11.1 Categories 1(a), 1(b), 2 & 4: Agricultural, Forest & Seed Treatment
Key Takeaways
- 302 KAR 26:020 Section 5(1)(a) requires agricultural plant applicators to know crops and their pests plus soil and water problems, preharvest intervals, reentry intervals, phytotoxicity, potential for environmental contamination, drift and non-target injury, and community problems from agricultural pesticide use.
- Section 5(1)(b) requires agricultural animal applicators to know the relative hazards created by formulation, application technique, age of animal, stress, and extent of treatment, plus pesticide toxicities and residue potentials because host animals are used for food.
- Section 5(2) requires forest applicators to know cyclic pest occurrence and population dynamics as the basis for programming applications, plus phytotoxicity, drift, persistence beyond the intended control period, and non-target exposure.
- Section 5(4) requires seed treatment applicators to know seed types, the effect of carriers and surface-active agents on binding and germination, hazards of handling, sorting, mixing, and misuse of treated seed, and proper disposal of unused treated seed.
- Category 4 is written for commercial applicators using or supervising the use of restricted-use pesticides on seeds in seed treatment facilities.
11.1 Categories 1(a), 1(b), 2 & 4: Agricultural, Forest & Seed Treatment
[!NOTE] Read the regulation, not the brochure. Section 5 of 302 KAR 26:020 states, in its own words, what each category exam must test. Everything below begins with that language and then applies it to Kentucky conditions.
Category 1(a): Agricultural Pest Control - Plant
Section 3(1)(a) scope. Persons applying or supervising the application of pesticides in production of agricultural commodities including, for example, tobacco, peanuts, cotton, feed grains, soybeans and forage, vegetables, small fruits, tree fruits and nuts, grasslands, non-crop agricultural lands, and greenhouses.
Section 5(1)(a) competency. Practical knowledge of crops and the specific pests of those crops, plus practical knowledge concerning:
| Required knowledge area | What it means in Kentucky |
|---|---|
| Soil and water problems | Karst leaching, atrazine and simazine groundwater advisories, sinkhole-fed conduits, filter strips along the Green and Licking |
| Pre-harvest intervals | Crop-specific PHIs on corn, soybean, wheat, and an entirely different set on vegetables and small fruit |
| Reentry intervals | WPS REIs on covered establishments; hand-labor crops such as tobacco, vegetables, and berries drive the REI question |
| Phytotoxicity | Growth-regulator carryover in a shared sprayer; sensitive rotational crops |
| Potential for environmental contamination | Runoff after a first flush; the Kentucky Agriculture Water Quality Act applies to landowners with 10 or more contiguous acres in agriculture or silviculture |
| Drift and non-target injury | Tobacco, grapes, and tomatoes are the classic Kentucky sensitive crops - injury shows at rates far below any labeled crop rate |
| Community problems | Rural-residential interface; neighbors, gardens, and beekeepers |
Kentucky's dominant Category 1(a) pest complexes are herbicide-resistant marestail, waterhemp, and Palmer amaranth in soybeans; corn rootworm and stalk borers in corn; foliar disease in wheat and double-crop soybean; and the specialty pest and residue rules of burley and dark tobacco.
Category 1(b): Agricultural Pest Control - Animal
Section 3(1)(b) scope. Persons applying or supervising the application of pesticides on animals - beef cattle, dairy cattle, swine, sheep, horses, goats, poultry, and livestock - and to places on or in which animals are confined.
Section 5(1)(b) competency. Practical knowledge of agricultural animals and their associated pests, and the relative hazards associated with such factors as formulation, application technique, the age of animal, stress, and extent of treatment. Practical knowledge is also required concerning specific pesticide toxicities and residue potentials because host animals will frequently be used for food.
The five hazard factors the regulation names are the exam's structure for this category:
| Factor | Why it changes the hazard |
|---|---|
| Formulation | An oil-based pour-on penetrates hide and reaches systemic circulation differently than a dust or a spray |
| Application technique | Whole-animal spray, pour-on, dust bag, back rubber, ear tag, and premise spray produce very different doses |
| Age of animal | Young animals have lower body mass and less developed metabolic capacity |
| Stress | Heat, transport, weaning, and disease reduce tolerance; treating stressed animals in July is a different risk than in October |
| Extent of treatment | Whole-herd versus spot treatment changes both animal risk and residue exposure |
Layered on top are the two residue clocks from Section 10.1 - the slaughter withdrawal interval and the milk discard period - and the commingling problem that makes a bulk milk tank so unforgiving. Premise treatments in confinement housing add ventilation, feed and water protection, and manure-handling considerations.
