9.6 Additional Certification: Fumigation, Aerial & Restricted Devices

Additional Certification: Fumigation, Aerial & Restricted Devices

Buried inside the CORE application-methods competency is a rule every Missouri candidate is expected to recognize. 40 CFR 171.103(c)(7)(ii) requires knowledge of which application method to use in a given situation and that use of a fumigant, aerial application, sodium cyanide, or sodium fluoroacetate requires additional certification.

Four categories of work sit behind an extra gate. Being certified in the use category is not enough.

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1. The Four Gated Activities and Missouri's Category Answer

+-----------------------------------------------------------------------------+
|            ACTIVITY -> ADDITIONAL MISSOURI CERTIFICATION REQUIRED           |
+-------------------------------+---------------------------------------------+
| FUMIGATION (structural,       | Category 7C - Fumigation Pest Control       |
| commodity, and MOLE control)  | (commercial / noncommercial / public)       |
+-------------------------------+---------------------------------------------+
| SOIL FUMIGATION               | Category 12 - Soil Fumigation Pest Control  |
| (excludes moles)              | Private equivalent: Category 21             |
+-------------------------------+---------------------------------------------+
| NON-SOIL FUMIGATION           | Private: Category 22                        |
| (grain bins, commodities)     | Commercial: Category 7C                     |
+-------------------------------+---------------------------------------------+
| AERIAL APPLICATION            | Category 13 - Aerial Pest Control, PLUS the |
| (manned or unmanned aircraft) | proper category of use. Private: Cat. 23    |
+-------------------------------+---------------------------------------------+
| SODIUM CYANIDE /              | Federal predator-control standards,         |
| SODIUM FLUOROACETATE          | 40 CFR 171.103(d)(11) and (d)(12).          |
| (predator control devices)    | PROHIBITED to provisional private           |
|                               | applicators without exception.              |
+-------------------------------+---------------------------------------------+

The mole detail Missouri tests: Category 7C covers "use of fumigants for structural pest control and mole control," while Category 12 soil fumigation is "for the control of pests (excluding moles) found in or on labeled sites." Fumigating for moles is 7C, not 12.

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2. Why Fumigants Get Their Own Standard

A fumigant is a gas. It does not stay where it is placed, it is not stopped by ordinary PPE, and several fumigants are odorless or have poor warning properties at dangerous concentrations. The federal standards in 40 CFR 171.103(d)(13) therefore add an entire competency set for soil fumigation. The examinable themes:

Labeling and comprehension

• Labeling requirements specific to soil fumigants.
• Requirements for certified applicators of fumigants, fumigant handlers and permitted handler activities, and the safety information the certified applicator must give noncertified applicators using fumigants under direct supervision.
• Entry-restricted periods for tarped and untarped field application scenarios.
• Fumigant-specific recordkeeping requirements.
• Labeling provisions unique to products containing certain active ingredients.

Safety

• How certified applicators, supervised noncertified applicators, field workers, and bystanders become exposed.
• Common problems and mistakes producing direct exposure.
• Signs and symptoms of human fumigant exposure.
• Air concentrations that require respirators to be worn, or that require exiting the work area entirely.
• What to do if an applicator experiences sensory irritation — the label-driven stop-work trigger.
• Air monitoring: when it is required, and where and when to take samples.
• Buffer zones: monitoring procedures and who is permitted inside one.
• First aid for fumigant exposure, and labeling requirements for transportation, storage, spill cleanup, emergency response, safe disposal of containers and contaminated soil, and management of empty containers.

Chemistry and application

• How fumigants change from liquid or solid to gas and how they disperse in the application zone.
• Compatibility of tanks, hoses, tubing, and equipment with the fumigant.
• Application methods including water-run and non-water-run, site characteristics influencing exposure, and temperature inversions.
• Weather conditions limiting application — air stability, temperature, humidity, wind currents.
• Soil sealing methods and how to choose among them; tarp selection, sealing, and labeling requirements for removal, perforation, and repair.
• Calculating product needed for a treatment area and calibrating fumigant application equipment.

[!IMPORTANT] Fumigant labels frequently require physical presence. The general rule is that direct supervision does not require the certified applicator to be physically present. Fumigant labeling routinely overrides that, and 40 CFR 171.103(c)(1)(iv) makes recognizing such labeling a CORE competency in its own right. A fumigation management plan, air monitoring, buffer zone posting, and an emergency response plan are label requirements — and therefore legal requirements — not best practices.

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3. Aerial Application

Category 13 is a rider. 2 CSR 70-25.100 states that the aerial applicant "shall not only demonstrate competence in the category of Aerial Pest Control, but must also be certified in the proper category(ies) of use." An aerial applicator spraying row crops needs 13 + 1A; one treating forests needs 13 + 2.

The category's stated scope is "pesticides applied by any manned or unmanned aircraft, either fixed or rotary wing." Drone applicators are inside this category, and drone work also carries independent FAA requirements that Missouri certification does not replace.

The aerial competencies emphasized in the federal standards and MU Extension's Aerial Applicators' Manual (MX326) include swath displacement and offset, release height, droplet spectrum control at high airspeed, vortex effects at the wingtip or rotor, marking systems including GPS and flaggers, and recordkeeping requirements for aerial applications including application conditions.

Aerial application also carries the largest Application Exclusion Zone under WPS — 100 feet — and the greatest drift exposure of any method, which is why inversion recognition (Section 6.2) matters most here.

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4. Sodium Cyanide and Sodium Fluoroacetate

These two predator-control materials are singled out by name in the federal CORE standards because of their extreme hazard.

• Sodium cyanide is deployed in mechanical ejection devices (M-44s). The federal standards in 40 CFR 171.103(d)(11) require knowledge of the EPA Administrator's use restrictions, safe handling and placement of capsules and devices, proper use of the antidote kit, notifying medical personnel before use of the device, conditions and restrictions on when and where devices may be used, consulting U.S. Fish and Wildlife Service maps to avoid endangered species, maximum device density, supervision and monitoring, information exchange where more than one agency may place devices, and specific recordkeeping, monitoring, field posting, storage, and disposal requirements.
• Sodium fluoroacetate ("1080") is used in the livestock protection collar. The standards in (d)(12) require knowledge of where and when products may be used, safe handling and placement of collars, practical treatment of poisoning in humans and domestic animals, and requirements for field posting, monitoring, recordkeeping, storage, disposal of punctured or leaking collars, disposal of contaminated animal remains, vegetation, soil, and clothing, and reporting suspected or actual poisoning, mishap, or injury to threatened or endangered species, humans, domestic animals, or non-target wild animals.

Missouri's provisional restriction. Of the five conditions on a Certified Provisional Private Applicator (RSMo 281.020(2)(e)), two come straight from this list: the RUP may not be a fumigant, and it may not contain sodium cyanide or sodium fluoroacetate. A third bars aerial application equipment. The 16- or 17-year-old provisional applicator is walled off from all three gated activities.

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5. Recognizing the Gate on the Label

You will not always be told a product is gated. Look for:

• The words fumigant, fumigation, or a fumigation management plan requirement.
• Buffer zone tables and air monitoring requirements.
• A statement that the certified applicator must be physically present.
• Respirator requirements tied to measured air concentrations rather than to the task.
• Statements restricting application to aerial equipment or naming aerial-specific parameters.
• Any reference to sodium cyanide, sodium fluoroacetate, M-44, or livestock protection collar.

When any of these appears, stop and confirm the certification before the job — not after.