PAT Policies and Procedures

Written December 2014, Revised September 2021

1.0 Introduction

This publication describes Montana State University (MSU) Extension Pesticide Education Program (PEP) policies created to meet the requirements of FIFRA, The Montana Pesticide Act & MT Administrative Rules. The policies are binding only to the Montana Private Applicator Program, and do not represent policies of the Montana Commercial Applicator Program including commercial, government or non-commercial applicators. Individuals interested in changing these policies or procedures should direct suggestions to MSU PEP at [email protected], (406) 994-5067. New policies are enacted through careful consideration from MSU PEP stakeholders.

1.1 Background

Written into the Montana Pesticide Act, MSU Extension is to coordinate the certification and training of the Montana Private Applicator Program. In addition, all MSU Extension personnel demonstrating, making recommendations, researching or supervising the use of pesticides, and/or conducting pesticide training are to be licensed (certified) as government applicators in the commercial applicator program. Written into administrative rule and supported by MSU policy, most county agents act as local Private Applicator Training (PAT) Coordinators. PAT programs are developed and conducted by PAT Coordinators within each county or reservation. Sometimes, a county agent may act as the PAT Coordinator for multiple counties. Where there is no county agent available, other individuals may be PAT Coordinators upon approval by the MDA and MSU PEP. In a few cases other non-extension individuals are local PAT Coordinators. Tribal Extension agents also conduct PAT programs often covering more than one county. Montana is divided into five PAT districts with one of the districts reaching the end of their recertification cycle annually.

2.0 Certification

2.1 Initial Certification

Private Applicators must be licensed prior to purchasing and using a pesticide designated by the Environmental Protection Agency (EPA) or MDA as a restricted use pesticide (RUP) on land they own, rent or lease for the purpose of growing an agricultural commodity. To become certified a Private Applicator is required to have a copy of the Montana Private Pesticide Certification Addendum and National Pesticide Applicator Certification Core Manual in their possession prior to:

Passing the 50-question open book, Montana Private Applicator Certification Exam at their local Extension office with a 70% or better. The test may be proctored by any member of the MSU Extension office if this individual is in the immediate vicinity of the designated PAT Coordinator to answer questions.
Attending a seven-hour training session and taking a 50-question open book ungraded quiz. These seven-hour sessions must adhere to criteria set forth for initial programs (section 3).

The agent must review the exam with individuals who answered less than 70% of the questions correctly or they must review the answers to the ungraded quiz after completion by the applicators.

Upon successful completion of the certification exam:

The agent must note the exam score on the Application for Private Farm Applicator Special Use Permit provided by the MDA.
The agent must sign the application in the appropriate box.
The applicator must mail the signed application and fee to the MDA, or the agent collects the fee from the applicator and mails the application and fee to the MDA.
The applicator will then receive a permit in the mail and will be entered into the MDA pesticide applicator database.

2.2 Fumigation Category Testing

Individuals intending to purchase and apply fumigants should be encouraged by PAT Coordinators to buy a Non-Soil Agricultural Fumigation Manual for Private Applicators and take the Non-Soil Agricultural Fumigation Exam. The test is non-graded but will indicate to the applicator their knowledge of fumigation safety and procedures. Fumigants are highly toxic, require different personal protective equipment, require a different calibration approach and are poorly covered in the required pesticide training manuals. This will be a closed-book graded exam in the near future when it is enforceable.

2.3 Recertification

Once an individual has received their private pesticide license they are termed as a recertifying applicator and are assigned to one of five districts with a five-year recertification cycle dependent on their county of residence. The districts are illustrated below:

Map of Montana private applicator districts

In order to be eligible to renew their private (farm) license for another five-year cycle, recertifying applicators have two options:

Complete the 50-question closed book Montana Private Applicator Certification Exam during the last year of their certification cycle and pass it with a 70% or better. The agent will go over the exam with individuals who answered less than 70% correct.

Accrue six recertification credits through onsite and/or online courses over the course of the five-year recertification cycle for their district. The accrual of six credits does not need to take place in the last year of the certification cycle but can be spread out over the five-year period.

