Make Sure You Have the Right Applicator's License
Farmers who purchase a new sprayer for their own use might be interested in helping pay for that sprayer by making additional applications for other farmers. Such applications, however, may require a different applicator's license than the one the farmer currently holds. The type of pesticide applicator's license required depends on the type of pesticide being applied, where it will be applied, and whether or not the application will generate a profit. In order to ensure that everyone has the proper license for the types of applications they might be making, we thought a review of license categories and requirements would be beneficial.
The first breakdown of who needs what license has to do with how the pesticide to be used is classified. Pesticides considered too hazardous for use by the general public are classified for "restricted use." Restricted use pesticides (RUP) will be prominently identified as such on their label—all others are general use pesticides. A pesticide license is required of anyone who wishes to purchase or apply a restricted use pesticide regardless of where the application is to be made. In addition, anyone applying any pesticide, restricted or general use, for hire or in the course of employment must have a license. In Illinois, you must be at least 16 years old to hold any type of pesticide applicator license.
The Illinois Pesticide Act requires individuals to become certified as a "private pesticide applicator" in order to purchase and use RUPs on land they own or control for the purpose of producing an agricultural commodity. A Private Pesticide Applicator License is required for persons who—for the purpose of producing an agricultural commodity primarily intended for sale, consumption, propagation, or other use by humans or animals—use or supervise the use of a restricted use pesticide (1) on property owned, rented, or leased by themselves or their employer, or (2) on no more than two neighbors' farms as exchange for labor.
If you make applications for no more than two neighbors' farms in exchange for labor with a general use pesticide, you do not need a license. If, however, you make any applications for profit or applications for more than two neighbors in exchange for labor, then you need a Commercial Applicator's License, no matter whether the pesticide is restricted use or general use. Farmers who do not use RUPs and do not make any pesticide applications for hire do not need to have a license at all.
To become certified as a Private Applicator, you must pass (70 percent correct) a written, closed book examination administered by the Illinois Department of Agriculture. There is a $20 fee for this three-year license. Private applicators wishing to purchase or apply grain fumigants to their own grain must also be certified in Grain Fumigation; the regular private applicator license is not valid for grain fumigation.
To make any application for profit, regardless of whether the pesticide is restricted or general use, you must be licensed as a Commercial for Hire Pesticide Applicator. An individual who applies a pesticide (restricted or general use) for any purpose on property other than that owned, rented, or leased by themselves or by their employer must be licensed as a Commercial for Hire Pesticide Applicator.
Generally, a commercial applicator is a person who owns or manages or is a supervisor for a business applying pesticides for profit. An applicator is the person in an organization who has the responsibility for pesticide purchasing, storage, handling, and use. Each organization must have at least one person licensed as an applicator at each facility location.
The categories included on the applicator's license dictate the areas in which a company may legally apply pesticides. Field Crops is the category one would need in order to spray corn, soybeans, small grains, or forages for hire. An applicator may use pesticides or supervise the use of pesticides by licensed operators.
Illinois issues Commercial for Hire Pesticide Operator licenses to qualified individuals who are employed and directly supervised by a person holding a Commercial for Hire Pesticide Applicator license. A licensed operator is permitted to operate application equipment; handle, mix, and apply pesticides; store pesticides; and dispose of excess pesticides and containers. A license will not be issued unless the person is working under the direct supervision of a licensed applicator. The applicator must be accessible to his or her operators when they are working with pesticides. If you work alone or are the only one in your company who applies pesticides, you must be licensed as an applicator.
Illinois law requires that Commercial Applicators and Operators pass (70% correct) a written, closed book General Standards examination. In addition, applicators must pass one or more category examinations appropriate for the sites to which they apply pesticides. As stated earlier, the required category for making applications to most agricultural crops grown in Illinois would be Field Crops. Exceptions are vegetable and fruit crops, which have their own categories.
All examinations are administered by the Illinois Department of Agriculture (IDA). Applicator and operator licenses are good for one calendar year and are renewable without examination for three years at the discretion of the Director of the IDA. For commercial licenses, the current fee is $60 for a 1-year applicator's license or $40 for a 1-year operator's license; the certification exam is valid for three years if no lapse in licensure occurs. All applicators and operators must reestablish competency (retest) at three-year intervals.
