2.5 Technician Training Mandates Under 8 CCR 1203-2 Part 5

2.5 Technician Training Mandates Under 8 CCR 1203-2 Part 5

Core Regulatory Standard: An unlicensed person who mixes, loads, applies, sells, or recommends pesticides for a commercial, registered limited commercial, or registered public applicator in Colorado is a technician, and the employer — not the technician — is legally responsible for delivering, documenting, and retaining a specific number of training hours before that person works unaccompanied. All Part 5 training must also conform to the federal noncertified-applicator training requirements at 40 CFR § 171.201.

---

1. The Four Technician Definitions (Part 5.01)

Getting the definition right determines which hour table applies, so learn all four:

Experienced technicians split further into a new hire experienced technician (meets the experience definition but is new to this employer) and an on-going experienced technician (meets the definition and stays with the same employer). Each gets a reduced hour requirement.

When Part 5 does and does not apply (Part 5.02)

• A person who uses, sells, or recommends a general use pesticide while under the on-site supervision of a qualified supervisor is not a technician for purposes of these Rules.
• A person who evaluates a pest problem under the on-site supervision of a qualified supervisor is not a technician.
• A person must be a trained technician to use an RUP under a QS's on-site supervision, and all of the federal direct-supervision conditions in 40 CFR § 171.201 must be satisfied first.
• A person may not use, sell, or recommend even general use pesticides unaccompanied by a qualified supervisor, certified operator, or experienced technician until the required training is complete. Note the third option: an experienced technician — not only a QS or CO — may be the accompanying person.
• Part 5 does not apply to limited commercial and public applicators that are not registered with the Department; those employers are covered by Part 16 instead.

---

2. Hour Requirements by Classification

The single most commonly missed fact on this topic is that there is no one number. Hours are set per classification and per technician type.

The 160-hour structural pathway in detail (Part 5.22)

┌─────────────────────────────────────────────────────────────────────────────┐
│      STRUCTURAL TECHNICIAN (Categories 301, 303, 304) — 160 HOURS           │
├─────────────────────────────────────────────────────────────────────────────┤
│  ≥ 32 CLASSROOM HOURS covering: applicable state, federal and local laws    │
│    and regulations; environmental precautions; use; equipment and           │
│    calibration; pesticides and their families; pest management; applicator  │
│    safety; pesticide label and labeling; host and pest identification;      │
│    and public safety.                                                       │
│                                                                             │
│  ≥ 120 ON-THE-JOB HOURS, of which:                                          │
│     • at least 60 hours must be conducted by a licensed qualified           │
│       supervisor, or by a licensed certified operator with at least 1 year  │
│       of structural pesticide application experience in the last 2 years;   │
│     • NO MORE THAN 60 hours may be conducted by an experienced technician   │
│       trained by that applicator.                                           │
│                                                                             │
│  + 8 REMAINING HOURS divided between classroom and on-the-job training as   │
│    the qualified supervisor determines the need.                            │
│                                                                             │
│  + A WRITTEN EXAMINATION prepared and given by the commercial applicator    │
│    showing overall comprehension of the subject matter of the training.     │
└─────────────────────────────────────────────────────────────────────────────┘

[!WARNING] Three distractors to reject. (1) The 120 on-the-job hours are not "128" — the arithmetic remainder of 160 minus 32 is split as 120 OJT plus 8 flexible hours. (2) Part 5 imposes no calendar deadline such as "within 60 days of employment"; the hours must be complete before the technician works unaccompanied, and that is the trigger. (3) The employer-administered written examination is a genuine Part 5.22(d) requirement for structural technicians and appears again for on-going experienced structural technicians under Part 5.23(b) — but Part 5.02(i) makes clear that an examination never substitutes for any of the required training hours.

The amount of time devoted to each individual topic is at the trainer's discretion (Part 5.02(g)), but the training must be relevant to that technician's actual job duties, and every employer must record the training on a form provided by the Commissioner, completed in full.

---

3. Training Records (Part 5.02(l)–(m))

A copy of all training records must be provided to the applicator technician on request and to the Commissioner on request. Inspectors routinely open an audit by asking for the training file, so an incomplete Commissioner-provided form is a stand-alone violation regardless of whether the training actually happened.

---

4. Part 16: Core Training for Non-Registered Limited Commercial and Public Applicators

Part 5 governs technicians of registered businesses. A limited commercial or public applicator that is not registered with the Department — because it applies general use pesticides only — falls under Part 16 instead, implementing C.R.S. § 35-10-109(2)(a) and (2)(b).

• Employees who mix, load, and apply general use products only and are not otherwise licensed must receive core pesticide safety training.
• The training must be provided within the three years prior to the date of any application, and the employer must keep the training record for three years.
• CSU's free Colorado Core Pesticide Training satisfies Part 16 and may also be used to fulfill 2.5 hours of Part 5 technician training.
• If any of those individuals intends to use a restricted use pesticide, Part 16 is not enough — that person must obtain a Certified Operator or Qualified Supervisor license.
• A person applying pesticides to produce an agricultural commodity under a private applicator's supervision needs federal WPS handler training instead.