Volume 23, No. 2, MAY 2005
Use of Insecticides Linked to Lasting
Neurological Problems for Farmers
Coordinator's Comments
Alternatives Sought to Alleviate
Herbicide Shortage
Johnson OKs Herbicides
to Control Kochia
Better Labels for
Mosquito Control Products
Johnson Approves Registration
for Blanket Herbicide
Notification When the Pesticide
Is Not Applied as Scheduled Under the Worker Protection Standard
Interpretive Statement and
Proposed Rule on the Application
of Pesticides to U.S. Waters in
Compliance with FIFRA
Senate Bill No. 2355 Enacted
Into Law
Editors note: This news release from the National Institute of Health came out on April 28, 2005. The conclusions underscore the need for using personal protective equipment to avoid long-term chronic health problems from pesticides.
New research shows that farmers who used agricultural insecticides experienced increased neurological symptoms, even when they were no longer using the products. Data from 18,782 North Carolina and Iowa farmers linked use of insecticides, including organophosphates and organochlorines, to reports of recurring headaches, fatigue, insomnia, dizziness, nausea, hand tremors, numbness and other neurological symptoms. Some of the insecticides addressed by the study are still on the market, but some, including DDT, have been banned or restricted.
These findings will be available online in April and published in the June issue of "Environmental Health Perspectives." The research is part of the ongoing Agricultural Health Study funded by the National Institute of Environmental Health Sciences and the National Cancer Institute, two of the National Institutes of Health and the Environmental Protection Agency.
"This research is really important because it evaluated the health effects of agricultural chemicals as they were commonly used by farmers. It's different from previous studies that focused on pesticide poisoning or high-dose exposures, for example when large amounts of a chemical were accidentally spilled on the skin," said Freya Kamel, Ph.D., a researcher for the National Institute of Environmental Health Sciences (NIEHS).
The NIEHS researchers examined questionnaires completed by farmers on lifetime exposure to herbicides, insecticides, fungicides and fumigants, and their history of 23 neurological symptoms. Those who reported experiencing more than 10 symptoms during the year prior to completing a study questionnaire were classified as having high levels of symptoms.
Researchers found that nearly 3,000 participants had a high lifetime exposure to insecticides — that is, they used insecticides more than 500 days in their lifetime. Nearly 800 of these farmers reported more than 10 neurological symptoms, compared to those using insecticides fewer than 50 days. The researchers found no significant association between neurological symptoms and other chemicals, including herbicides or fungicides, and only a weak association between fumigant exposure and neurological symptoms.
Some of the insecticides used by the licensed farmers over the past 25 years are no longer available commercially. DDT, a well known example of an organochlorine, has been banned for use in the U.S. since 1972.
Organophosphates, such as malathion, chlorypyrifos and diazinon, have been banned or restricted for home and garden use in the U.S. However, some of the pesticides examined, including carbaryl and some pyrethroids, are available to home gardeners, although in different formulations and in lower concentrations, which may make them less hazardous.
"Because the participants in this study are telling us they have never been previously diagnosed with pesticide poisoning or medically treated for any exposure to any pesticide, we are led to conclude that their symptoms are related to moderate lifetime exposure," said Kamel.
"Most studies of this issue have sample sizes ranging from 50 to 100 participants, making it hard to understand the detailed relationship between exposure and health effects. The large size of this study gives it great statistical power," said Kamel.
The AHS ( www.aghealth.org /) is designed to investigate the effects of environmental, occupational, dietary and genetic factors on the health of the agricultural population. The study will provide information that agricultural workers can use in making decisions about their health and the health of their families.
In this issue of the "Pesticide Quarterly," you will find a series of news releases on the issuance of special labels for the use of various sulfentrazone-based herbicides. Ordinarily, this would be ho-hum stuff, hardly worth mentioning. However, this time the stakes were huge and the issues extraordinarily complex.
Essentially, a miscalculation in the manufacture and marketing of sulfentrazone resulted in an acute shortage of the herbicide Spartan for this and future seasons. This sent users to underground markets and widespread illegal use was predicted. Desperate and agitated growers huffed in meetings with regulators and dealers that they gladly would accept the liability of fines in exchange for relief from weeds in their crops.