In addition to the annual fee, a Commercial Applicator applicant must either post a $50,000 surety bond (or two $25,000 bonds—one for bodily injury and the other for property damage) or provide evidence of general liability coverage. This general liability coverage must include a minimum of $50,000 per person and $100,000 per occurrence bodily injury, with an annual aggregate of not less than $500,000; or a combined single limit of not less than $100,000 bodily injury and property damage liability combined, with an annual aggregate of not less than $500,000.
For more information on both Private and Commercial Applicator licenses, including testing and training options, call University of Illinois Extension at 1-800-644-2123 or visit http://www.pesticidesafety.uiuc.edu.
(Scott Bretthauer and Bruce Paulsrud)
Bed Bug Increase Due to Pesticide Regulation?
Bed bugs have been increasing in Illinois and the rest of the United States for the past few years. Various hypotheses have been offered as causes of this occurrence. Some have suggested that increased air travel has resulted in more movement of bed bugs into this country. It has been suggested that bed bugs have adapted better to our home environments or that our home environments have changed to being more acceptable to bed bugs.
Another suggestion is that the switch from controlling cockroaches with baseboard crack and crevice spraying to using baits is the cause. This increased baiting, along with the loss of the registration of organophosphate insecticides for indoor use appear to be the most likely causes for the increase in bed bugs.
Bed bugs were very common in this country until organochlorine insecticides such as DDT and chlordane came into widespread use after World War II. Since the 1940s, bed bug infestations had become almost unknown, and even pest control operators ceased to recognize them or know how to control them.
Starting in the late 1950s and continuing through the 1960s, indoor insecticide use converted from the use of organochlorine to organophosphate and carbamate insecticides. The organophosphates chlorpyrifos (Dursban) and diazinon along with the carbamate propoxur (Baygon) became the indoor insecticides of choice to control cockroaches, silverfish, crickets, spiders, and most other pests. At about this same time and not really noticed by the general public, bed bugs developed insecticide resistance to the organochlorines.
Towards the end of the 1980s and through the 1990s, pyrethroid insecticides such as pyrethrins, allethrin, tetramethrin, permethrin, esfenvalerate, bifenthrin, cyfluthrin, cypermethrin, deltamethrin, d-phenothrin, imiprothrin, lambda-cyhalothrin, resmethrin, and tralomethrin partially replaced the organophosphates for indoor use. They are low or no odor materials compared to the smelly organophosphates and some provided several weeks of longevity after application like the organophosphates provided.
In 1996, the Food Quality Protection Act was passed by Congress and signed by President Clinton. It changed the risk assessment rules, resulting in the need to reduce the use of many pesticides. Some of the first pesticide groups to be addressed were the organochlorine, organophosphate, and carbamate insecticides. The quantity of pesticides applied is a major factor in these risk reduction guidelines.
Because pyrethroids are effective in insect control at much lower quantities and are lower in toxicity to humans than these other insecticides, they can be applied in many situations and stay within risk assessment guidelines. In general, registrants voluntarily removed registration for indoor as well as outdoor residential uses of organophosphates in order to keep uses for crop production. This caused indoor pest control to rely even more heavily on pyrethroids.
Pyrethroid insecticides have a very similar mode of action to that of organochlorines. They both interrupt the transmission of impulses along nerves. As pyrethroid use has increased, bed bugs along with other insect pests have exhibited cross resistance. Cross resistance is an accelerated resistance developed to a pesticide with the same or similar mode of action as a pesticide where resistance has already developed.
Bed bugs have now developed resistance to all pyrethroids labeled to control them. Very recent research has shown resistance in bed bugs to chlorfenapyr (Phantom), the last insecticide to provide residual control. Because different bed bug populations are typically resistant to some insecticides, but not all, some residual control is still being obtained. However, as resistance spreads between bed bug populations, residual control ability will disappear.
Interestingly, even bed bug populations resistant to many different insecticides show no resistance to chlorpyrifos (Dursban), an organophosphate insecticide. It might be appropriate for USEPA and registrants to revisit the elimination of organophosphate insecticide labeling for indoor use unless new, effective insecticides are about to be registered.
At this time, bed bug control relies on steam treatment, heat treatment, non-residual contact insecticides, and bed bug tight containment of mattresses and bed springs. These methods are not effective in every location that bed bugs inhabit and are labor consuming, resulting in high costs of control. These costs are high enough to be difficult or impossible to bear by lower income people. These high costs are probably increasing the likelihood of insecticide misuse. We may soon experience misuses like that of methyl parathion for cockroach control in Chicago and other locations across the country in the 1990s.
(Phil Nixon)
New Spray Equipment/Nozzle Publications
Two new Extension publications addressing effective spraying methods are now available online.
