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1
of
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DRAFT
Ms.
Allison
Jones
Executive
Vice
President
National
Alliance
of
Independent
Crop
Consultants
349
E.
Nolley
Drive
Collierville,
TN
38017
Dear
Ms.
Jones:

The
purpose
of
this
letter
is
to
respond
to
your
June
26,
2002
written
request
seeking
EPA's
acknowledgment
that
the
Certified
Professional
Crop
Consultant­
Researcher
(
CPCC­
R)
Program
of
the
National
Alliance
of
Independent
Crop
Consultants
(
NAICC)
is
an
appropriate
certification
program
for
the
WPS
crop­
advisor
exemption.

EPA
has
reviewed
NAICC's
CPCC­
R
Program
and
concluded
that
the
program
includes
all
of
the
requirements
set
forth
in
EPA's
1996
Guidance,
as
described
below.
Therefore,
EPA
hereby
acknowledges
in
writing
that
NAICC's
CPCC­
R
Program
is
appropriate
for
the
WPS
crop­
advisor
exemption.

In
May
1995,
EPA
amended
the
Worker
Protection
Standard
(
WPS),
40
CFR170,
to
exempt
certain
certified
or
licensed
crop
advisors
(
and
persons
under
their
direct
supervision)
performing
crop
advising
tasks
from
specific
WPS
requirements
(
60
FR
21948,
May
3,
1995)
(
hereinafter
referred
to
as
the
"
WPS
crop­
advisor
exemption").
In
order
to
qualify
for
the
WPS
crop­
advisor
exemption,
the
crop
advisor
must
be
certified
or
licensed
as
a
crop
advisor
under
a
program
acknowledged
as
appropriate
in
writing
by
EPA
or
a
State
or
Tribal
lead
agency
for
pesticide
enforcement.

In
1996
EPA
issued
a
Guidance
to
States
for
Approving
and
Developing
Programs
Which
Recognize
Crop
Advisors
Qualified
for
the
Worker
Protection
Standard's
Crop­
Advisor
Exemption.
The
Guidance
identifies
the
minimum
requirements
that
EPA
expects
in
any
crop
advisor
certification
or
license
program
acknowledged
by
EPA
for
the
WPS
crop­
advisor
exemption.
The
Guidance
also
recommends
that
these
same
requirements
be
included
in
any
certification
or
license
program
that
a
State
or
Tribe
acknowledges
or
develops
for
the
WPS
crop­
advisor
exemption.

In
1996
EPA
reviewed
the
Certified
Professional
Crop
Consultant
(
CPCC)
Program
of
the
NAICC
and
the
Certified
Crop
Advisor
(
CCA)
Program
of
the
Agronomy
Society
of
America
(
ASA)
and
concluded
that
both
programs
included
all
of
the
requirements
set
forth
in
EPA's
1996
Guidance.
Accordingly,
EPA
acknowledged
in
writing
that
NAICC's
CPCC
Program
and
ASA's
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CCA
Program
are
appropriate
for
the
WPS
crop­
advisor
exemption.

Also,
pursuant
to
your
request
letter,
EPA
is
informing
the
State
and
Tribal
lead
agencies
for
pesticide
enforcement
of
this
decision
today
(
see
enclosure).
To
date,
EPA
has
acknowledged
in
writing
that
NAICC's
CPCC
Program
and
CPCC­
R
Program,
as
well
as
ASA's
CCA
Program,
are
appropriate
for
the
WPS
crop­
advisor
exemption.
Accordingly,
under
EPA's
regulations
at
40
CFR
§
§
170.104
and
170.204,
provided
that
all
other
specified
regulatory
requirements
are
met,
an
individual
certified
or
licensed
as
a
crop
advisor
under
NAICC's
CPCC
Program,
NAICC's
CPCC­
R
Program,
or
ASA's
CCA
Program,
and
persons
under
the
direct
supervision
of
that
certified
individual,
are
exempt
from
specific
WPS
requirements
while
performing
crop
advising
tasks
in
treated
areas.

If
you
have
any
questions,
please
contact
Kevin
Keaney,
Chief
of
the
Certification
and
Worker
Protection
Branch
at
703­
305­
7666.

Sincerely,

Jay
Ellenberger,
Acting
Director
Field
and
External
Affairs
Division
Enclosure
cc:
Jim
Jones
Anne
Lindsay
Kevin
Keaney
