A Closer Examination of EPA’s Proposed Amendments to 40 CFR Part 171: Certification of Pesticide Applicators – Impacts on Texas

Dean A. McCorkle, Dan D. Hanselka, Don L. Renchie, Mark A. Matocha, Janis J. Reed


In 2015, the Environmental Protection Agency (EPA) published a report entitled “Economic Analysis of Proposed Amendments to 40 CFR Part 171: Certification of Pesticide Applicators.” The objective of this study was to assess EPA’s report; more specifically, the estimated economic impact on Texas pesticide applicators and the state. Additionally, an effort was made to replicate EPA’s economic cost calculations for Texas. For private and commercial applicators, most of EPA’s estimated costs are tied to the proposed minimum age requirement. Several economic costs were identified that were not taken into account by EPA. We contend that these should be included in order to assess the full economic impact associated with the proposed changes in regulations. For private applicators, these costs include time and travel costs to attend the proposed additional certification trainings. For commercial applicators, they include lost business revenue and associated travel cost. For the state, costs include Texas A&M AgriLife Extension Service agricultural agents’ and specialists’ time and increased travel expenses to conduct more certification trainings. As a result of this analysis, the authors developed a template that allows states to determine the economic impact (on agencies and applicators) of EPA’s proposed changes within their states.

Keywords: certification and training, economic costs, Environmental Protection Agency (EPA), pesticide applicators

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