View Full Version : What is the purpose of applicator's licensing?
09-03-2003, 12:11 PM
I know the title of this one will generate a lot of lookers. I don't want to sound naive, but this question becomes an issue for all professionals when selling organic products to your clients.
Maybe I am naive, but to me the purpose of the law is to protect the environment from the overapplication of poisons. Are there other reasons for the law? This is a serious question.
Because here's the issue with organics. The way the organic program works is to build up a soil and plant population of beneficial microbes. Inside the soil and outside on the plant surfaces are tens of thousands of species of microbes both beneficial and pathogenic. When the soil contains adequate amounts of sugar and protein, the beneficial microbes will outperform the pathogens leading to all forms of good plant health similar to when chemical fertilizers and pesticides are applied. So does the simple application of sugar and protein to the soil surface constitute the application of a pesticide? It sometimes has the same effect.
Allow me to get specific. Ordinary corn meal, when used at 10-20 pounds per 1,000 square feet, is a great organic microbial food. When it is applied to the surface of the soil, the microbes start their digestion process and eventually a fantastic plant food is produced which the roots take up and turns plants dark green - just like nitrogen fertilizer! Corn meal also highly encourages anti-fungal microbes when used at the same rates - just like a fungicide. Is that a problem for applicators? Here's another example: corn GLUTEN meal is a superior organic fertilizer at 10 pounds per 1,000, but when used at 30-40 pounds per 1,000 also has preemergent herbicide qualities. Is that a problem?
Both products are safe to eat in large quantities on a daily basis for entire lifetimes. So when, if ever, do you need an applicator's license to apply corn meal and corn GLUTEN meal?
If the purpose of the law is to protect the environment from poisons, these organics are not poisons. Do we need the protection of licensing to keep us from non poisons? This gets back to the reason for the law. If it is for more than protection of the environment, I would like to know.
09-03-2003, 01:25 PM
Dchall - yes, the licensing requirements are for the protection of the environment and the people who rely on it. From my understanding (and i could be wrong), most of the pesticide requirements for applicators were implemented after the PBB/PCB problems in Michigan in the 70's. Apparently, someone mistakenly added a fire ******ant chemical (which contained PBB/PCB. These chemicals contained dioxin) to cattle feed, thinking that they were adding a feeding supplement. Well, that feed was shipped all over Mich. and the cattle had to be destroyed by the thousands. This apparently had been going on for some time and folks actually comsumed tainted beef and dairy products. As time went on, the gov't added additional regulations as they deemed necessary. This is where we are at today with the licensing requirements to apply pesticides. Will organic products need EPA certification to be used commercially in the future? I would bet they would. And I would also bet you'll be seeing this happen fairly soon as more studies are done on organics, albiet at a slower pace compared to chemicals. For now, we'll have to wait and see, or become proactive to hasten the process for organic certification.
Now to help answer another of your questions, not all products with the organic label are safe. I remember when you could use nicotine as an insecticide, but not any more. Also, pyrethrum based insectides were derived from ground up chrysanthemum plants. Now, if you are using cornmeal as a fungicide, could there be detrimental side effects? I, for one, would doubt it, but I'd be much more comfortable applying it if it had a thorough study done to find out. Don't get me wrong, I'm in favor of using organic products. I just don't want to lose my Pesticide Liscense by using them until the EPA registers them. HTH.
09-03-2003, 04:57 PM
DCHall - I have talked with people from the Structural Pest Control Board as well as the Dept of Ag and they have told me personally over and over that the rules are as follows (for us Texans).
Without a license you can apply Fertilizers and organic "bug killers" as long as they are not listed as a pesticide. As they both explained to me, I cannot spray RoundUp without a license, but I can spray my vinegar/salt solution. I may not spread Weed-n-Feed, but I can spread corn meal or straight fertilizer.
I don't know anything about pesticides and I am not licensed, nor am I seeking a license at this time. I believe that I may be able to operate successfully without ever getting one. This may change one day...
Don't misunderstnd me, I am interested in educating myself in this area.
Neither do I trust anything I hear from a State employee, unless I hear it from a number of sources. If you know differently, please let me know. Thanks.
A1 Grass, I am, unfortunately from a personal experience, very familiar with TDA guidelines and enforcement processes. No, I was not the one investigated. The simplest way to put it is this way: TDA considers anyone who applies any type of chemical, and there is no distinction between organic and synthetic, for hire to be a commercial applicator.
If you wish, I can provide direct telephone numbers to confirming State supervisors.
The state allows for quantities below one quart to be made available to unlicensed individuals for home use only. Hence, why Home Depot can sell some chemicals, but not beyond one quart quantities.
The state operates off of a observation/complaint basis. If a TDA employee (I did not say Inspector) reports an application with an unmarked tank, or worse yet, an Inspector sees it - you - the applicator have to prove you have a license. I am speaking of a conceivable LCO setting, try convincing an Investigator that what you are doing is for no pay whatsoever.
There are mandatory fines the Inspectors have no discretion to waive.
Bear in mind, the Structual Pest Control Board has been trying for a number of years to swallow up the TDA.
What I would recommend is that you contact the TDA's enforcement branch in Austin and have a supervisor there confirm what I am saying.
If I am proven incorrect, I will say so.
Dchall, license requirements are in place to protect a multitude of people, from applicators, consumers and bystanders.
Unfortunately, I have to cut this short.
09-03-2003, 08:57 PM
SWD - Thanks. You can see now why I don't trust most of the people I talk to when I call a State agency. Apparently I was provided with false information by the people that work there. Imagine that... tax dollars at work...
09-04-2003, 12:36 AM
For everyone, licensed or not, here is the FIFRA definitions page: TITLE 7 > CHAPTER 6 > SUBCHAPTER II > Sec. 136 (http://www4.law.cornell.edu/uscode/7/136.html) Scroll down to the definitions for "pest" and "pesticide" and read and understand. Every state pesticide regulatory legislation I have read uses similar definition.
Now if you understand them, answer this question: If I find that my dog's urine kills dandelions, do I need a license to hire out my dog to kill weeds? In states I've checked, yes. BUT, I can only use him if he has a legal pesticide label on him.
And for someone to use salt on lawns? Salt is more toxic to humans and most other life than most lawn care chemicals.
09-04-2003, 12:08 PM
Salt on lawns? Who said that?
Most fertilizer whether organic or synthetic is a "SALT"
09-04-2003, 02:38 PM
I'm pretty sure organic fertilizers are not considered to be salts. Salts are the simple ionic combination of a metal and a near-noble gas from the periodic table of elements. Salts usually dissolve (or ionize) in water. Ammonium sulfate is the combination of the ammonium ion and the sulfate ion.
Corn, alfalfa, cottonseed, feathers, milo, soy, canola, etc. are not of that nature. These are complex, naturally occurring, protein strings usually combined in a cellulose structure with some other carbohydrates tossed around in there.
09-04-2003, 06:54 PM
Originally posted by A1 Grass
......I cannot spray RoundUp without a license, but I can spray my vinegar/salt solution.
That was what I was referring to. And the vinegar is dealt with in another thread.
09-04-2003, 07:51 PM
Originally posted by GroundKprs
That was what I was referring to. And the vinegar is dealt with in another thread.
Right. And as I mentioned, I never said anything about spraying it on lawns. (that would be stupid).
Also, my reply really had nothing to do with the use of vinegar, I used it as an (incorrect) example for what could be sprayed with and without a license... see? So, yes - if I want to talk about vinegar I will go to the vinegar thread. I think I can find my way there...
Thanks for the link, it was informative.
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