CHARACTERISTICS
OF
ITEMS
PROPOSED
FOR
CHANGE
IN
C&
T
AND
WPS
Prepared
by
Amy
Brown,
Kerry
Richards,
and
Carol
Ramsay
with
input
from
the
American
Association
of
Pesticide
Safety
Educators
(
AAPSE)

14
March
2006
Proposed
C
&
T
Change
Most
Benefit
to
Safety,

Environment,
&/
or
Security
Most
Significant
Programmatic
Impact
Needs
Most
Discussion
1.
Expand
users
(
beyond
RUP)
required
to
demonstrate
competency
high
benefit
extremely
high
impact
on
Ext.
and
SLA
yes
2.
Eliminate
"
under
the
supervision"
high
benefit
extremely
high
impact
on
Ext.
and
SLA
yes
3.
Require
RUP
dealers
to
prove
competency
­­
high
impact
on
SLA
­­

4.
Require
trainers
to
prove
competency
­­
high
impact
on
Extension
and
SLA
yes
5.
Set
minimum
age
for
occupational
users
­­
­­
­­

6.
Require
testing
for
all
occupational
users
­­
high
impact
on
SLA
yes
7.
Set
standard
requirements
for
testing
­­
high
impact
on
SLA
yes
8.
Competency
requirements
consistent
with
risk
high
benefit
­­
­­

9.
Ensure
continued
competency
of
applicators1
­­
­­
­­

10.
Ensure
maintenance
of
current
knowledge2
high
benefit
­­
yes
11.
Develop
standard
certification
categories
­­
high
impact
on
Extension
and
SLA
­­

12.
Equalize
standards
for
states/
tribes/
territories
­­
­­
­­

13.
Assure
program
accountability
­­
­­
yes
Proposed
WPS
Change
Most
Benefit
to
Safety,

Environment,
&/
or
Security
Most
Significant
Programmatic
Impact
Needs
Most
Discussion
1.
Ensure
meaningful
hazard
communications
­­
high
impact
on
Ext.
and
SLA
­­

2.
Ensure
meaningful
training
­­
­­
­­

3.
Require
trainers
to
demonstrate
competency
high
benefit
high
impact
on
SLA
yes
4.
Establish
training
verification
system
­­
high
impact
on
SLA
­­

5.
Protect
children
from
pesticide­
treated
fields
high
benefit
­­
­­

6.
Clarify
vague
WPS
provisions
­­
­­
­­

7.
Clarify
exceptions
­­
­­
­­

8.
Exempt
certified
crop
advisors
and
aerial
applicators
­­
­­
­­

9.
Require
handlers
to
demonstrate
competency
high
benefit
extremely
high
impact
on
Ext.
and
SLA
yes
10.
Express
regulation
in
plain
English
­­
­­
­­

11.
Assure
program
accountability
­­
­­
yes
Proposed
Label
Change2
Most
Benefit
to
Safety,

Environment,
&/
or
Security
Most
Significant
Programmatic
Impact
Needs
Most
Discussion
1.
Amend
rules
to
make
applicator
certification
changes
enforceable
high
benefit
­­
­­

2.
Amend
rules
to
make
ag.
worker
protection
changes
enforceable
high
benefit
­­
­­

3.
Revise
labels
to
conform
to
rule
changes
high
benefit
­­
­­

1We
have
re­
worded
this
heading
to
make
it
consistent
with
the
heading
of
the
slide
in
which
the
proposed
change
is
described.
Our
understanding
is
that
this
item
refers
to
testing.

2We
have
re­
worded
this
heading
to
make
it
consistent
with
the
heading
of
the
slide
in
which
the
proposed
change
is
described.
Our
understanding
is
that
this
item
refers
to
continuing
education
or
recertification
training.