[!WARNING] Category 1(b) is Animal, not Agricultural Fumigation. Stored-grain and commodity fumigation is Category 13 (Non-Soil Fumigation) and pre-plant soil fumigation is Category 12. The old Category 1(b) Agricultural Fumigation was converted into those two by Section 10(2) of the 2022 regulation.
Category 2: Forest Pest Control
Section 3(2) scope. Persons applying or supervising the application of pesticides in forests, forest nurseries, and forest seed producing areas.
Section 5(2) competency. Practical knowledge of the types of forests, forest nurseries, and seed production within the department's jurisdiction and the pests involved, including:
- The cyclic occurrence of certain pests and specific population dynamics as a basis for programming pesticide applications - forest pests run on multi-year cycles, so the decision is a program decision, not a single-season decision;
- The relevant harmful organisms and their vulnerability to the pesticides to be applied;
- How to determine when pesticide use is proper;
- Selection of application method and proper use of equipment to minimize non-target exposures;
- Appropriate responses to meteorological factors and adjacent land use;
- The potential for phytotoxicity across a wide variety of plants to be protected, for drift, for persistence beyond the intended period of pest control, and for non-target exposures.
Kentucky forest work centers on invasive woody plant control (bush honeysuckle, tree-of-heaven, kudzu, autumn olive), bark beetle and defoliator management, forest nursery and Christmas tree production, and herbicide site preparation and release. The adjacent-land-use requirement is not abstract in Kentucky: forest tracts sit next to tobacco, gardens, and headwater streams, and the Kentucky Agriculture Water Quality Act reaches silviculture as well as agriculture.
Category 4: Seed Treatment
Section 3(4) scope. This category "applies to commercial applicators using or supervising the use of restricted use pesticides on seeds in seed treatment facilities." Note how narrow that is - it is a facility-based, restricted-use-based category.
Section 5(4) competency. Practical knowledge including:
- Recognizing types of seeds to be treated;
- The effects of carriers and surface active agents on pesticide binding and germination - the single most technical requirement in the category, because a coating that binds poorly dusts off in handling and a coating that binds too aggressively can impair germination;
- The hazards associated with handling, sorting and mixing;
- Misuse of treated seed;
- The importance of proper application techniques to avoid harm to non-target organisms;
- Proper disposal of unused treated seeds.
Two facts drive the practical exam questions:
- Treated seed must never enter food or feed channels. Treated seed is dyed a conspicuous, contrasting color specifically so that it cannot be mistaken for commodity grain. Feeding treated seed to livestock or delivering it to an elevator is a serious violation and a food-safety event.
- Dust-off is the non-target pathway. Abraded seed treatment dust carried on planter exhaust is a recognized route of pollinator exposure, which is why fluency agents, planter modifications, and handling discipline matter.
Disposal of surplus treated seed follows the label - typically planting it at a labeled rate on a labeled site, or disposal as pesticide waste. It is never landfilled casually, burned, or dumped, and in Kentucky it is never put in a sinkhole.
Exam Alert: For 1(a), memorize the seven Section 5(1)(a) knowledge areas. For 1(b), memorize the five hazard factors - formulation, technique, age, stress, extent - plus the residue clocks. For 2, the distinctive phrase is cyclic occurrence and population dynamics as the basis for programming applications. For 4, the distinctive phrase is carriers and surface active agents affecting binding and germination, and the distinctive rule is that treated seed never enters food or feed channels.
Under 302 KAR 26:020 Section 5(1)(b), which set of factors must an agricultural animal applicator specifically understand as determining the relative hazard of a treatment?
A Kentucky seed treatment facility has surplus treated soybean seed at the end of the planting season. What does the Category 4 competency standard require?
Which phrase from 302 KAR 26:020 Section 5(2) captures what makes forest pest control decision-making different from row-crop decision-making?