Private Applicators as Qualified Trainers

Requirement:

Title 3, California Code of Regulations (3CCR) section 6724(f) lists persons who are qualified to give pesticide handler training. The list includes “a California certified private applicator” without restrictions.

3CCR section 6764(e) lists persons who are qualified to give training for fieldworkers who will be working in treated fields. The list includes “a California certified applicator” without restrictions.

Interpretation:

A person holding a valid private applicator certificate is qualified to provide pesticide handler and fieldworker training on the same basis and scope as any of the other persons listed in 3CCR section 6724(f) and 6764(e).

Background:

When the Worker Protection Standard (WPS) regulations were adopted, private applicators were still being certified via a restricted materials permit. The training given at that time included a provision restricting the qualification of private applicators to training their own employees. This restriction is no longer appropriate in view of the fact that private applicators are now certified by written examination and subject to continuing education requirements for renewal. It was recently pointed out that this restriction had never been reviewed. This interpretation supercedes any previous policy that may conflict with it. We will be amending the WPS training module to reflect this position.

If you have any questions pertaining to the application of this interpretation, please contact your Senior Pesticide Use Specialist Liaison.

Sincerely,