If an applicator allows their certification to lapse by not attaining six recertification credits prior to the January 1 deadline they must take a closed book Montana Private Applicator Certification Exam within the 12 months after their license expired to requalify. The lapsed applicator can once again take the open book exam 12 months after his license lapses. The lapsed applicator has the option of attending a seven-hour initial certification training session and taking the 50-question open book 'ungraded quiz' at any time.

2.4 Differential Credit Requirements

Individuals who enter the system prior to June 30 of the third year of their certification cycle must accrue six recertification credits before the end of the recertification cycle in order to be eligible to renew. Applicators who obtain their license after June 30 of the third year of their certification cycle only need to accumulate three recertification credits to be eligible for renewal. Initial applicators who obtain their license in the last 12 months of their recertification cycle do not need to accrue any credits before the end of their recertification cycle.

For example, applicator John Doe lives in Gallatin County (District 2). For this example, his recertification cycle is from January 1, 2015 through December 31, 2019. He takes the 50-question exam at his local extension office on May 19, 2018 (fourth year of the recertification cycle). He needs to obtain only three recertification credits by the end of December 31, 2019. On the other hand, Jane Doe, who also lives in Gallatin County, received her license on April 15, 2019 (fifth year of recertification cycle). She DOES NOT need to accumulate any recertification credits to renew her license.

2.5 Licensing Out-of-state or Commercial Applicators

Private, commercial, or government applicators from another state moving to Montana who desire a Private Applicator license will need to pass the Montana Private Applicator Certification Exam and pay the appropriate fees.

Montana government, commercial or non-commercial applicators desiring a Montana Private Applicator license must:

Present a valid MT license to a PAT Coordinator;
Fill out the Application for Private Farm Applicator Special Use Permit;
Purchase or have in their possession the Montana Private Pesticide Certification Addendum;
Send the permit application with appropriate fee to the MDA.

2.6 Pesticide License Age Requirements

To hold a Private (Farm) Applicator pesticide license in Montana, applicators must be a minimum of 18 years old. An applicator must be a minimum of 16 years old to apply pesticides under the supervision of a family member who holds an active Montana private applicator license.

3.0 Pesticide Education Events

3.1 Initial Private Applicator Training

RUP's are pesticides available for purchase and use only by certified pesticide applicators or persons under their direct supervision. This designation is assigned to a pesticide product due to its relatively high degree of potential human and/or environmental hazard. Therefore, initial pesticide training programs are primarily geared towards pesticide safety, preventing environmental contamination from pesticides and compliance with pertinent pesticides laws and regulations.

Initial training programs must be a minimum of seven-hours over seven core topics, followed by a 50-question open book quiz. PAT Coordinators who want to host a Private Applicator Initial Training must submit the program agenda to the Pesticide Education Specialist by submitting the agenda online using the Initial Training Program Submittal Form. For assistance in submitting the program or finding speakers contact Cecil Tharp. The agenda must include presentation time slots, presentation titles, speakers and speaker affiliation, as well as the event date, location, contact and registration information. Once approved the event is given a program number and the PAT Coordinator will be sent an approved sign-in sheet. If the PAT Coordinator wishes to offer recertification credits the agenda must be submitted to the MDA as outlined in Section 3.3.

3.2 Core Categories

The following subject areas and topics are required for seven-hour Initial Private Applicator Training events.

3.2.1 Private Applicator License

Minimum of 30 minutes
What are pesticides and what are RUP's?
How to read your license number and why it is important
Recertifying
Pesticide fees and where they go
What you can and can't do with your license

3.2.2 Reading the Pesticide Product Label

Minimum of 30 minutes
What are active versus inert ingredients and signal words?
What/where do you find the restricted entry interval (REI)?
What/where is the pesticide product rate? Can you go above product rates?
What/where do you find storage and disposal information?
Importance of crop and site locations

3.2.3 Integrated Pest Management

Minimum of 60 minutes
Definition of integrated pest management (IPM)
Benefits of IPM (why zero tolerance doesn't work)
Economic thresholds & economic injury levels
Monitoring techniques
Pest identification
Control methods (chemical, cultural, bio-control, transgenic, and mechanical)
Resistance/resistance management