The first one is titled Droplet Size Calibration: A New Approach to Effective Spraying. This document explains what is involved in calibrating a boom sprayer to meet label specified droplet characteristics based on ASABE S-572 (Spray Nozzle Classification by Droplet Size). More and more labels are starting to include the droplet specific requirements for optimum coverage while minimizing drift. Scott Bretthauer, University of Illinois Pesticide Safety Education Specialist, is coauthor on this fact sheet (MF2869). Use the following link:
http://my.extension.uiuc.edu/documents/332091703090309/MF2869.pdf
The second publication is specific to boomless nozzles and reports on some research done at Kansas State University regarding the use of boomless nozzles to spray pastures, rangeland, roadsides, etc. The link to this document is:
http://www.oznet.ksu.edu/library/ageng2/EP156.pdf
(Robert Wolf, Extension Specialist Application Technology, Kansas State University)
Can Amiben, a Cancelled Herbicide, Still Be Used?
Recently we received an email from a person who wanted to use a herbicide that hasn't been registered for use since the early to mid-1990s. Amiben (chloramben) was the product and he intended to apply it in his vegetable garden. What he wanted from us was pest control recommendations from the 1980s. It's not every day we get requests like this.
Of course many questions arose. Because it's no longer registered, can the product still be used legally according to label directions? If so, can it be legally used on produce as tolerances on food crops no longer exist? Why was the product cancelled? Did it have safety issues or was it some other reason? Would the product still be effective after all those years? Was the product label still intact and legible? If not, could a replacement label still be obtained? These are some serious issues and after some careful debate, our advice to him was that he not use the product and instead dispose of it properly. End of story. Problem solved.
Still, I could not help but wonder if it would be legal to use up the existing stocks. I then consulted with EPA Region 5 for answers to these tough (and nagging) questions.
We learned that the uses of the products were cancelled in 1993, but the Federal Register stated that EPA did not revoke the tolerances (raw agricultural commodity use) until March 1, 1999 to allow for use of existing stocks. Because the tolerances have been revoked, the product is illegal to use on food crops (for sale). However, this product could still be used for non-food uses unless the cancellation notice specifically set a cutoff date for these uses. For example, it was labeled for conifers, shrubs, and hardwood trees. Because the inquiry was specifically on vegetables, we did not dig into the archived files deep enough to find if a cutoff date had been issued for these ornamentals.
In the end, our assessment is that the garden owner could legally use Amiben on his own garden provided he did not sell or give away any of the produce. It is my understanding that food tolerances would not apply in this particular situation. There is a potential liability that exists with sharing food that has been treated with a canceled product. What if the person gets sick? If applied at label directions, it is unlikely that anything would happen. However, the potential still exists. Why take chances?
Also in question is how and when the cancelled pesticide was obtained. Amiben could be legally applied to the owner's garden only if the product was acquired back when it was still legal to sell and distribute Amiben. If it was purchased recently from say either a neighbor or a sale on the internet, it would be illegal to apply. So, the cancelled products in your possession are yours forever unless you dispose of them properly or use them according to label directions.
Another big issue with applying old pesticides is the loss of effectiveness in control. My guess is that the product's performance would be less than stellar. Most pesticides begin to lose effectiveness after about 5 years. How effective can a product be when it is at least 16 years old? Would you rely on medicine that was that old?
Before using an old pesticide, the first step is to determine whether it will mix properly. Emulsifiable concentrates can separate into two or more components. Once they separate, they frequently will not mix back together. This also makes it unlikely that they will form an emulsion in the spray tank. In other words, the pesticide will not mix with the water or other carrier. Old wettable powders may clump together and not form a uniform suspension. Using a jar test will let you know whether the pesticide will mix properly. Emulsifiable concentrates may also discolor with age, turning dark or milky. In some cases they will still be effective as pesticides, but a color change is certainly an indication that they may not.
If your pest infestations are minor, it can be worth a try to use old products. The product is already paid for. If the herbicide fails and you have a few weeds emerge, institute plan B in your weed management program. The alternative is to dispose of the product properly, which can be easier said than done if you have large stocks. Information can be found on the product label or by calling the manufacturer. Pesticide Disposal Options can be found in the July 2001 issue of this newsletter.
