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Federal Credentials. and Cooperative Enforcement Agreements. David Rise U.S. EPA Montana Office (406) 457-5012 [email protected] KEY PROVISIONS. Determine issuing credential is appropriate and in EPA’s interest Develop and sign agreement with State or Tribe that addresses

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federal credentials

Federal Credentials


Cooperative Enforcement Agreements

David Rise

U.S. EPA Montana Office

(406) 457-5012

[email protected]



  • Determine issuing credential is appropriate and in EPA’s interest
  • Develop and sign agreement with State or Tribe that addresses
  • guidance elements
  • Establish tracking system for everything
  • Ensure inspector has completed required training
  • Communicate conditions and limitations on use of credential


  • Inspections at EPA request or according to inspection
  • plan
  • Inspection report submitted to EPA

EPA Region reviews report and takes

appropriate enforcement action



Before September 30, 2004

  • Varied between EPA Regions
  • Not well communicated
  • Sometimes incorrect

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Specific Training for State and Tribal FIFRA Inspectors

Mandatory and Recommended Training:

Mandatory Training

• Basic FIFRA Inspection Course “FIF901 Inspector Training” [Source: www.netionline.com “FIF901"]

Mandatory Self-Study/Review


• FIFRA §2 -Definitions

• FIFRA §3 (a), (b) & (d) -Registration of Pesticides

• FIFRA §5 -Experimental Use Permits

• FIFRA §7 -Registration of Establishments

• FIFRA §8 -Books and Records

• FIFRA §9 -Inspection of Establishments, Etc.

• FIFRA §11 - Use of Restricted Use Pesticides; Applicators

• FIFRA §12 - Unlawful Acts


Mandatory Self-Study/Review Continued:


• FIFRA §13 - Stop Sale, Use, Removal, and Seizure

• FIFRA §14 - Penalties

• FIFRA §17 - Imports and Exports

• FIFRA §18 - Exemption of Federal and State Agencies

• FIFRA §23 - State Cooperation, Aid, and Training

• FIFRA §24 - Authority of States

• FIFRA §25 (b) & (c) - Authority of Administrator

• FIFRA §26 - State Primary Enforcement Responsibility

• FIFRA §27 - Failure by the State to Assure Enforcement of State Pesticide Use Regulations

• FIFRA §28 - Identification of Pests; Cooperation with Department of Agriculture’s Program

• FIFRA §30 - Minimum Requirements For Training of Maintenance Applicators and Service Technicians

• 40 CFR Parts: 152.1 - 152.30, 156, 162, 166, 168.22, 169, and 170 [Source: www.gpo.gov/ecfr/]


Mandatory Self-Study/Review Continued:

Guidance/Reference Materials

• FIFRA Inspection Manual (2002) [Sources: CD version and hard copy - Regional Program Office, or OECA/OC/Agriculture Division, 202-564-4157]

• Label Review Manual 3rd Edition (2003) [Sources: Office of Pesticide Programs/Labeling Team (703-308-9068); www.epa.gov/oppfead1/labeling/lrm ; National Technical Information Services 800-553-6841]

• Antimicrobial Inspection Protocol [Sources: Regional Program Office; OECA/OC/Agriculture Division 202-564-4161]

• Worker Protection Inspection Guidance (2004); and the WPS How-To-Comply Mannual [Sources: Regional Program Offices; OECA/OC/Agriculture Division 202-564-4161]

• Routine Biosecurity Procedures for EPA Personnel Visiting Farms, Ranches, Slaughterhouses and other Facilities with Livestock & Poultry. – Memorandum dated 12/10/01, signed Director, Office of Compliance [Sources: Agriculture Compliance Assistance Center 888-663-2155, and at: http://epa.gov/agriculture/biosecurity.pdf; Regional Administrators; Regional Program Offices]


Mandatory Self-Study/Review Continued:

Guidance/Reference Materials

• The FIFRA Program is based on compliance with pesticide product labels. The inspector shall review a variety of registered pesticide labels to be familiar with various pesticide products. An example of these products are: insecticides, herbicides, rodenticides, antimicrobials, restricted use products, and products which contain WPS label language. A minimum of five product labels, including an RUP and a WPS product label shall be reviewed. EPA Registered pesticide labels can be found at: www.epa.gov/pesticides/pestlabels and http://www.cdms.net/pfa/LUpdateMsg.asp and another source is: http://pested.unl.edu/pat/

• Review a minimum of four completed inspection reports/files for each type of FIFRA inspection activity for which inspections will be conducted.