3.2.4 Pesticide Safety

Minimum of 90 minutes
Acute vs. chronic toxicity
Four routes of exposure
Pesticide formulations and applicator safety: liquid vs. dry formulations
What is an LD₅₀? Signal words
Protecting yourself: personal protective equipment (PPE)
Laundering pesticide contaminated clothing
Proper pesticide storage: storage of pesticides in their original containers, triple rinsing, storage checklist, disposal of empty containers and excess pesticide product
Procedures for poisoning
Heat stress
Cleaning PPE and pesticide equipment
Interactive demonstration: demonstrating use of PPE, reading the label and selecting PPE, fluorescent dye tracer demonstrating exposure, etc.

3.2.5 Pesticide Laws

Minimum of 60 minutes
Worker Protection Standard (WPS)
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
Montana Pesticides Act and other Montana laws and regulations
Surface water discharge permit (MPDES)
Federal recordkeeping requirements: key elements to record, how to use calibration formulas to help you keep accurate records

3.2.6 Calibration of Pesticide Spray Equipment

Minimum of 90 minutes
Determining GPA of hand, boom and broadjet sprayers
Determining nozzle output
Reading a nozzle specification sheet
Understanding the effects of speed and pressure
Acres you can spray with a given volume
Amount of pesticide product to add to the tank
Pesticide solution to add to the tank
Useful conversions (pints to ounces, gallons to ounces, etc.)
Using calibration formulas to help keep pesticide records
Calibration exercises
Interactive demonstration: Calibrating GPA of hand sprayer, boom or boomless sprayer

3.2.7 Pesticides in the Environment: Movement & Degradation

Minimum of 60 minutes
Pesticide properties regarding environmental contamination
Solubility
Soil binding capabilities (adsorption)
Pesticide behavior in the soil: leaching, runoff, and groundwater contamination
Drift
Volatilization
How nozzles and pressure contribute to drift
Degradation

3.3 Assigning Pesticide Recertification Credits

The guiding principle towards assigning recertification credits to a program is if the topic(s) will contribute to the competence in the use and handling of pesticides by a Private Applicator (40 CFR 171). Pesticide recertification credits are granted for the attendance and successful completion of an approved training or educational workshop or seminar held for the recertification of Private Applicator licenses. In general, 50 minutes to one hour of instruction equals one credit.

Recertification programs will receive credits for programs related to the core areas described by the MDA. These programs should strive to be relevant to the interest of the target audience. Applicators do not need to accrue credits in each of the subject areas in order to qualify for recertification. Any programs related to pesticide use or pest management will be awarded one credit per 50 minutes of material. Programs related to soil health, fertility, rotational systems must demonstrate they pertain to pest management to be awarded credits.

Note: It is a Private Applicator’s responsibility to attend only programs approved for Private Applicator recertification credits. Montana commercial pesticide credits or pesticide credits from another state will not automatically constitute a Montana Private Applicator credit award. All out-of-state programs must be submitted through the Private Applicator program credit request process described below.

3.4 Requesting Recertification Credits

A completed MDA Request for Pesticide Course Recertification Credit Assignment must be submitted at least 30 days in advance of the scheduled program. A training program must be approved for recertification credits before the program can be advertised as qualifying for recertification credits.

Pesticide recertification credits will be awarded for each program credit request submittal qualifying for a credit award. If separate credit awards are desired for morning and afternoon sessions, or for multiple day events, a coordinator must submit each session as a separate program request. For example, a three-day conference would need to have a program credit request for each day credits are desired.

Resources for trainings are diverse, including Extension agents, Extension specialists, MDA specialists, MSU Agricultural Research Station faculty, MSU faculty, industry personnel, Weed District personnel, and other non-biased personnel from government institutions. Non-Extension sponsored meetings can include producer organizational meetings, pesticide product updates, weed district meetings, etc.

