Healthy Environment, Healthy Community, Healthy Business

Environment Protection Authority

Environmental Issues

Chemicals and pesticides

Pesticides training: frequently asked questions

Overview

The following information, grouped under topic headings, provides answers to some specific questions about mandatory training requirements.

Herbicides

Small use exemption

Occasional use exemption

Types of users who need training

Purchasing pesticides

Subsidies

Competency

Reassessment

Herbicides

Is training needed if I apply herbicides?

Yes. Herbicides are classified as a pesticide under the Pesticides Act 1999. You must be trained if you use any type of pesticide or herbicide on produce that will be sold commercially or if you use it as part of your job or business.

Small use exemption

What is the 'small use' exemption?

The small use exemption (clause 10(2)(c), Pesticides Regulation 2009) exempts people who have not received training, provided they use only small quantities of a pesticide that is ordinarily used for domestic purposes and widely available to the general public at retail outlets (e.g. supermarkets) and that they only apply the pesticide by hand or a hand-held applicator.

What is 'hand-held' equipment under the small use exemption?

The hand-held applicator can be either hand-powered (e.g. backpack) or powered (e.g. a hand applicator attached to a pump on the back of a truck). The important thing is that the pesticide is distributed by hand, not applied by mechanical equipment (such as a boom-spray on the back of a tractor). Note this is not the case under the occasional use exemption – see below - clause 10(2)(d) where the equipment used must be hand-held and hand-powered.

What is a job?

As with record keeping, the quantities in the small use defence apply to each 'job' that the pesticide user does. A commonsense definition of job applies here. Spraying on two separate properties during a day is considered two jobs. If you started the spraying one day and finished it the next, it would be considered one job. If you were spraying weeds along a roadside the 'job' would be the complete job you set out to do in that day - the exemption would not apply each time you stop to hand-spray a patch of weeds during that job.

What 'domestic' products are exempt?

'Domestic' products are those products that you can buy in a supermarket or hardware store and can be used by the householder in the home or around the garden. These products contain label instructions for use in domestic situations such as in the home or around the garden (for example, glyphosate products). There are too many products for the Environment Protection Authority (EPA) to provide a comprehensive list. If you are unsure, check the label.

Are products purchased from rural produce stores exempt?

Not automatically. Many people think that because these products are available to the public in a rural produce store they will fall under the small use exemption. The important thing is that the product must be something that is meant to be used by the householder in the home or around the garden, i.e. it includes label instructions that permit use by householders in the house or around the garden. [Note: for this reason backline treatments for cattle and many herbicides do not fall under this exemption]. If you are unsure, check the label.

Occasional use exemption

I understand that an exemption may apply in some agricultural situations for people who use pesticides occasionally. Does this apply to me?

You can apply pesticides occasionally as part of agricultural or forestry operations without training if you are directly supervised by a person who has been trained. For this exemption to apply:

  • The person supervising you must be trained and hold a relevant qualification under the Pesticides Regulation 2009.
  • The person supervising you must select the pesticide; prepare the pesticide for use; calibrate and test the equipment used to apply the pesticide before it is used; and instruct you in how to apply the pesticide.
  • You must only apply the pesticide using hand-held and hand-powered equipment (for example, if you are doing backline treatments for livestock or if you use a backpack and hand applicator to spot-spray).
  • You must not regularly use pesticides as part of agricultural and forestry operations – in other words you must only use pesticides on an 'occasional' basis. 'Occasional' is defined as pesticide use on no more than 12 days in the previous 12 months, and on no more than four days in the previous month.

Types of users who need training

Do hobby farmers need to be trained?

If you are selling your produce or livestock commercially, you need to be trained. If you don't sell anything and are not a commercial enterprise, training is not required under the Pesticides Regulation 2009.

Do volunteers need to be trained?

Yes – if they are working for a public authority.

However, in practice most volunteers only do the sort of work that falls under the small use exemption (hand application of domestically available pesticides such as round-up in small quantities). If they use greater quantities than those specified in the regulation (20 litres of ready-to-use product or 5 litres of concentrate for outdoor use) or if they use a product that is not readily available to the public they need to be trained.

Do I need to be trained if I handle and store pesticides?

No. If all you do is handle (e.g. load for transport) or store pesticides, you do not need training.

Do I need training if I only mix pesticides and do not apply them?

If you mix pesticides for use (e.g. adding water to concentrate) or if you calibrate equipment used to apply a pesticide, you must be trained - even if the actual application is undertaken by someone else. This currently includes loader-mixers involved in the aerial pesticide application industry.

Do I need training if I only treat livestock?

Yes, if you are putting your livestock through a spray race or a dip-bath. These are considered pesticides and are covered by the Pesticides Regulation 2009.

