1.4 Professionalism, Chemical Security & Supervising Others

1.4 Professionalism, Chemical Security & Supervising Others

Quick Summary: Two of the ten federal core competency areas are about conduct, not chemistry: Responsibilities of supervisors of non-certified applicators (40 CFR 171.103(c)(9)) and Professionalism (40 CFR 171.103(c)(10)). Together they cover giving use-specific instructions, explaining the law to the people you supervise, keeping restricted use pesticides secure against theft and diversion, communicating exposure and risk to customers and the public, and practicing product stewardship. Indiana adopted the federal supervision standard wholesale through Senate Enrolled Act 216, effective July 1, 2024.

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1. What a Supervisor Owes the People They Supervise

Section 1.1 covered the mechanics of 355 IAC 4-2-2 and 40 CFR 171.201. This section covers the two supervisory duties that are about teaching, because they are the ones applicators most often skip.

Use-Specific Instructions (40 CFR 171.103(c)(9)(iii))

"Site-specific instructions" is not a form to sign. Before a non-certified applicator touches a restricted use pesticide, the supervising certified applicator must convey, in language the worker understands:

Instructions must be understandable to the worker. If the person you supervise reads Spanish more comfortably than English, "I told them in English" is not compliance — and Purdue publishes the Core manual in Spanish (PPP-C, Fundamentos Sobre el Uso de Pesticidas) precisely because Indiana's handler workforce is not monolingual.

Explaining the Law (40 CFR 171.103(c)(9)(iv))

The supervisor is also expected to explain pertinent state and federal laws and regulations to the non-certified applicators working under them. In practice that means the worker should be able to tell an OISC investigator:

• that the label is the law and using a product inconsistently with it is a violation;
• that they must have access to the product labeling at all times during use;
• who their supervisor is and how to reach them immediately;
• that their annual training must be current, and that the record of it is kept for two years;
• that they must be 18 to use an RUP, and that Indiana requires a registered technician credential to apply general use pesticides for hire without a certified applicator on site.

[!IMPORTANT] The supervisor is legally responsible for all requirements and activities carried out by the non-certified applicator. When an unlicensed worker misapplies a product, IC 15-16-5-65(10) reaches the certified applicator and the business, not just the worker.

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2. Chemical Security for Restricted Use Pesticides

Professionalism competency (i) is chemical security: keeping restricted use pesticides out of the hands of people who intend harm, and out of the hands of children who do not.

                          THE FOUR LAYERS OF PESTICIDE SECURITY

  ┌───────────────────┐   ┌───────────────────┐   ┌───────────────────┐   ┌───────────────────┐
  │  1. PHYSICAL      │   │  2. INVENTORY     │   │  3. PERSONNEL     │   │  4. TRANSPORT     │
  │  Locked, posted,  │   │  Know what you    │   │  Only trained,    │   │  Never unattended │
  │  dedicated room;  │   │  have; reconcile  │   │  authorized       │   │  and unlocked;    │
  │  fenced outdoor   │   │  purchases        │   │  people hold      │   │  never in the cab │
  │  storage; keys    │   │  against use      │   │  keys; check      │   │  or with food,    │
  │  controlled       │   │  records          │   │  references       │   │  feed, or people  │
  └───────────────────┘   └───────────────────┘   └───────────────────┘   └───────────────────┘

Practical Security Measures

• Lock it, and post it. Storage must be locked when unattended and placarded so that emergency responders know what is inside before they open the door.
• Reconcile inventory against records. Your 355 IAC 4-4-1 application records already state the amount of each product used. A product that leaves the shelf faster than the records account for is the first sign of diversion. This is the practical payoff of accurate recordkeeping.
• Control who can buy. Indiana requires an annual RUP dealer registration for anyone selling restricted use pesticides to end users, and the dealer must record the buyer's name, certification number, issuing authority, expiration date, and categories for every transaction, keeping those records two years. Your license number is the credential that lets you buy — treat it like a credit card number.
• Lock the bulk tanks. Indiana's bulk containment rules require a locked shutoff valve on bulk tanks whenever the facility is unoccupied, and no sight gauges on pesticide tanks.
• Report losses. A missing container of an RUP is not an inventory rounding error. Notify OISC, and notify law enforcement.
• Children first. The federal safety competency specifically calls out "precautions to be taken to prevent children from having access to pesticides and pesticide containers." Never transfer a pesticide into a beverage bottle, food jar, or unlabeled container — that single act is the leading cause of accidental child poisoning and is illegal under FIFRA and Indiana law.

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3. Communicating Exposure and Risk to Customers and the Public

Professionalism competency (ii) asks whether you can explain a pesticide exposure to a non-expert without either alarming them or misleading them. This is a testable skill because most enforcement cases begin with a phone call from an upset neighbor.

The Honest Framing: Hazard = Toxicity × Exposure

The single most useful thing you can say to a worried homeowner is that risk depends on both how toxic the product is and how much of it reaches them — and then explain what you did to hold exposure near zero: the droplet spectrum you chose, the buffer you left, the wind speed at which you stopped, the re-entry interval you posted.

What Not to Say

When Someone Reports an Exposure

1. Stop the application and remove people and animals from the area.
2. Get the label and the SDS into the hands of whoever is providing medical care, and give the exposed person the product name, EPA registration number, and active ingredient.
3. Poison control: 1-800-222-1222. National Pesticide Information Center: 1-800-858-7378.
4. Document the time, the weather, the equipment settings, and what was said. Your record is your defense.
5. Expect an OISC investigation. Anyone may file a pesticide complaint with OISC, and completed investigation records are publicly searchable. Investigators collect samples, weather data, and equipment information, and they will ask for your application records.
6. Know your appeal rights. A person aggrieved by a State Chemist decision may petition the Indiana Pesticide Review Board in writing within thirty (30) days (IC 15-16-5-67).

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4. Product Stewardship

Professionalism competency (iii) is stewardship — protecting the continued availability of the tools you depend on.

• Resistance stewardship: rotate mode-of-action groups, not brand names, and apply full labeled rates at the right timing (Chapter 2.3).
• Container stewardship: triple-rinse or pressure-rinse, and recycle through the Ag Container Recycling Council (ACRC) program. Open burning of pesticide containers is illegal in Indiana.
• Unwanted-product stewardship: OISC runs Clean Sweep collection events on published dates each year for disposing of unusable or unwanted pesticides — the lawful alternative to letting an unknown drum sit in the back of the barn.
• Pollinator stewardship: consult Indiana FieldWatch / DriftWatch before treating, even though participation is voluntary, and time applications away from foraging.
• Endangered species stewardship: check Bulletins Live! Two no more than six months before the application when the label directs it.
• Keep learning: Continuing Certification Hours exist for this reason. No more than half of a category's required CCHs may be earned at any single program, which is a deliberate push toward varied sources — and OISC's newsletter, The Scoop, is where rule changes are announced.

[!TIP] Stewardship is also self-interest. Every product on the market is one adverse-effect finding away from a label restriction. The applicator who buffers a stream, documents a drift-safe droplet size, and files a clean record is protecting their own tool inventory for next season.