Accredited programs will be assigned a program number by the MDA. This number is for both private and commercial credits. Agents requesting the program will be emailed verification of accreditation within 14 days of a completed program credit request including an official sign-in sheet to be used at the event.

3.4.1 Program Attendance

During the program a sign-in sheet must be filled out completely with the applicator’s license number, first and last name, county, contact information and signature. Illegible or incomplete entries may result in the applicator not receiving credits. Prior to sign-in sheet submission, program sponsors should review the sign-in sheet for proper license numbers. Sponsors may review applicator license information on the MDA pesticide license database by entering the license number or the applicator’s first and last name.

Note: Applicators are encouraged to keep track of the programs they attend. It is the Private Applicator’s responsibility to correctly record their pesticide license number on a program sign-in sheet. Applicators who neglect to sign the sign-in sheet will not receive credit after the program has completed.

3.4.2 Program Completion

Forward a copy of your sign-in sheets to the MDA Pesticide Applicator Training office within 14 days of program completion. Once the program is finished, course attendees can be reviewed by entering the program number into the MDA Meeting Attendees Search.

4.0 Applicator License Fees

In 2017, legislative changes to the Montana Pesticide Act resulted in increased fees for the Private Applicator (farm) license. The new fee for each Private Applicator during the five-year recertification period is $60.00. The $60.00 is distributed in the following manner:

$15.00 (25%) to MDA for administration.
$15.00 (25%) to fund the Waste Pesticides and Pesticide Container Disposal Program.
$30.00 (50%) to MSU Extension Service broken down as follows:
- $5.00 (8%) to the MSU PEP.
- $25.00 (42%) to the county Extension office in which the Private Applicator resides. This money is used to support pesticide certification and training programs conducted in those counties.

The $60 applicator license fees are prorated over the five-year Private Applicator certification cycle. Certification cycles are staggered by district. For example, an initial applicator paying their fees during the 2nd year of the cycle would pay $48.00. The payment in the 3rd year would be $36.00 and so forth.

5.0 PAT County Funds

PAT funds can be used by PAT Coordinators for the purpose of supporting their county’s PAT programs including educational supplies, conference rooms, speaker costs including hotel and travel, catering, travel to pre-approved pesticide train the trainer programs and pre-approved equipment. Contact Cecil Tharp if approval is needed for equipment or attendance at a train the trainer event (i.e. Crop Pest School, PAT Core Training, PEP Update, Level 1 or 2 Weed Management Trainings). PAT funds can be used by PAT Coordinators for an entire purchase if the equipment purchased is to be used for pesticide applicator trainings more than 50% of the time. Anything less than 50% indicates pesticide fees may pay for only a portion of the purchase; however, some exceptions are outlined in the bulleted list below. For example, if the county is going to use a laptop computer 80% of the time for day-to-day office work and 20% of the time for pesticide education uses, the pesticide applicator fund may pay 20% of the costs. Pesticide applicator funds:

Cannot be used to purchase ATV's or other vehicles unless those vehicles will be used 50% of the time for pesticide TRAINING purposes.
Cannot be used to purchase herbicides or pesticide applicator equipment unless that equipment will be used 50% of the time for pesticide TRAINING purposes
Cannot be used to fund travel to meetings unless 50% of the presentations attended are related to pesticide use or pest management.
Cannot be used to purchase alcohol.

Any county Extension office or those working under their delegated authority may utilize county PAT funds available to their respective county or counties. Tribal Extension agents may also qualify to use county PAT funds, however tribal Extension agents must apply for PAT funds using the Tribal Funds Justification Form. If PAT funding is critical, tribal employees should submit this form prior to the event.

Only PAT Coordinators can request pesticide applicator funds. See the Instructions for Accessing PAT County Funds for more information. PAT Coordinators must submit a Banner Payment Authorization (BPA) to their regional Department Head only after PAT expenditures are finalized and receipts are in hand. A BPA, receipts and invoice should be forwarded to the regional Department Head for signature. The regional Department Head will forward the approved document to the Budget & Fiscal Director. MSU Extension will then reimburse the individual/companies indicated on the BPA.