1.3 Supervisors, Operators & Written Instructions
Key Takeaways
Under RCSA § 22a-66-5(i), a commercial application needs a certified supervisor present or written instructions in the operator's possession.
Junior operator instructions must list supervisor and operator certificate numbers, pest, pesticide, dilution, method, place, and site(s).
A Connecticut supervisor must be able to be present at the application site within two hours of being contacted by the operator.
A junior operator may choose not to apply a pesticide if no pests are present or conditions increase the risk of harm.
Written instructions must be kept with the commercial application records, which CGS § 22a-58(d) requires for at least five years.
1.3 Supervisors, Operators & Written Instructions
The relationship between a certified supervisor and a junior operator is the single most tested Connecticut-specific rule on the operator exam. DEEP's operator manual opens with it, the operator statutes booklet quotes it in full, and the supervisor certification page repeats it. The rule lives in RCSA § 22a-66-5(i), with supporting duties in CGS §§ 22a-54(b), 22a-61(e), 22a-63(f), and 22a-66f.
Every Commercial Application Needs a Supervisor
RCSA § 22a-66-5(i)(1) states that no commercial application of pesticides shall be made unless a person holding a valid supervisory certificate either:
- (A) is present at the time of application where the pesticide labeling requires the presence of a certified applicator; or
- (B) where the labeling does not require presence, is either present or provides written instructions to the certified operator.
CGS § 22a-66f backs this up at the business level. A pesticide application business must employ, at each place of business and for each category or subcategory in which it applies pesticides, at least one commercial supervisor certified in that category. A company that adds tick control to its general pest control work needs a 3A supervisor as well as its 7A supervisor.
Written Instructions for a Junior Operator
Under RCSA § 22a-66-5(i)(2)(A), written directions given to a junior operator must include:
- The certified supervisor's name and certification number.
- The certified operator's name and certification number.
- The pest to be controlled.
- The pesticide to be used.
- Directions for use, including the dilution rate (if the product is not ready-to-use) and the method of application.
- The place to be treated and the site or sites at that place.
Two definitions in RCSA § 22a-66-1 give these words their meaning. The place is the street address, unit number if any, and municipality. The site is the specific location at the place to be treated. The site must be designated clearly enough that it is clear which of the instructions on the pesticide label are to be followed. "Front lawn turf" and "kitchen cracks and crevices" point to different label directions; "the whole property" does not. Instructions may also need further directions depending on label precautions and site-specific limits.
Possession, electronic delivery, and retention
- The written instructions must be in the possession of the certified operator at the time of application.
- They may be delivered electronically. If so, they must be made available in printed form, or electronically transmitted, to DEEP's representative at the time of an inspection of the operator or the business.
- The commercial applicator must retain the written instructions as part of the records required by CGS § 22a-58(d). That means at least five years (Section 1.4).
When the job changes
DEEP's supervisor page and operator manual describe the field consequence. The operator must not apply pesticides without the written instructions. If, during a job, a treatment is required or requested that the written instructions do not cover, the operator must not perform that treatment until receiving written instructions for the new application.
Warning
A customer asks your junior operator to "also hit the wasp nest by the garage" while the operator is treating the lawn for grubs. The operator must not do it until the supervisor issues written instructions covering the wasp treatment. Being reachable by phone does not replace written instructions.
The operator's right to say no
RCSA § 22a-66-5(i)(2)(B) gives a junior operator explicit discretion: the operator may choose not to apply a pesticide if no pests are present or if conditions present a potential increased risk of harm (for example, wind toward a playground or children in the treatment area).
Senior Operators
Connecticut regulations create two classes of operational certificate: junior and senior (RCSA § 22a-66-5(h)). Both require a written exam. A senior operator may also be required to pass category exams, and is certified only in those categories.
| Feature | Junior operator | Senior operator |
|---|---|---|
| Instruction content | Supervisor and operator names and numbers, pest, pesticide, directions (dilution and method), place and site(s) | Supervisor and operator names and numbers, place, and directions for control of each pest expected at that place (pesticides, dilution rate, method) |
| Reuse of instructions | Specific to the job | May keep pest-control directions as a reference for future applications at multiple places |
| Category scope | Not category-certified | Limited to categories passed; outside them the senior operator is treated as a junior operator |
| Right to decline | Yes, if no pests or increased risk | Yes, same rule |
The Two-Hour Availability Rule
RCSA § 22a-66-5(i)(4): a certified supervisor shall be available to an operator when and if needed, and shall be able to be present at the application site not later than two hours after being contacted by the operator. A supervisor who sends operators across the state while remaining hours away fails this test even if the phone is answered.
What an Operator Cannot Do
| Activity | Rule |
|---|---|
| Buy restricted use pesticides | Not allowed. RUPs may be sold only to commercial supervisors, private applicators, or registered sellers (CGS § 22a-57). |
| Run a pesticide business | Not allowed. The operator manual says an operational certificate "does not allow an individual to go into business for himself." |
| Advertise, solicit, or perform supervisory work | Unlawful under CGS § 22a-61(e). The civil penalty is $1,000 to $2,000 per day, and up to $5,000 for a subsequent violation (§ 22a-63(f)). |
| Decide what, where, when, or how much | Supervisory duties under § 22a-54(b). |
| Apply without instructions in hand | Prohibited when the supervisor is not present (RCSA § 22a-66-5(i)). |
The same § 22a-63(f) penalty applies to an uncertified person who performs, advertises, or solicits commercial application.
A Sample Set of Junior Operator Instructions
| Required element | Example entry |
|---|---|
| Supervisor and certificate number | J. Rivera, S-0000 (category 3A) |
| Operator and certificate number | M. Chen, O-0000 |
| Pest | White grubs (Japanese beetle larvae) |
| Pesticide | Product trade name as on the label |
| Directions for use | Granular, ready-to-use; rotary spreader at the calibrated setting; water in with 0.5 inch of irrigation per label |
| Place | 12 Example Road, Unit 2, Town, CT |
| Site(s) | Rear lawn turf only; no application to vegetable bed or within the pond setback on the label |
Note what is not required by the regulation: a "daily" form, customer billing data, or weather readings. The operator still needs all the other legal documents for the job, such as posting signs (Section 1.5).
Private Applicators: "Direct Supervision"
For farms, CGS § 22a-47(e) defines a pesticide as applied under the direct supervision of a private applicator if a competent person applies it on property owned or rented by the private applicator, acting under the instructions and control of a private applicator who is available if and when needed. Written instructions are not required in the private applicator definition, but the certificate holder is responsible for training the person who does the work.
Which item is required in written instructions given by a Connecticut supervisor to a junior operator under RCSA § 22a-66-5(i)?
The customer's billing account number and payment terms
A notarized customer signature authorizing each pesticide
Recorded wind speed and temperature taken by the supervisor that morning
The supervisor's and operator's names and certification numbers, the pest, the pesticide, directions including dilution and method, and the place and site to be treated
A junior operator calls the supervisor from a job in a distant town. Under Connecticut rules, how quickly must the supervisor be able to be present at the site?
Within 30 minutes
Within 24 hours
Within two hours of being contacted
There is no time limit if the supervisor answers the phone
While treating turf for grubs under written instructions, a junior operator is asked by the homeowner to spray a yellowjacket nest under the deck. What must the operator do?
Spray the nest if the supervisor approves by phone and the customer signs a waiver
Spray the nest using the same product if the label lists wasps
Not treat the nest until the supervisor provides written instructions for that new application, unless the supervisor is present
Spray the nest only if it is within six feet of the foundation
Sections you finish are checked off in the contents.