EPA Releases Temporary Guidance Regarding Certification of Pesticide Applicators During COVID-19

Last week, EPA released guidance providing information on how State Lead Agencies can make temporary modifications their Certification Plans during the public health emergency and still remain in compliance with the Federal Certification and Training Rule. Normally, substantial changes to certification plans must be approved by EPA, but this guidance provides details on conditions under which temporary changes will be pre-approved. Specifically, EPA cites the following changes as pre-approved by the agency for the remainder of the public health emergency:

• Relying upon training or testing conducted by or approved by another certifying authority for applicator certification or recertification;
• Offering remote (e.g., internet-based) testing or testing administered by a third party as long as the requirements of 40 CFR 171.103 related to exam administration and security are satisfied;
• Offering remote (e.g., internet-based) training rather than, or in addition to, face-to-face training for applicator certification or recertification;
• Extending the duration of the certification/recertification period so those with expiring certifications would still have a valid certification, so long as no certification extends beyond five years (per 40 CFR 171.107(a)); and
• Where existing state, tribal or federal agency requirements are more stringent than the requirements of 40 CFR part 171, any modification to make the state, tribal or federal agency certification program consistent with 40 CFR part 171, including:
• Suspending any or all certification requirements for applicators of general use pesticides (i.e., non-RUPs); and
• Allowing use of RUPs under the direct supervision of a certified applicator in accordance with 40 CFR 171.201.

NPMA has been working closely with state associations through the NPMA State Policy Affairs Representatives (SPAR) on certification and testing issues across the country. This guidance will help State Lead Agencies implement modifications to their programs that will ensure that our industry can continue to provide essential pest control services during the COVID-19 pandemic.