requirements for EPA-administered
certification plans in States or areas of
Indian country without EPA-approved
certification plans in place, including
specific standards for certification and
recertification of pesticide applicators.

Implementation
Schedule

Certifying authorities must submit revised
certification plans within 3 years of effective
date of final rule.

If revised plan is timely submitted to EPA,
existing plan will remain in effect until revised
plan is approved by EPA.

Timeframe for implementation/compliance with
revised certification plan will be decided on a
case-by-case basis as part of EPA's review and
approval of each revised certification plan.

171.5

Certifying authorities must submit revised
certification plans within 2 years of effective
date of final rule.

Existing certification plans may remain in effect
up to 4 years from effective date of the rule.

After 4 years from effective date of the rule or
EPA approves revised certification plan, all
certification must be done in accordance with
revised certification plan.

Not applicable.

December 20, 2016

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