As part of your lawn and/or landscape business, do you apply pesticides? Or do you plan to apply pesticides? These highly regulated chemicals are often a common element of maintaining an attractive lawn and garden, which means you fall under “Commercial Applicator” guidelines. A commercial applicator is anyone applying pesticides on the property of another for a fee, in other words, being paid to treat property you do not own.
State laws are often stricter than those of the Environmental Protection Agency (EPA). In most states, the Department of Agriculture, or extension service, is responsible for license testing. Testing usually consists of two exams: a core exam and another exam in a specific category, such as Turf and Ornamental. However, there are a number of other categories, such as: Aquatic; Right-of-way; Public Health; etc. Should a landscaper choose to add additional services, s/he would need to take the applicable category exam. Once the core exam is passed, however, it doesn’t need to be taken again as long as the license is maintained. Most states also require license holders to have a certain amount of general liability insurance.
When preparing for testing, landscapers should have a practical knowledge of: a pesticide label; pest identification and management; pesticide formulations; laws and regulations; pesticide application equipment; basic calculations; and pesticide safety. Study guides for the core exam and the category exam can generally be purchased from your extension service, state Department of Agriculture, or the state agency tasked with regulating pesticide use. In some states, an extension service may provide a prep course prior to taking the exam. Most states offer a computer-based exam performed at a local technical college or testing center.
Once licensed, a landscaper must:
- Attend trainings to obtain certification units (CEUs). The number of CEUs hours required varies state to state but in general, the license holder has a period of 3-5 years to obtain these. Also, these trainings serve as a way for the applicator to continue learning about pesticides, laws governing them, pest identification, and new sampling and application techniques. Most states require the license holder to renew their license annually. License holders need to make sure their address and contact information are current with the agency that issues the license.
- Notify the licensing agency if you change jobs or your mailing address. If you’re an employee who took the test, it is your license, not your employer’s license. Therefore, the license goes with you.
- Maintain application records. This means for every single pesticide application, the who, what, where, when, why, and how must be recorded. (See example on facing page.) Additionally, these records must be maintained for a period of at least two years, but I recommend keeping them longer.
- Expect a visit from a regulatory agent that conducts pesticide inspections in your area. Some inspector’s conduct inspections every two to three years, however, it varies. During these visits, inspectors will be looking at your pesticide application records, pesticides used, and pesticide storage.
- Be on-site or nearby during applications if necessary. Generally, only one person per company has to be licensed since the other employees can work under one license holder. But there are some exceptions. If you are applying a Restricted Use Pesticide (RUP), then the licensed applicator must be on-site (as per the label). Also, if your state has direct supervision laws in place, this means a “signal” word on the pesticide container will determine the distance the licensed applicator can be from the application site. For example, in South Carolina, any pesticide which has the signal word “Caution” on the label requires the license holder to be within 100 miles by ordinary ground transportation of the application site and immediately available by telephone or radio.
- Conduct training. If you become licensed and allow someone working under your direction to apply pesticides, then you are ultimately responsible. Therefore, it is imperative to conduct in-house training with staff about proper pesticide use. If the employee applying pesticides is licensed, however, then they assume responsibility for the application.
- Wear your Personal Protective Equipment (PPE)! The pesticide label lists the minimum PPE required. Also, you are responsible for providing PPE to any staff that apply pesticides as a part of his/her job.
- Check the requirements of surrounding states if you have clients there. Some states allow reciprocal licenses. This means that if you hold a license in one state, and apply in a neighboring state, you would not be required to retake the exam. Being previously licensed, you would fill out an application, pay a fee, and then be licensed in two states.
Becoming a licensed pesticide applicator can provide an additional revenue stream to a landscaping operation. However, it also comes with responsibility and is a decision not to be taken lightly. If a company decides to add this service, it’s a good idea to have more than one person become licensed. In this way, if one licensed applicator leaves, is on vacation, or off for any period of time, pesticide application services do not need to be suspended.
One final point: if you are currently making pesticide applications and aren’t licensed, cease the applications and take this season to become licensed. The fine and professional embarrassment will cost much more than the license. The license also plays an important role in demonstrating to customers that your company is competent in applying pesticides on their property.
Dr. Weaver is director of research and horticulture at Greene County Fertilizer Company. He holds a PhD in Turfgrass Science from Clemson University. He has 10+ years experience in Pesticide Regulatory in SC and GA, where he has worked to educate pesticide applicators on pesticide regulations from both the state and federal levels, proper use of pesticides, and record-keeping. Weaver has spoken at several local, state, and national conferences on pesticide regulations.