The good news is that everything worked out for the best (the labels were issued properly to the satisfaction of the general public and the industry). But, to quote the Duke of Wellington, who quipped soon after his victory at Waterloo, "It was a near-run thing."
Things were so hot that following the battle, NDSU Extension Service weed specialist Richard Zollinger commented:
"The Department of Ag issued a news release last week stating several reasons why a Section 18 exemption for Spartan on flax will not be possible this year. No doubt of the large volume of phone calls from flax growers to the Department of Ag describing their conundrum. In retrospect and without knowing the details of these recent happenings, one may summarize that if a group of growers makes enough noise, the Department of Ag will finally do something. This Pest Report is not the place to make a rebuttal, but a few things should be said in defense of the Department of Ag, which you will probably not see in print.
One - A different kind of Section 18 was approved (Crisis) for flax this year, meaning an unforeseeable catastrophe quickly occurred where no other remedy can solve the problem. See page 5 of the Weed Guide for an explanation between Emergency and Crisis exemptions. Time to develop a Section 18 exemption, which normally takes 50 to 60 days, including time to prepare a request document, to obtain comment from the U.S. Fish and Wildlife Service and other partner agencies, and to have EPA review the request, could not be done. So by definition, having an Emergency Section 18 on flax from 2002 to 2004 does not validate the Crisis Emergency Exemption in 2005.
Two - When Jim Gray, pesticide registration coordinator, NDDA, approached the EPA to ask for their consideration of a North Dakota Crisis Exemption on flax, he was told they will NOT support it but they will not deny it AND IF IT WERE ANY STATE OTHER THAN NORTH DAKOTA, THEY WOULD DENY IT. What does this mean? It means North Dakota has earned a good relation with EPA. It means the Section 18 packages we have submitted in years past were of high quality and we have NOT abused that registration process. It means the EPA has extended, in this one instance, some latitude. It does not mean this will ever happen again."
Further, many players were involved in this effort, but I think the words used by Larry Kleingartner, executive director of the National Sunflower Council, capture where the primary credit should go:
". . . Thanks to you and Jim (Jim Gray, pesticide registration coordinator) for your excellent work on this very difficult subject," said Kleingartner. "My board of directors, especially those familiar with pesticide issues, opined that getting Authority® and Blanket® labels was a long shot at best, and probably not doable. Well, it is done and it is a very good feeling to know that farmers will be in compliance."
While Jim is in fact a bureaucrat, pure and simple, he is someone who has not forgotten for whom he is working. He knows that his paycheck comes from members of the industry and the general public. To that end, he is an underappreciated hero in this effort. He deserves our thanks and admiration.
All the best,
Andrew A. Thostenson,
Pesticide Program Specialist
April 28, 2005
BISMARCK - The anticipated shortage of a popular herbicide, widely used in North Dakota to control kochia, especially in no-till or reduced-tillage systems, has growers, commodity groups, Extension personnel, pesticide manufacturers and state officials looking for alternatives.
"FMC Corp., the manufacturer of Spartan® herbicide, has said there will not be sufficient supplies of either Spartan® or Spartan® 4F herbicides for the 2005 growing season," said Agriculture Commissioner Roger Johnson. "We are working very hard to find other sources of sulfentrazone to replace the Spartan herbicide that sunflower, potato, bean and pea producers need."
Spartan® herbicide is a dry, flowable formulation of sulfentrazone that is labeled for use on a variety of crops, including sunflowers, peas, chickpeas, potatoes and dry beans. FMC is currently replacing Spartan® herbicide in the marketplace with a liquid formulation, called Spartan® 4F, but has encountered unanticipated manufacturing delays with this formulation change.
Johnson said he hopes other manufacturers of sulfentrazone-based herbicides will step into the breach and provide supplemental labeling for their products.
"Both Authority®, manufactured by DuPont, and Blanket® 75WDG, manufactured by Tenkoz, use sulfentrazone supplied by FMC," Johnson said. "FMC has released DuPont from its sulfentrazone supply contract, freeing DuPont to label Authority® for use on sunflowers. FMC and DuPont are now negotiating to add additional crops, and we understand that FMC is presently in similar negotiations with Temkoz."
