40 CFR 171: EPA Pesticide Applicator Certification

Regulatory citation: 40 CFR Part 171, Certification of Pesticide Applicators

What Is the Pesticide Applicator Certification Rule?

40 CFR Part 171 sets federal minimum standards for certifying people who apply restricted use pesticides (RUPs). It covers commercial applicators, private applicators such as farmers, and noncertified applicators who use RUPs under a certified applicator's direct supervision. States, tribes and federal agencies run the programs through EPA-approved certification plans.

EPA revised Part 171 in 2017. Existing plans stayed in effect until EPA approved a revised plan or November 4, 2023, whichever came first. EPA approved nearly all revised plans in 2023, and each plan has its own implementation schedule, so some new requirements may phase in by jurisdiction.

Why Applicator Certification Matters

Restricted use pesticides can cause serious harm to applicators, workers, the public and the environment if misused. Certification makes sure the people using them can read labels, protect themselves and others, and apply products correctly.

Core Requirements

1. Hold a Valid Certification (171.1(b))

A person is a certified applicator only if they hold a currently valid certification issued under an approved plan in the jurisdiction where they apply RUPs. Certification in one state does not automatically cover work in another.

2. Meet the Minimum Age (171.103(a)(1) and 171.105(g))

Commercial and private applicators must be at least 18 years old to be certified.

3. Pass Proctored Exams for Commercial Certification (171.103)

Commercial applicators must pass a written core exam and a written exam for each category they want. Exams are closed book except for approved references, proctored by someone not seeking certification in that session, and taken after showing valid government-issued photo identification. Core topics include label comprehension, safety, environmental effects, pest identification, application methods, laws and supervising noncertified applicators.

4. Certify in the Right Category (171.101)

Commercial categories include agricultural pest control (plant and animal), forest, ornamental and turf, seed treatment, aquatic, right-of-way, industrial, institutional and structural, public health, regulatory, and demonstration and research. Private applicators get a general certification by exam or an approved training program under 171.105(h).

5. Add Application-Specific Certifications (171.103(d) and 171.105(b)–(f))

Separate certifications are required for soil fumigation, non-soil fumigation and aerial application, and for sodium cyanide and sodium fluoroacetate predator control. A general private applicator certification does not by itself authorize these uses.

6. Recertify at Least Every 5 Years (171.107)

Certifications expire five years after issuance unless the applicator is recertified first. A certifying authority may set a shorter period. Recertification is by written exam or approved continuing education, and online courses must include a way to verify completion.

7. Supervise Noncertified Applicators Properly (171.201)

Noncertified applicators using RUPs under direct supervision must generally be at least 18, and must have been trained within the last 12 months, for example by the rule's training or Worker Protection Standard handler training. Before each use, they need access to the labeling, correct and clean PPE, site-specific instructions, checked equipment and a means of immediate communication with the certified applicator. Commercial applicators must keep supervision records at their principal place of business for two years from the date of use.

Common Compliance Approaches

Keep a Certification Matrix

Track each applicator's jurisdiction, categories, application-specific certifications and expiration date in one list.

Run an Annual Training Cycle

Train all noncertified staff each year and keep signed records showing name, date, trainer and course title.

Brief Before Every Job

Use a short pre-job checklist covering label directions, PPE, equipment checks and how to reach the supervisor.

Example: Applicator Certification in Practice

A pest control company offers structural fumigation and lawn care in two states. Its fumigation technicians hold commercial certification with the non-soil fumigation category in both states. New hires apply RUPs only under direct supervision after completing annual training, and the office keeps their training records for two years. A spreadsheet flags each certification six months before its five-year expiry so staff can complete continuing education in time.

Related regulations: EPA Agricultural Worker Protection Standard, OSHA Hazard Communication Standard, OSHA Respiratory Protection.

Note: Part 171 sets federal minimum standards. States, tribes and federal agencies run certification through EPA-approved plans and may set shorter recertification periods or extra requirements. Always check the rules of the jurisdiction where you apply pesticides.

Frequently Asked Questions

Can a 16-year-old apply restricted use pesticides?

Only in a narrow case. A 16- or 17-year-old may work under the direct supervision of a private applicator who is an immediate family member, but not with fumigants, sodium cyanide or sodium fluoroacetate, or in aerial application.

How often must I recertify?

Before your certification expires, which is no more than five years after issuance. Your state may set a shorter period.

Does Part 171 apply to general use pesticides?

No. Part 171 covers certification for restricted use pesticides. Other label and state requirements still apply to general use products.