Pesticide Use Enforcement Standards Compendium Volume 4, Inspection Procedures – Handler Training Requirements

This letter announces a correction to Pesticide Use Enforcement Standards Compendium Volume 4, Inspection Procedures. Compendium guidance incorrectly exempts Pest Control Advisors (PCA) and Registered Professional Foresters (RPF) from handler training requirements in Title 3 of the California Code of Regulations (3 CCR) section 6724. Currently, all the handler training requirements in Volume 4 state, in part:

PCAs and RPFs are exempt from certain worker safety regulations, including handler training requirements, while performing crop adviser tasks after the application is completed. This section does not exempt PCAs and RPFs from handler training requirements if they are doing other activities or in the field during a pesticide application. (3 CCR section 6720(d)(1)).

3 CCR section 6724(d) states, in part: certified private or commercial applicators, as defined in section 6000, and individuals with a manned or unmanned apprentice pilot certificate are considered trained for the purposes of this section. Since PCAs and RPFs are not included in the definition of certified private or commercial applicators, they are not considered trained handler and are not exempted from handler training if they decide to apply pesticides. If a PCA or RPF will be handling pesticides as part of their duties, they would need to obtain a Qualified Applicator License or Certificate, a manned or unmanned apprentice pilot certificate, or complete handler training.

The following have been updated:

• Chapter 4, Pesticide Use Monitoring Inspection Report.
  • Requirement 12, Handler Training. PCA and RPF exemption removed.
• Chapter 5, Commodity Fumigation Use Monitoring Inspection Report.
  • Requirement 12, Handler Training. PCA and RPF exemption removed.
• Chapter 6, Field Fumigation Use Monitoring Inspection Report.
  • Requirement 14, Handler Training. PCA and RPF exemption removed.
• Chapter 9, Pest Control Headquarters Inspection Report.
  • Requirements 14, 15, and 16, “N/A” example removed.
• Chapter 10, Pest Control Business Headquarters Inspection Report.
  • Requirements 6, 7, and 8, “N/A” example removed.

Updated chapters will be made available online for download here.

If you have any questions, please contact the Enforcement Branch Liaison assigned to your county.

Sincerely,