Recommended Training

• Core FIFRA workshops [as sponsored and offered by Office of Enforcement and Compliance Assurance (OECA) or the Regional FIFRA Program Offices] • Pesticide Inspectors Residential Training Courses (PIRT) (as sponsored by OECA/OC/AD, and/or the Region and States) [Courses include: Worker Protection Standards (WPS), Pesticide Use/Misuse Inspections, Pesticide Product Inspections and Sampling Procedures]

• Pesticide Regulatory Education Program Courses (PREP) are primarily for Program Managers and/or Senior Program Staff (as sponsored by OPP/OECA - John Ward OPPTS/OPP/FEAD 312-315-9510) [Source: www.prep-gov.net]


Recommended Self Study/Review

• 40 CFR Parts: 152, 153, 157, 159, 167, 168, 171, 172, 173, and 174 (U.S. Environmental Protection Agency) [Source: www.gpo.gov/ecfr/]

• 19 CFR Parts: 12, 18, 19, and 146 (Department of the Treasury, U.S. Customs Service) [Source: www.gpo.gov/ecfr/]

• 49 CFR Parts: 171 - 180 (U.S. Department of Transportation) [Source: www.gpo.gov/ecfr/] • Compliance/Enforcement Guidance Manuals, Vol. 1 - 5 [Sources: Regional Program Offices; OECA/OC/Agriculture Division]

• Pesticide Registration Notices (PR Notices) [Source: http://www.epa.gov/PR_Notices/]


Mandatory On-the-Job Training (OJT) and mentoring with senior lead FIFRA inspector:

  • Inspectors are required to conduct a minimum of three inspections for each type of applicable inspection activity with a lead inspector, prior to leading an inspection. The actual number of inspections required before the inspector is approved to lead inspections will be determined by the inspector’s first-line supervisor. [Note: this includes inspection preparation procedures with a senior inspector.]
  • Inspectors shall review such items as: Case Files, Previous Inspection Reports, Producing Establishment Reports, types of Pesticide/Device product labels for familiarity with each type of inspection activity. Inspections include but are not limited to: Pesticide/Device Producer Establishment Inspections (PEI); Retail/Wholesale/Dealer/Distributor type firms that sell/distribute pesticide/devices (Market Place (MKT), Restricted Use Pesticide (RUP) Dealer; Worker Protection Standards Inspections (WPS); Import Inspections; Use/Misuse of Pesticides Inspections; and other inspections described in the FIFRA Inspection Manual (2002).

Mandatory Refresher Training:

  • • Federal and/or State -Tribal program specific refresher training as identified by the supervisor; the EPA Region or Headquarters.


How do we meet these







Develop and sign agreement with State or Tribe that addresses guidance elements

  • Training- Section 5H of Appendix 3
  • When EPA credentials will be used
  • How State or Tribal and EPA inspections differ
  • FIFRA Inspection Manual
  • State Quality Management Plan
  • Disinfectant Sample Collection Protocol
  • Feedback on inspections, reports and enforcement


  • EPA has made the determination that it is appropriate to authorize employees of the Department of Agriculture to conduct inspections using EPA credentials under conditions specified in this agreement.
  • Training and Use
  • In order to be authorized to receive an EPA inspector credential,
  • a state inspector must have completed the following training:
  • EPA’s Basic Inspector Training
  • 24 hr Health and Safety Training (Safety, Health and Environmental Management Training for Field Activities)
  • Review of the terms and conditions of credential authorization
  • Basic FIFRA Inspection Course (FIF901 Inspector Training)
  • Review of the statute (FIFRA), the implementing regulations 40CFR 152.1-152.30, 156, 162, 166, 168.22 and 170, and the Mandatory Self-Study/Review Guidance/Reference Materials as listed in the credential issuing guidance document
  • Mandatory On-the Job Training (minimum of three inspections for each type of inspection activity with a lead inspector).
  • In addition, each authorized state inspector must undergo annual health and safety and program specific refresher training as required by their supervisor and/or EPA.

