The Wisconsin Corn Growers Association submitted comment in opposition to EPA’s proposed rule on Certification of Pesticide Applicators, saying the changes would greatly and unnecessarily expand the burdens imposed upon farmers in the state of Wisconsin and beyond. WCGA’s comment states:
“The new rule proposes a shift to a three-year certification cycle. Wisconsin currently uses a five-year certification period which we believe is already adequate. The main changes to pesticide applications come in the form of revised/updated product labels, not changes to safety equipment, application techniques, or pest identification. The EPA hasn’t shown any reason why a three-year cycle would be preferable.
“The new rule also proposes a more stringent exam requirements than the state of Wisconsin currently implements. While the state already meets the majority of the proposed requirements, the requirement to give closed-book exams violates The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). FIFRA clearly states that the EPA “shall not require private applicators to take any examination to establish competency in the use of pesticides.”
“This change is simply unnecessary given the limited scope of private applicator pesticide applications.
“It is also worth noting the Wisconsin Department of Agriculture, Trade, and Consumer Protection has submitted 9 pages of concerns regarding the extensively increased costs and complications with this proposed rule, while noting the EPA has never indicated the current certification program is inadequate.
“While an increased economic burden is clearly attached to compliance with this proposed rule, any real-world benefits are questionable at best. We urge the Agency to leave rules as they are, or work with stakeholders in crafting a new rule that better reflects real world conditions and the needs of American farmers.”
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