An individual with current private certification does not need any additional requirement for mixing/loading/handling, their current certification will allow them to do mixing/loading/handling of RUPs. However, those who ONLY mix/load/handle RUPs and are not currently certified, they need private certification.
What additional steps will farmers need to take to remain compliant?
An individual with current private certification, farmer who applies RUPs on their farm, does not need any additional requirement to remain in compliant. Their current certification is sufficient to mix/load/handle RUPs.
For mixer/loader/handler, there is no requirement of recordkeeping. For pesticide applicators, there are 3 new requirements added to Pesticide Application Records:
- Size of treated area/units treated
- Total amount of RUP applied/application
- Crop, commodity, stored product, animals, or sites treated for RUP applications
Revised recordkeeping templates can be found on the Pesticide Application Record Templates page.
How can businesses prepare, and what support will the MDA offer for the new record-keeping requires?
For mixer/loader/handler, there is no requirement of recordkeeping. For pesticide applicators, there are three new requirements added to Pesticide Application Records:
- Size of treated area/units treated
- Total amount of RUP applied/application
- Crop, commodity, stored product, animals, or sites treated for RUP applications
Revised recordkeeping templates can be found on the Pesticide Application Record Templates page.
For new application recordkeeping requirements, the MDA will be working with pesticide industry to bring applicators in compliance for the next three years. The MDA has started communicating on recordkeeping and other legislative changes with industry via recertification workshops, mass mailing, emails, and meetings with industry associations.
For mixer/loader/handler, there is no requirement of recordkeeping. For pesticide applicators, there are 3 new requirements added to Pesticide Application Records:
- Size of treated area/units treated
- Total amount of RUP applied/application
- Crop, commodity, stored product, animals, or sites treated for RUP applications
Revised recordkeeping templates can be found on the Pesticide Application Record Templates page.
How can businesses prepare, and what support will the MDA offer for the new record-keeping requires?
For mixer/loader/handler, there is no requirement of recordkeeping. For pesticide applicators, there are three new requirements added to Pesticide Application Records:
- Size of treated area/units treated
- Total amount of RUP applied/application
- Crop, commodity, stored product, animals, or sites treated for RUP applications
Revised recordkeeping templates can be found on the Pesticide Application Record Templates page.
For new application recordkeeping requirements, the MDA will be working with pesticide industry to bring applicators in compliance for the next three years. The MDA has started communicating on recordkeeping and other legislative changes with industry via recertification workshops, mass mailing, emails, and meetings with industry associations.
The MDA will be working with pesticide industry to bring these new individuals (who mix/load/handle RUPs) in compliance for the next three years. The MDA will communicate these new requirements to regulated clientele using, the MDA webpage, mass mailings, emails, recertification workshops, attending pesticide association meetings. The MDA may pursue an enforcement action when individuals do not get the right license after repeated warnings. Also, an enforcement action may be taken without any warning if an applicator provided false information about themselves on the application form.
Will there be routine inspections or audits to ensure compliance?
At this point, the MDA is not planning to conduct routine inspections specifically to mixer/loader/handler licensing requirements.
The MDA will be working with pesticide industry to bring these new individuals (who mix/load/handle RUPs) in compliance for the next three years. The MDA will communicate these new requirements to regulated clientele using, the MDA webpage, mass mailings, emails, recertification workshops, attending pesticide association meetings. The MDA may pursue an enforcement action when individuals do not get the right license after repeated warnings. Also, an enforcement action may be taken without any warning if an applicator provided false information about themselves on the application form.
Will there be routine inspections or audits to ensure compliance?
At this point, the MDA is not planning to conduct routine inspections specifically to mixer/loader/handler licensing requirements.
RUPs have the higher potential to cause unreasonable adverse effects to the environment and injury to applicators or bystanders without added restrictions. Having these products applied and handled by licensed individuals reduce the risk to our environment.
Can you share any data or research that informed these changes?
EPA categorize pesticides as an RUP based on their risk assessment.
RUPs have the higher potential to cause unreasonable adverse effects to the environment and injury to applicators or bystanders without added restrictions. Having these products applied and handled by licensed individuals reduce the risk to our environment.
Can you share any data or research that informed these changes?
EPA categorize pesticides as an RUP based on their risk assessment.
If the independent contractor just drives their truck, they do not need a license, but if the independent contractor helps in mixing/loading/handing of RUPs, they need a license. It is the independent contractor’s responsibility to hold the appropriate license.
A private owner operator is hired to provide a truck and driver to pull coop XYZ’s tender trailer. Would they be required to obtain a Commercial license? Is a private license sufficient?
If a private owner operator’s driver just pulls coop XYZ’s tender trailer they do not need a license, but if the private owner operator’s driver helps in mixing/loading/handing of RUPs for hire, they need a commercial license. Private certification is ONLY for those who apply/mix/load/handle RUPs at their farm for the production of farm commodity.
If the independent contractor just drives their truck, they do not need a license, but if the independent contractor helps in mixing/loading/handing of RUPs, they need a license. It is the independent contractor’s responsibility to hold the appropriate license.
A private owner operator is hired to provide a truck and driver to pull coop XYZ’s tender trailer. Would they be required to obtain a Commercial license? Is a private license sufficient?
If a private owner operator’s driver just pulls coop XYZ’s tender trailer they do not need a license, but if the private owner operator’s driver helps in mixing/loading/handing of RUPs for hire, they need a commercial license. Private certification is ONLY for those who apply/mix/load/handle RUPs at their farm for the production of farm commodity.
No, you do not need a license to handle repacked SEALED RUPs.