Appendix A

  • Section 2: Training Documentation/Certification by State/Tribe
  • Training Documentation
  • Basic Inspector Training Course. Date completed:_________________________
  • Initial Health and Safety Training Course. Date completed:__________________
  • Refresher Health and Safety Training Course. Last date completed:___________
  • Program Specific Training. Statute:________ . Date completed:______________ *Please attach a list of the Mandatory training items (including OJT and Refresher training) required for this statute from the Guidance, and list corresponding completion dates.
  • Training on the Terms and Conditions of the Authorization
  • B) Training Certification
  • I certify that the above named individual has completed all inspector training listed
  • in Appendix 3 of the Guidance (or has completed training that covers the same
  • material) as documented above. I further certify that the above named inspector needs
  • credentials in order to conduct inspections on behalf of EPA pursuant to the
  • authorization agreement.

Appendix B – Required

  • Required Form for Requesting Credentials from Headquarters
  • Please note: A separate Appendix B form is required for each statute and state/tribe.
  • Please complete the following information:
  • Region:__________ Statute (one only):_____________ Date of Request:____________
  • State/Tribe rganization/Department:__________________________________________
  • RCC (or alternate) Name: ___________________________ Phone #:______________
  • Mailing Address/Mail Code (to which credentials are to be sent):___________________
  • ______________________________________________________________________
  • ______________________________________________________________________
  • B) Please Check off the following:
  • _____Authorization Agreement which contains required elements in Guidance is in place
  • _____Training has been verified and documented by the Region
  • _____Credential Tracking System is in place
  • _____Inspection Work Plan is in place

Appendix C - Optional

  • Model State/Tribal Inspection Credential Tracking Record
  • Section 1: Credential Information
  • State/Tribal Inspector Full Name: ___________________________________________
  • Credential Number:________ Statute:_________ Expiration Date: _________________
  • State/Tribal Organization/Department: _______________________________________
  • State/Tribal Inspector’s Supervisor Name: ____________________________________
  • Section 2: Transfer of Credential from Region to State/Tribal Inspector’s Supervisor
  • I certify that I mailed a credential completed with the inspector information above to the State/Tribal Inspector’s Supervisor named above.
  • _____________________________ ___________________________________
  • Full Name Signature/Date

It Goes On …


Section 3: Date the State/Tribal Inspector’s Supervisor transfers the credential to the Inspector and Return

  • I (S/T Inpspector’s Supervisor) transferred the credential to the Inspector named above.
  • ______________________________ __________________________________
  • S/T Inspector’s Supervisor Full Name S/T Inspector Supervisor Signature/Date
  • I (State/Tribal Inspector’s Supervisor) received the credential back from the Inspector named above.
  • ______________________________ __________________________________
  • S/T Inspector’s Supervisor Full Name S/T Inspector’s Supervisor Signature/Date

And On …


Appendix D – Required

  • Required Credential Acknowledgment and Receipt
          • Section 1: Credential Information
          • Credential Number:____________ Expiration Date: ____________ Statute: _________
          • State/Tribal Inspector Full Name
          • (First, Middle Initial, Last):_________________________________________________
          • State/Tribal Organization/Department:_________________________________________________
          • State/Tribal Inspector’s Supervisor Name
          • (First, Middle Initial, Last):_________________________________________________

Section 2: Signature of State/Tribal Inspector (The inspector must read below and sign below acknowledging to the terms of the agreement).

  • I acknowledge receipt of the above referenced EPA inspector credentials and understand that in the event I transfer, resign, are no longer employed as an inspector, or the credentials are no longer required, authorization is suspended or revoked, upon credential expiration, or a lost credential is found, they will be surrendered to my supervisor named above.
  • I agree that at any time upon request by EPA or my supervisor, I will surrender this credential.
  • I also agree that I will not relinquish or allow anyone …

The Inspector signs this form.

It is sent to the EPA Region






An actual e-mail.


I just left you a long voice mail. Sorry. Here are our remaining comments on the Montana agreement.

Comments which need to be addressed in the Montana agreement and future FIFRA agreements:

- Please reference or attach section 5-H of Appendix 3 of the September 30, 2004 Guidance for …