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DIRECT SUPERVISION OF NONCERTIFIED APPLICATORS

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Requirements for Direct Supervision of Non-Certified Applicators

For more information, call toll-free 877-301-4555 or email pestlicenseupdates@agr.wa.gov.
The C&T rule changes include additional requirements for the direct supervision of noncertified (unlicensed) applicators using federal restricted use pesticides (RUPs). 

"Using" a federal restricted use pesticide includes mixing, loading, transporting, disposing of, and applying pesticides. See the Resources section below or RCW 17.21.020 for full definition of use, as in to "use a pesticide".
 
Updated Requirements (see below for more detailed information)
Minimum age Noncertified applicators must be at least 18 years old to use federal RUPs under the direct supervision of a certified (licensed) applicator. (exceptions apply for private applicators)
Recordkeeping Certified applicators who supervise noncertified people must maintain accurate records of their training.
Supervisor Responsibilites The supervising certified applicator must ensure that noncertified applicators meet all eligibility and training requirements.
Annual training Noncertified applicators must complete approved training every 12 months when applying federal RUPs.

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Minimum Age for NonCertified Applicators

Minimum age requirement
Private Applicators
(including Limited and Rancher)		 Noncertified applicators using federal RUPs under the direct supervision of a certified applicator must be 18 years old.

Exception: Noncertified applicators may be 16 or 17 years old if the supervising private applicator is an immediate family member and:
  • Pesticide used is not a fumigant and
  • Application is not made aerially.
All other applicators Noncertified applicators using federal RUPs under the direct supervision of a certified applicator must be at least 18 years old.

Supervisor Responsibilities

The supervising certified applicator must:
  • ​Hold a valid Washington license in the category of pest control being supervised.
  • Confirm that the noncertified applicator meets all requirements (training, minimum age, etc.).
  • Retain training records for each noncertified applicator using federal RUPs for a minimum of three years from the date the RUP was used.

Before supervising a noncertified applicator using a federal RUP, the supervising certified applicator must provide the following:
  • Access to product labeling during the use of the federal RUP.
  • Clean, label-required personal protective equipment (PPE) and training to ensure the noncertified applicator is wearing it properly when using the RUP.
  • Clear, site-specific instructions for the RUP being used.
  • Fully functioning equipment required to safely use the RUP.
  • Means to immediately communicate with the supervising certified applicator.
It is the licensed applicator's responsibility to provide the level of immediate communication that is specific to their license type. See Resources section for full definition.

Training Recordkeeping Requirements

Requirements for:  
Private Applicators 
(including Limited and Rancher)		 Recordkeeping must follow standards outlined in WAC 16-233-201, the Worker Protection Standard (WPS):
Records must include:
  • Non-certified applicator's full printed name and signature.
  • Date of training.
  • Information identifying which EPA-approved training materials were used.
  • Trainer's name and documentation showing that the trainer met requirements in WAC 16-233-201(3)(d).
  • Employer's name
All other applicators Supervising certified applicators must maintain training records for each noncertified applicator using federal RUPs.

Records must include:
  • Noncertified applicator's full name and signature.
  • Date the noncertified applicator completed required training.
  • Name of trainer who conducted the training session.
  • Title and brief description of training provided.
  • If applicator is licensed, their license number, expiration date, and certifiying authority (e.g., WSDA).

Training Requirements for Noncertified Applicators

Noncertified applicators can meet the training requirement for using federal RUPs one of three ways:
  1. Complete pesticide handler training under WAC 16-233-201,
  2. Hold a current pesticide certification in a category not specific to the application being made, or
  3. Complete a pesticide training program described below and in 40 CFR 171.201(2)(d).
Training must be completed before the first use of the RUP and every 12 months after that.

Find different available trainings in the Resources section below.

Required Training Topics

Specific topics must be covered in the annual training for noncertified applicators using federal RUPs. 
NOTE: This is not a comprehensive list. For a complete breakdown of the required topics, refer to 40 CFR 171.201(2)(d).
 
Topics include:  
Health hazards
  • Toxicity risks and exposure effects on applicators and their families (acute, chronic, delayed, senstization).
  • Routes of exposure (inhalation, dermal, ingestion) and how they occur.
  • Signs and symptoms of pesticide poisoning.
Emergency response and first aid
  • Eye flushing techniques.
  • Dermal exposure response: washing with soap and water, shampooing, changing clothes, etc.
  • Handwashing before eating, drinking, chewing gum or tobacco, or using the restroom.
  • When and how to seek emergency medical care.
Residue and exposure prevention
  • Risks from pesticide residues on clothing and footwear.
  • Special precautions for children and pregnant women.
Reporting violations
  • How to report suspected misuse to the director or appropriate enforcement agency.
Labeling and PPE requirements
  • Understanding pesticide labels including:
    • Restricted Use Pesticide (RUP) statements.
    • When a certified applicator must be physically present.
    • PPE specifications and proper use.
Heat-related illness
  • Recognition, prevention, and first aid response.
Safe handling and disposal
  • Procedures for transporting, storing, and disposing of pesticides.
  • General spill cleanup protocols.
Environmental impact
  • Risks of drift, runoff, and harm to wildlife from improper use.
Use restrictions
  • Who is authorized to apply RUPs.
  • Prohibition on taking pesticides or containers home from the worksite.
Certified applicator responsibilities
  • Oversight duties as outlined in previous sections.

Trainer Qualifications

The individual providing this required training must meet certain criteria.

Training must be conducted by an individual who meets one of the following criteria:
  • Currently licensed as a pesticide applicator in Washington State,
  • Designated as a WPS pesticide hander trainer, or
  • Has successfully completed an approved WPS train-the-trainer program.

Resources

The definition of use, as in to use a pesticide, includes activities beyond application. (RCW 17.21.020)

Using a federal RUP includes:
  • Preapplication activities involving mixing and loading the pesticide,
  • Applying the pesticide including, but not limited to, supervising the use of a pesticide by a noncertified applicator,
  • Transporting or storing pesticide containers that have been opened,
  • Cleaning equipment used to apply the RUP,
  • Disposing of excess pesticides, spray mix, equipment wash waters, pesticide containers, and other pesticide-containing materials.
The definition of direct supervision is different for different license types. (RCW 17.21.020(13))
 
License Type Direct Supervision Requirement
Private Applicator Immediately available when restricted use pesticides (RUPs) are used but does not have to be physically present for most uses.
Some highly toxic RUPs require on-site supervision or use by a certified applicator only.
Public Opeartor Must be physically present and always within eye and earshot of the unlicensed person when RUPs are used or during application of any pesticide using power equipment.
Commercial
Private Commercial
(Forestry only)		 Must be on-site and readily available to directly observe mixing and loading of pesticides.
If employee is only using general use pesticides with non-power equipment, does not require voice and visual contact.
All other certified applicators Must be physically present and always within eye and earshot of the unlicensed person when use occurs. 
  • Requirements for direct supervision of noncertified applicators by certified applicators, Federal Certification of Pesticide Applicators Rule, 40 CFR 171.201.
  • Application of certain pesticides by noncertified applicators, Washington Pesticides Application Act, RCW 17.21.450.

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