Johnson said he understands that DuPont will distribute supplemental labeling to allow use of Authority® on sunflowers. The herbicide is already registered and labeled for soybeans in North Dakota. The North Dakota Department of Agriculture (NDDA) will inform growers and dealers if and when the supplemental labeling for Authority® becomes available.
"Unfortunately, Blanket® is not registered in North Dakota, but is used elsewhere in soybean fields," Johnson said. "We will expedite the registration of Blanket® 75WDG if we get a registration application from Tenkoz, and we will notify growers and dealers if and when supplemental labeling is received from Tenkoz allowing the use of Blanket® on crops other than soybeans."
Johnson said that to ease the shortfall of Spartan® herbicide, FMC has provided supplemental labeling for Spartan® 4F to allow its use on sunflower, pea, chickpea, and several other crops grown in North Dakota. Spartan® 4F was previously labeled and sold for use only on a handful of crops, most notably tobacco and sugarcane.
Since the supplemental labeling will not include all crops allowed by the Spartan® herbicide labeling, users should read the Spartan® 4F supplemental labeling carefully.
The supplemental labeling for Spartan 4F can be downloaded from the online pesticide registration database at www.kellysolutions.com/nd /. Growers can also obtain the supplemental labeling from either NDDA at (800) 242-7535 or their local pesticide dealer.
Johnson urged producers to keep detailed application records and to notify the appropriate manufacturer about any problem that may arise from application of the products.
Johnson said that although Spartan® could be used on flax in North Dakota in 2002 through 2004 through Section 18 exemptions, it will not be available to flax growers this year.
"FMC was unwilling to support a Section 18 exemption for use on flax until recently, making approval by EPA impossible in time for the use season," Johnson said.
Johnson said it is important for growers to use only
registered sulfentrazone products in North Dakota, and to follow all
directions, restrictions and precautions on product labeling. It is a violation
of state law to sell, offer for sale, distribute or use any pesticide
in North Dakota that has not been registered. It is also illegal to use
any pesticide product in a manner inconsistent with the labeling.
May 4, 2005
BISMARCK - Agriculture Commissioner Roger Johnson has issued a 15-day crisis exemption for Spartan® and Spartan® 4F, enabling North Dakota flax producers to use the herbicides to control kochia and ALS-resistant kochia.
In a related action, Johnson also ordered a special local need (SLN) registration to E.I. du Pont de Nemours and Co., allowing the application of Authority® herbicide on sunflower, dry field pea and chickpea fields to control kochia and ALS-resistant kochia.
"Both of these actions relate to a nationwide shortage of sulfentrazone, the active ingredient in both Spartan® and Authority®," Johnson said. "Growers of sunflowers, peas and chickpeas have used Spartan® to manage kochia for several years, and I have obtained exemptions for Spartan® to control kochia in flax for the past three years."
Johnson told the Environmental Protection Agency that producers are having increased problems with kochia in central and western North Dakota in recent years, and that much of the kochia is now resistant to herbicides that inhibit acetolactate synthase (ALS). ALS-resistant kochia has escaped control in many crops, allowing the weed to reproduce and spread throughout the state.
"The EPA limits a crisis exemption to 15 days," Johnson said. "Flax growers have through May 17 to use either Spartan® or Spartan® 4F for kochia control."
The crisis exemption allows a single ground application of Spartan® or Spartan® 4F at a rate of .09 to .25 pound of active ingredient per acre. The application may be made up to 30 days prior to, or up to three days after planting.
The SLN registration for Authority® allows application of the herbicide to sunflowers, dry field peas and chickpeas at the same rates as Spartan®. Applicators must follow all instructions, warnings and precautions on both the Section 3 label and the supplemental SLN label. The SLN labeling must be in the possession of the user during application.
Johnson said the decision to issue a crisis exemption for Spartan® and Spartan® 4F was made possible by DuPont's request for a Section 24(c) registration for Authority® on sunflowers, dry field peas and chickpeas. The herbicide is normally registered only for soybeans.
"FMC first told us last fall that there would not be enough Spartan® for 2005," Johnson said. "It was not until April 12 that we learned how much Spartan® would be available and we received assurance from FMC that they would support an exemption for Spartan® on flax. We also knew that DuPont was negotiating with FMC to allow a registration for Authority® in North Dakota."
