Dear Certified Crop Advisors,

Please be advised that each state within the Northeast region maintains its own definition of “use” when it comes to pesticides. These definitions can vary significantly, and it is essential that you take the time to understand the specific rules and regulations of any state in which you are working to ensure full compliance.

As an example, the State of Vermont outlines its definition of “use” in the Vermont Rule for Control of Pesticides (Page 9, Section (d), Subsection 1.71) as follows:

“Use” means:

(a) Pre-application activities involving mixing and loading a pesticide;

(b) Applying a pesticide, including supervising the use of a pesticide by a noncertified applicator;

(c) Other pesticide-related activities, including transporting or storing a pesticide container that has been opened, cleaning equipment, and disposing of any excess pesticide, spray mix, equipment wash water, a pesticide container, and other pesticide-containing material; or

(d) Recommending the use of a pesticide.

This example highlights how broadly “use” may be defined and reinforces the importance of reviewing state-specific regulations prior to conducting any pesticide-related activities. Use in some states includes the recommending the need to use a pesticide.

Your diligence in understanding and adhering to these varying definitions is critical to maintaining compliance and upholding professional standards across the region.

Thank you for your attention to this matter.

Sincerely,

Shawn Wallace, CCA

Chair NRCCA