COVID-19: UDAF’s Pesticide Program Q&A’s
Updated June 19th, 2020
I was planning on renewing my license by retesting this spring, but all of the testing centers are closed. How do I renew now?
Many renew by retesting instead of earning 24 CEU’s. If your applicator’s license expired 12/31/2019 and you were in “Good Standing” with UDAF, then your license is being extended to December 31, 2020. You do not have to take any steps to do this. You will not receive a new license. You will have to retest/renew before the end of 2020. Your renewed license will expire December 31, 2022. In other words 2020 will be counted as one of the 3 years that a license is valid..
If you need to purchase an RUP, contact the pesticide inspector in your area for a written temporary license.
You cannot renew with CEU’s since the CEU renewal period ended February 29, 2020 which was well before any stay at home orders started.
I have new people to get licensed for the first time, but all of the testing centers are closed. Can they temporarily apply pesticides without a license?
No. The EPA has made it clear to the states that testing/licensing requirements will not be “softened” during this COVID-19 emergency. In Utah “if you pull the trigger, you need a license” remains in effect.
So how do my new hires test?
Since most of the testing centers were closed, UDAF in SLC performed limited proctoring as was stated on the website. At this time UDAF has ceased proctoring since USU will reopen their testing centers June 22, 2020. See https://ag.utah.gov/farmers/plants-industry/pesticides/use-of-pesticides/pesticide-licensing-testing-centers/
Is licensing required in Utah to apply disinfectants and sanitizers commercially?
As long as the product is a General Use Pesticide, it is labeled for such uses and the label directions are followed (target pest, site, rates, PPE, etc.), no licensing is required in Utah. However, you can’t make claims (advertise) that your product will kill COVID-19 specifically, unless they are approved by the EPA for that specific purpose. There are two categories of products that are approved by EPA for use against COVID-19:
- They are on the approved list, also known as List N: https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2
- The label has the verbiage “assists with emerging viral pathogens”. This list can be found here: https://www.americanchemistry.com/Novel-Coronavirus-Fighting-Products-List.pdf
All of my suppliers are out of these EPA allowed sanitizers. Can I use a product that has the same active ingredient, but is usually used for other, non-pesticidal purposes (for example hydrogen peroxide)?
No. Under federal law, it is illegal to use any chemistry unless it has been approved by EPA and labeled as such, even if the active ingredient seems to be identical. States cannot override federal law.
Is my company or entity an essential business?
Utah hasn’t clearly defined what “essential” is and they probably won’t. According to Homeland Security, Agriculture is essential (see list here). Otherwise, “essential” seems to be defined by the issuing authority. Many believe Salt Lake County’s decree to be one of the most stringent. Their order can be found here. Starting on page 13 of 16, there is a list titled “Essential Businesses and Operations”. On page 15 of 16, under “m. Critical trades” it includes the following: “exterminators, pesticide application, cleaning and janitorial staff for commercial and governmental properties,….forestry and arborists, and other service providers who provide services that are necessary to maintaining the safety, sanitation, and essential operation of residences…”
The Utah Pesticide Control Act defines pesticides as follows: (25) “Pesticide” means any:
(a) substance or mixture of substances, including a living organism, that is intended to prevent,
destroy, control, repel, attract, or mitigate any insect, rodent, nematode, snail, slug, fungus,
weed, or other form of plant or animal life that is normally considered to be a pest or that the
commissioner declares to be a pest;
Practice social distancing, avoid going into other’s homes, send sick employees home and follow all the other instructions on preventing the spread of COVID-19.
If you have any concerns about an issuing authority’s intent, contact them for clarification.
I can’t find the PPE I need. What do I do?
Respirators, face masks, disposable gloves and other PPE are in short supply and you may have trouble buying them over the next few months. Review your PPE requirements and start thinking about alternative PPE (example: rubber gloves instead of disposable nitrile) or alternative pesticides that may have less PPE requirements (example: one that doesn’t require a respirator).
Hunting for Alternative Products and Practices
CDMS Label Database: http://www.cdms.net/Label-Database
Crop Data Management Systems (CDMS) works with key pesticide registrants, hosting their current labels and Safety Data Sheets online.
Pesticide Information Center Online (PICOL) for WA and OR – The search menu can find products by crop and pesticide type, and filter by target pest to seek out alternatives, and view current approved labels.
Works with manufacturers to have labels and other supporting documents. This search engine has a safety tab that lists the PPE requirements without having to search the label. The pesticide label can also be referenced.
USDA Integrated Pest Management (IPM) Database: https://ipmdata.ipmcenters.org/
Documents include common pests by crop, and a variety of pest management options.
NPIC’s Product Research Online: http://npic.orst.edu/NPRO
Search for federally-registered pesticides by crop, by pest/weed, and read labels online.
Will there still be inspections?
Yes. Most inspectors are resuming in-person application and Worker Protection Standard (WPS) inspections again. Social distancing will be practiced and the other state instructions implemented. Inspectors are still performing a limited number of record inspections via email. It’s like a standard record inspection, but documents/records will have to be sent to the inspector via email.