It is recommended, of course, that you not get yourself into this situation of having old pesticides on hand. Only purchase enough pesticides for the current growing season and storage won't likely be an issue. Use up the pesticides you have before purchasing new ones. Sometimes it is best to simply apply old pesticides to a labeled area rather than putting them in a landfill. Think of your children. If you die tomorrow, what is your spray cabinet filled with that your kids are going to inherit? Is there the slight chance that your kids will be a little displeased with you? Or, perhaps your pesticide inventory is at work and your coworkers will be the lucky recipients. Are all containers clearly labeled? Contact the pesticide's manufacturer for replacement labels if original ones are badly stained or missing.
We at the Pesticide Safety Education Program welcome any "interesting" pesticide related queries you might have. They help to keep our jobs interesting and they certainly provide us fodder for newsletter articles. (Michelle Wiesbrook; specific formulation information was contributed by Phil Nixon.)
The EPA Revokes Carbofuran Tolerances
As of May 11, 2009, the EPA has issued a final rule revoking all carbofuran tolerances. Carbofuran is an N-methyl carbamate insecticide and nematicide that has been registered to control pests in soil and on leaves in a variety of field, fruit, and vegetable crops. No residential uses are registered. The EPA has concluded that dietary, worker, and ecological risks are unacceptable for all uses of carbofuran. All products containing carbofuran do not meet safety standards and therefore are ineligible for reregistration.
After considering public comment on the agency's July 2008 proposal, the EPA concluded that the combined exposure to carbofuran from food and water significantly exceeds EPA's level of concern for children, and it does not meet the U.S. food safety standard. Based on these findings, the EPA plans to proceed with cancellation of any remaining carbofuran uses due to unreasonable ecological and worker risks. Because dietary exposures to infants and children are of particular concern, the agency has moved to revoke carbofuran tolerances first, before canceling remaining carbofuran registrations.
Carbofuran is used on only a small percentage of the U.S. food supply, and most food is not expected to contain carbofuran residues. Carbofuran tolerances for all commodities will be revoked effective Dec. 31, 2009. This means that no food crops in the U.S. will be allowed to have residues of carbofuran after December 31, unless it can be shown that the crop was treated before that date. EPA is encouraging growers to switch to safer pesticides or other environmentally preferable pest control strategies. The agency has set the effective date in December because they believe this is the quickest time frame in which the decision can be practically implemented, and to ensure that growers have been provided with a reasonable amount of time to allow them to develop appropriate pest management strategies.
Following a public comment period, EPA granted a request from the registrant, FMC Corporation, for voluntary cancellation of certain uses of and products containing flowable and granular carbofuran effective March 18, 2009. In December 2008, FMC requested cancellation of 22 uses of the pesticide. At that time, FMC sought to retain six uses, including four food uses. Since EPA could not make a safety finding in food and water, EPA announced the Final Tolerance Revocations on May 11, 2009.
All federally registered uses of carbofuran have been canceled except for four food crop uses (field corn, potatoes, pumpkins, and sunflowers) and two non-food crop uses (pine seedlings and spinach grown for seed). Certain state Special Local Need registrations are also being canceled, as requested by FMC Corporation.
Although carbofuran uses have benefits, none of these are sufficient either to individual growers or at the national level to outweigh the substantial combined occupational and ecological risks. EPA concluded that carbofuran products pose an unreasonable risk to man and the environment, which outweighs the benefits of continued use.
After EPA issued the Interim Reregistration Eligibility Decision, the carbofuran registrants submitted for the agency's review a number of studies addressing ecological and human dietary risk, as well as other informational documents. The federal EPA reviewed all submitted data and documents, as well as additional data developed by the agency's Office of Research and Development. While these submissions resulted in certain refinements to the agency's assessment, the EPA continues to believe that all uses of carbofuran should be canceled for the reasons identified above.
Somewhat different from previous pesticide announcements, step one of this process was to revoke the tolerances under FFDCA due to acute dietary risks to children (food plus water) and step two is to issue a Notice of Intent to Cancel the uses of the pesticide at a later date. All remaining food tolerances will be revoked in December 2009, 90 days after the rule becomes effective (the rule becomes effective 60 days after publication in the Federal Register).
The Final Rule will become effective provided a stay is not requested by the registrant or affected growers within the 60 days following publication. The announcement was signed on May 11, 2009 by the Director of the Office of Pesticide Programs and then published in the Federal Register within 14 days. Several expected implications of this decision include the need for growers treating grain with carbofuran this year to keep good records of the date of application of the pesticide.
The EPA's action is focused on promoting greater food safety. The U.S. has a safe and abundant food supply, and children and others should continue to eat a variety of foods, as recommended by the federal government and nutritional experts.