You do not need to be trained if you only treat livestock with internal parasite treatments (drenching) or with external parasite treatments such as backline products that do not require dilution or mixing with water. This is because these parasite treatments are regarded as stock medicines and are not covered by the Pesticides Regulation 2009.

Vets undertake chemical training as part of their university degree. Is this enough?

Not if vets are using products in their work that meet the definition of a pesticide under the Pesticides Act 1999. Vets need to undertake competency-based training under the National Training Framework in order to comply with the Regulation. It is recommended that you contact training providers in your local area to discuss undertaking a skills accreditation course or an assessment course that tests on-job experience and prior learning.

I have been applying pesticides for years – why do I need to do training?

If you are an experienced pesticide user it may not be necessary to undertake the full training course. Training providers are able to run a skills accreditation course or an assessment course that tests on-job experience and prior learning. Talk to the training providers in your local area to find out whether this would apply to you.

Can the EPA grant me an exemption from training?

No. There are no provisions in the Pesticides Regulation 2009 that allow the EPA to grant individuals or groups exemptions from training. The only exemptions available are the small-use and occasional use exemptions explained above.

Purchasing pesticides

Do I need to be trained to buy pesticides?

No. The NSW training requirements only apply to pesticide use. You do not need to meet the training requirements of this Regulation before you can purchase a pesticide. Note the Australian Pesticide and Veterinary Medicines Authority (APVMA) does require proof of training in order for users to purchase some restricted chemical products. Contact the APVMA on (02) 6410 4701 for further information.

Subsidies

Is there any government subsidy/relief to help me with the cost of training?

Fees are set by the relevant training provider and the EPA is not involved in this process. While there is currently no subsidy/relief for general pesticides users, if you are experienced in pesticides applications you may be able to undertake a shorter (and cheaper) assessment of prior learning, rather than the full course. Contact the training providers in your local area for further information.

Competency

What level of competency is required?

The minimum level of competency in pesticide use required under the Pesticides Regulation 2009 is Australian Qualifications Framework Level 2 (AQF2).

This is unit code AHCCHM201 - Apply chemicals under supervision. Earlier versions of this unit are also acceptable.

What level of training should be promoted to users?

AQF2 is the minimum level of competency. However, people should seek training that is appropriate for their level of work and experience.

If you are working as an unsupervised operator/farmer, this means seeking training at Australian Qualifications Framework Level 3 (AQF3).

What about people with language or literacy difficulties?

Major providers of chemical training have agreed to train people with language or literacy difficulties at AQF3. If you are unable to meet these competencies, you can be deemed competent at AQF2 if you successfully demonstrate competence at that level.

The EPA strongly encourages anyone who has low literacy/language skills, and who applies pesticides independently, to initially seek training at AQF3.

How do I prove that I have met these training requirements?

Proof of training is now required and may be requested to be produced at any time by an authorised officer of the EPA. The Pesticides Regulation 2009 sets out what is acceptable as proof. In summary the proof needed is:

  • a certificate or statement of attainment issued by the registered training organisation in accordance with the Australian Qualifications Framework (AQF), or a card issued by the registered training organisation that proves these have been obtained, or
  • a card, issued by another body that has been approved by the EPA, that provides equivalent record of evidence to the above forms of proof – currently this applies to cards issued by ChemCert NSW, SmartTrain and RuralBiz training, or
  • a permit or licence held by groups such as pest technicians and aerial applicators, who are subject to separate mandatory qualification requirements.

What courses meet the training requirements?

There are a number of NSW training providers and providers in other states/territories that offer training at AQF2 or above.

In order for the person undertaking the training to comply with the Regulation, the course must include the following competencies:

  • unit AHCCHM201 - Apply chemicals under supervision (for AQF2 courses)
  • units AHCCHM303 - Prepare and Apply Chemicals and AHCCHM304A - Transport and Store Chemicals (for AQF3 courses).

The predecessor competency units including those with a RTC prefix are still recognised to allow for existing qualifications and for new qualifications issued by training providers before they transition to the updated AHC Training Package.

The EPA does not approve any particular training provider or course. See where can I get information about trainers for contacts.

Reassessment

Why is regular reassessment of my pesticide application skills necessary?

Significant ongoing developments in the number of pesticides available, application technology, and community expectations regarding pesticides management mean that it is essential that all pesticide users undergo periodic assessment of their competence.

If pesticides users' application skills are not periodically reassessed or updated there is a risk that some users may develop poor practices or remain unaware of new techniques to manage pests.

This is just as important in relation to relatively simple types of applications, such as ectoparasite pour-ons, as misapplication of these pesticides can still pose risks to users' health and the environment.

Page last updated: 23 February 2017