Changes to CEU Requirements for Commercial Applicators in 2023

New laws and regulations governing the sale, use, and storage of pesticides as well as changes to training and certification standards were approved earlier this year and will be implemented in 2023. This is the most significant change to the program since 1978. While in September I outlined some of the more important changes for the Private and Commercial Applicator Programs with two Kentucky Pest News articles, in this article I explore changes to the CEU requirements for commercial applicators and how these changes can affect recertification and relicensing.

New Category Structure and Recertification

Beginning in 2023, there will be fewer commercial categories, several have been consolidated or split and a few have been eliminated. In terms of those that have been consolidated, the old categories 3 (Lawn and Ornamental), 18 (Golf Course), 19 (Interior Plantscape Pest Control), and 20 (Athletic Turf) will be consolidated into the new Category 3; Turf, Lawn, and Ornamental Care. People certified in any of those 4 categories will be issued a new Category 3 certification without having to retest. The previous fumigation categories of 1b (Ag Fumigation) and 7b (Structural Fumigation) have been separated into the new categories of Category 7b (Structural Fumigation), Category 12 (Soil Fumigation), and Category 13 (Non-Soil Fumigation). This new Category 13 covers fumigation of structures which are not habitable such as grain bins and grain cars, while Category 7b, Structural Fumigation, also addresses fumigation of habitable structures. Persons holding current Category 1b certification will be certified in both Categories 12 and 13 without having to retest. The categories being eliminated are 12 (Pesticide Retail Sales Agent), 13 (Anti-Fouling Marine Paint), 14 (Consultant), 15 (Anti Microbial), and 16 (Sewer Root Control). While retail pesticide sales agents will not be certified, the business must be registered and maintain and submit necessary records to the KDA.

General CEUs Eliminated

In the past, commercial applicators had to accrue 9 general and 3 category-specific CEU credits by the end of their third year of the certification period to be eligible to recertify. With the new system, they need to earn 12 CEU credits with at least one being in each of the categories they are certified in. So, applicators do not need to keep track of general and category-specific CEU hours. In order to deliver the general information to commercial applicators, presenters applying for CEU credit will need to identify what general pesticide safety and use educational material they will cover in their presentation in order to receive approval.

Annual CEU Requirement

However, what has changed is that each year with relicensing (licenses are valid for one year and certifications last for 3 years), applicators must have 12 CEUs earned in the previous 3 years. In the past, applicators only had to meet this requirement when they recertified every 3 years. This is to ensure that applicators receive more frequent pesticide updates. For people that have just taken the test and passed, they will be awarded 12 CEU hours that first year which will cover that requirement until they recertify in 3 years. My recommendation is to have applicators get into the habit of earning at least 4 CEU each year in order to meet this requirement.

License Renewal Grace Period Shortened

In the past, commercial applicators had 90 days to pay the annual fee and renew their licenses online. That grace period has been shorted to 31 days past the expiration of the license. Persons not renewing their license before the end of the 30-day period will not be able apply pesticides and will have to pay their license fee, a late fee penalty, and may have to retest.

Penalty for not Earning CEUs

Commercial applicators that have not earned the necessary 12 CEUs in the previous 3 years will need to retest and will be subject to a $200 recertification fee. This is to encourage commercial applicators to stay up to date in their areas by earning CEU credits. The best practice for applicators will be to earn at least 4 CEU hours each year and for persons organizing training sessions for pesticide education credit to offer at least 4 CEU hours.