(Source: EPA email announcement sent May 11, 2009. Slightly modified and reduced by James E. Schuster, Extension Specialist, PSEP – Plant Pathology Crop Sciences Department, University of Illinois.)
Handle Pesticide Clothing with Care
The pair of soiled work jeans doesn't look dangerous. But if they contain a pesticide residue, they may be a health hazard – not only to the wearer but possibly also to other family members.
When people work with pesticides, whether in the garden or in the field, they often contaminate their clothing with the pesticide they are using. This contamination can occur through direct spills onto the clothing or through pesticide particles drifting through the air and onto the clothing. And the contamination can occur regardless of the formulation of the pesticide–liquid, powder, or granular.
Although pesticides differ in their toxicity, with some much more dangerous than others, the long-term effects of even the least toxic pesticides are uncertain. It is wise for handlers of pesticides to exercise caution in use, cleanup, and laundering. And if pesticide residue is not removed during laundering, it may be absorbed through the worker's skin the next time the garment is worn.
Studies of fabrics by textiles researchers show that fiber content makes no significant difference in the amount of pesticide removed when laundered. But shirts and pants made of 100% polyester allow more penetration of pesticides, and should not be worn during pesticide application.
To properly launder pesticide-contaminated clothing follow these procedures:
Be certain the person doing the laundry is aware of the pesticide used, the clothing that was worn, and has access to the pesticide labels for information on clean-up and disposal.
• Discard clothing that is soiled with full-strength liquid concentrate pesticides. This may seem costly, but keeping clothes that have been saturated with pesticides is too high of a risk.
• Put the pesticide worker's clothing in a separate container from other items in the family laundry. Use a plastic garbage bag for collecting contaminated clothing. Or, use a plastic garbage pail that is designated for pesticide contaminated garments.
• Wear waterproof gloves to handle pesticide contaminated clothing. Wash the gloves thoroughly before removing. Dispose of the gloves using the guidelines on the pesticide container labels. DO NOT use the gloves for any other household task.
• Launder clothing as soon as possible after each day's use. The concentration of pesticide in fabric builds with successive exposures. The more concentrated the pesticide, the more difficult it is to remove in laundering.
• Always pre-treat, pre-rinse or pre-wash pesticide contaminated clothing and do not reuse the water. If the washing machine has a pre-rinse cycle, it should be used.
• Launder pesticide contaminated clothing separately from other household laundry. Wash together only garments contaminated with the same pesticide, since a combination of pesticides makes removal of each chemical more difficult.
• Use hot water – 120 to 140 degrees – for laundering. To save energy, a cold-water rinse may be used.
• Use either a heavy-duty liquid detergent or the amount of powdered detergent that is recommended by the manufacturer for heavily soiled loads.
• Wash only a few items at one time, use the highest water setting, and do not overcrowd the washer.
• Use the cycle for heavy-soiled clothes on the washer – or a 10-12 minute wash cycle with rinse cycles following.
• Use of other laundry additives, such as bleach, ammonia or fabric softeners, does not appear to affect pesticide removal.
• Clothing worn while using slightly toxic pesticides may be effectively laundered in one to three washings. More than three washings of clothing contaminated with more toxic or more concentrated pesticides are strongly recommended.
• Line dry clothing when possible to avoid transfer of any residue to the dryer. Sunlight can degrade some pesticides but if line drying is not possible, use the high heat setting on the dryer. Pesticides tend to be volatile, so hot air helps reduce contamination.
• After washing pesticide contaminated clothing, clean the washer with an "empty load" of hot water and detergent and run the washer through the complete cycle before the washer is used to launder other family laundry.
(Materials adapted by Ellen Burton, Extension Educator, Consumer and Family Economics, University of Illinois Extension, February, 2001, from:
Guides for Laundering Clothes Soiled with Pesticides, University of Illinois Extension, Marge Sohn, Extension Specialist, Textiles and Clothing, 1994.
Pesticide-Contaminated Clothing Needs Washing Care, Ohio State University Extension Fact Sheet, Textiles and Clothing, Judith A. Wessel, Joyce Smith, Norma Pitts, 1994 .
What to do when clothes are soiled with pesticide, Iowa State University, University Extension, Janis Stone, Professor and Extension Textiles and Clothing Specialist, 2000.
Reprinted with permission. Taken from http://www.ace.uiuc.edu/cfe/pesticides/ on May 29, 2009.)
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