Dicamba Training Requirements — Frequently Asked Questions
Certain dicamba formulations can be used to control weeds in cotton and soybean plants that are genetically engineered to tolerate dicamba. This page has some common questions and answers to help applicators understand the dicamba product training requirements, including for "over-the-top" (use on growing plants) soybean and cotton uses.
On October 27, 2020, EPA announced the registration of two over-the-top end-use dicamba products and extended the registration for one over-the-top dicamba product, all for applications only on dicamba-tolerant cotton and dicamba-tolerant soybeans. These questions and answers reflect the latest training requirements for over-the-top dicamba products.
Learn more about the registration of dicamba for use on dicamba-tolerant crops.
- What are the training requirements for dicamba products? Are these different from certified applicator training requirements?
- Which products are impacted by the dicamba training requirement?
- Are state personnel required to give the dicamba-specific training themselves?
- Are states authorized to approve or mandate changes in the registrant’s dicamba training program? Can states restrict registrant-conducted training?
- Because the dicamba products registered for over-the-top soybean and cotton uses are restricted use, does the certified applicator training need to be taken or repeated before applying these products?
- Who must take the dicamba-specific training?
- All applicators must attend the training for the dicamba products that include over-the-top soybean and cotton uses. However, do all applicators need to obtain their certified applicator license to apply these products, or can they continue to operate under someone who already has their license?
- Are there components that the dicamba-specific training must include?
- May the state-required or the registrant-provided training be conducted online?
- One of the recordkeeping elements for Restricted Use Products is to maintain a record of the completed training. How will applicators show proof that they completed the required training?
- Who is responsible if an applicator overlooks a label requirement, even if the dicamba-specific training material covered that point?
- Do applicators need to take part in required training if they intend to use a generic form of dicamba for over-the-top application to dicamba-tolerant soybean and/or cotton?
1. What are the training requirements for dicamba products? Are these different from certified applicator training requirements?
Registrants are required as part of the terms and conditions of their registrations: how many training sessions they conducted, identifying the dates, locations, and numbers of individuals trained per session. If a company supported or partnered with other entities to provide training, they must report the names of the entities and the number of training sessions conducted by each, identifying the dates, locations, and numbers of individuals trained per session.
In response to the relatively high number of reports of alleged off-target crop damage related to the use of dicamba in 2017 and 2018, EPA, in cooperation with state lead agencies and registrants, implemented further changes to dicamba products registered for over-the-top application to dicamba-tolerant soybean and cotton.
These changes include a requirement for certified applicators to be trained specifically for application of these products to ensure better label compliance and stewardship. Product-specific training must be completed prior to using these products, and certified applicators need to take the training again annually.
Although the dicamba training does not have to be a pesticide applicator certification requirement, some states may choose to adopt a certification category or subcategory for dicamba use. Also, some states may approve dicamba training programs for continuing education units (CEU) in its applicator recertification program. For requirements in your state, contact your state lead pesticide agency. To find the contact information for your state lead pesticide agency, see the National Pesticide Information Center’s webpage on state pesticide regulatory agencies.
2. Which products are impacted by the dicamba training requirement?
The training requirements apply to the only three dicamba products that are registered for over-the-top application to dicamba-tolerant soybean and cotton. They include:
- Xtendimax with Vapor Grip Technology (EPA Reg. No. 524-617);
- Engenia Herbicide (EPA Reg. No. 7969-345); and
- Tavium plus VaporGrip Technology (EPA Reg. No. 100-1623).
3. Are state personnel required to give the dicamba-specific training themselves?
No, state employees are not required to give training. States may authorize third parties, including registrants or Pesticide Safety Education Program extension experts, to do the training. At the state’s discretion, states may decide to rely exclusively on registrant-sponsored training.
4. Are states authorized to approve or mandate changes in the registrant’s dicamba training program? Can states restrict registrant-conducted training?
If a state decides to regulate the registrant’s training program, the state would do so through its regulatory system. In states where these questions are relevant, EPA is relying on the state and the registrants to work through any issues in the training.
5. Because the dicamba products registered for over-the-top soybean and cotton uses are restricted use, does the certified applicator training need to be taken or repeated before applying these products?
The dicamba-specific training is different from the certified applicator training, and does not replace the requirements to become a certified applicator or to maintain a certified applicator’s license.
You must be a certified applicator to apply dicamba over-the-top products. It is possible in your state that the certified applicator training could include the dicamba training as well.
For more information, contact your state lead pesticide agency. To find the contact information for your state lead pesticide agency, see the National Pesticide Information Center’s webpage on state pesticide regulatory agencies.
6. Who must take the dicamba-specific training?
The pesticide product label for these products states they are to be used by certified applicators only. Certified applicators involved in the application of the three products registered for over-the-top use on dicamba-tolerant soybean and/or cotton are required to complete the training annually.
7. All applicators must attend the training for the dicamba products that include over-the-top soybean and cotton uses. However, do all applicators need to obtain their certified applicator license to apply these products, or can they continue to operate under someone who already has their license?
The products may only be applied by the certified applicator, not by someone under the supervision of a certified applicator. Non-certified personnel may not perform any activities with dicamba products, including mixing or loading.
8. Are there components that the dicamba-specific training must include?
EPA is not designing these training requirements. However, the focus of the training should be to address the new labeling requirements and restrictions that are included in the revised product labels, and to train applicators on:
- How to determine appropriate buffer distances;
- Best management practices to avoid conditions that favor drift and/or temperature inversions;
- Sprayer rig cleanout procedures;
- Training for Bulletins Live 2!;
- Record keeping requirements;
- Application timing;
- The prohibition on the use of the dicamba products not intended for use on DT crops formulation for all application timings
- The use of newly required pH buffering agents/adjuvants (volatility-reduction adjuvants) and/or drift reduction adjuvants.
- How users/growers can report incidents to EPA and states; and
- Any conditions/circumstances that exist in the state that may be relevant to careful applications.
9. May the state-required or the registrant-provided training be conducted online?
Each state can choose how to implement the required dicamba-specific training and to determine the most effective method for delivering training. Online training is acceptable to EPA.
10. One of the recordkeeping elements for Restricted Use Products is to maintain a record of the completed training. How will applicators show proof that they completed the required training?
Once the training is completed by the applicator, a certificate should be provided that the applicator can keep as a record. (One of the recordkeeping elements for these registrations requires the certified applicator to show proof of completing dicamba-specific training.)
Some states have decided to maintain a database of individuals who have completed the training. EPA encourages each state to work with their training coordinators and/or registrants to provide applicators with proof of training, once completed.
11. Who is responsible if an applicator overlooks a label requirement, even if the dicamba-specific training material covered that point?
The intent of the training is to provide the best understanding of the product labeling possible to ensure careful applications that follow all label restrictions and directions for use. Ultimately, it is the applicator’s responsibility to apply the product in strict accordance with the product labeling.
12. Do applicators need to take part in required training if they intend to use a generic form of dicamba for over-the-top application to dicamba-tolerant soybean and/or cotton?
There are only three products approved for over-the-top use on dicamba-tolerant soybean and cotton:
- Xtendimax with VaporGrip Technology (EPA Registration number 524-617);
- Engenia Herbicide (EPA Registration number 7969-345); and
- Tavium VaporGrip Technology (EPA Reg. No. 100-1623).
Application of any other dicamba product to dicamba-tolerant cotton and soybeans, that is not registered for use on dicamba-tolerant soybean and cotton, is strictly illegal. This will be considered a misuse and is punishable by law.