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1
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DRAFT
State
and
Tribal
Government
Pesticide
Lead
Agencies
Dear
Colleague:

The
purpose
of
this
letter
is
inform
you
of
the
Agency's
recent
response
to
the
National
Alliance
of
Independent
Crop
Advisors
(
NAICC)
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
has
acknowledged
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
CFR
170,
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
cropadvisor
exemption.
The
Guidance
notes
that
any
program
acknowledged
by
EPA,
a
State
or
a
Tribe
must
include
pesticide
safety
training
that
conveys
at
least
all
of
the
information
required
by
the
WPS
for
a
pesticide
safety
training
program
for
handlers,
as
specified
in
40
CFR
§
170.230(
c)(
4).
The
Guidance
also
recommends
additional
requirements
to
be
included
in
any
certification
or
license
program
that
a
State
or
Tribe
acknowledges
or
develops
for
the
WPS
crop­
advisor
exemption.
These
additional
requirements
are
as
follows:

°
a
written
test
for
competency;
°
a
requirement
for
experience;
°
a
requirement
for
continuing
education;
and
°
a
specific
license/
certification
renewal
period.

In
1996
EPA
reviewed
the
Certified
Professional
Crop
Consultant
(
CPCC)
Program
of
the
National
Alliance
of
Independent
Crop
Consultants
(
NAICC)
and
the
Certified
Crop
Advisor
Program
(
CCA)
of
the
Agronomy
Society
of
America
(
ASA)
and
concluded
that
both
programs
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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
CCA
Program
are
appropriate
for
the
WPS
crop­
advisor
exemption.
Recently,
EPA
reviewed
NAICC's
Certified
Professional
Crop
Consultant­
Researcher
(
CPCC­
R)
Program
and
similarly
concluded
that
the
program
includes
all
of
the
requirements
set
forth
in
EPA's
1996
Guidance.
Accordingly,
EPA
has
acknowledged
in
writing
that
NAICC's
CPCC­
R
Program
is
appropriate
for
the
WPS
cropadvisor
exemption
(
see
Attachment).

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
the
NAICC's
CPCC
Program,
NACC's
CPCC­
R
Program,
and
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.

Sincerely,

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