The shortage of sulfentrazone, a proprietary FMC formula, is the result of unexpected manufacturing delays that FMC is experiencing as it replaces Spartan®, a dry flowable formulation, with the liquid Spartan® 4F.
Johnson said Tenkoz Inc. is negotiating with FMC to allow its sulfentrazone-based product, Blanket® 75WDG, to be used on sunflowers, peas and chickpeas. Blanket® is presently unregistered in North Dakota, but Johnson said NDDA will expedite a registration if requested by the company.
EPA is issuing seven new recommendations to pesticide registrants and others to improve label statements for pesticide products used to control adult mosquitoes. The recommendations pertain to pesticide products applied by ultralow-volume aerial or ground application methods. The recommendations promote consistency and clarify labeling statements that may have been unclear to users. The improvements will help public health mosquito control officials use the most effective techniques while ensuring that use of these products will not pose unreasonable risks to public health or the environment.
The recommendations are:
1. Adult mosquito control applications should be limited to trained personnel.
2. Mosquito control directions and precautions should be distinguished clearly from any other use directions allowed on the label, such as agricultural crops.
3. Label precautions and directions should be revised as needed to make hazards to aquatic life as clear as possible, and also to allow the application of these products over or near a body of water under some circumstances.
4. Users should consult with the state or tribal agency for pesticide regulation to determine if permits or other regulatory requirements exist.
5. Labels should specify a spectrum of spray/fog droplet sizes and indicate that droplet size should be determined according to directions from equipment manufacturers or other appropriate sources.
6. Precautionary language to protect bees should have a provision to allow mosquito control applications to respond to public health threats that health or vector control agencies identify based on evidence of disease organisms or disease cases in animals or humans.
7. Labels for adult mosquitoes should include limits on timing and the number of applications to the same location.
The EPA worked with state agencies to develop initial recommendations and presented them at two public meetings of the Pesticide Program Dialogue Committee, an advisory committee to EPA representing a full spectrum of interests, including pesticide manufacturers, public health agencies, academia, user groups and public interest groups. In April 2004, the EPA issued draft recommendations for public comment.
To view the seven new recommendations, go to www.epa.gov/PR_Notices . For additional information, contact: Enesta Jones, (202) 564-7873 or jones.enesta@epa.gov .
May 6, 2005
BISMARCK - Agriculture Commissioner Roger Johnson has approved registration of Blanket® herbicide, enabling North Dakota soybean, sunflower, field pea and chickpea producers to use the product to protect their crops from kochia and ALS-resistant kochia.
"The availability of Blanket® should ease the shortage of sulfentrazone-based herbicides that are widely used in North Dakota to control kochia," Johnson said.
Earlier this week, Johnson issued an SLN registration to DuPont for Authority® for sunflowers, field peas and chickpeas and a crisis exemption for Spartan® and Spartan® 4F.
Both Blanket® and Authority®, as well as the two Spartan® formulations, contain the active ingredient sulfentrazone.
The product label for Blanket® allows pre-emergence applications to soybeans at a rate of 3 to 8 ounces of product per acre, depending on soil type. The supplemental label for sunflowers allows preplant, pre-emergence and preplant-incorporated applications with ground equipment at a rate of 2 to 5.3 ounces of product per acre. For field peas and chickpeas, the supplemental labeling allows fall or spring preplant, pre-emergence and preplant-incorporated applications with ground equipment at a rate of 1.5 to 5.3 ounces of product per acre.
Sunflower, field pea and chickpea growers may not apply more than 5.3 ounces of product per 12-month period. The label also prohibits applications to be made by air or through irrigation systems.
Applicators must follow all instructions, warnings and precautions on both the Section 3 label and the supplemental labeling. The supplemental labeling must be in the user's possession during application.
Blanket® is manufactured by Tenkoz Inc.
Johnson said the availability of sulfentrazone-based herbicides is crucial to many producers, since most kochia is now resistant to previously registered herbicides.
"Sulfentrazone is very effective against kochia and ALS-resistant kochia," he said. "Unfortunately, there is a shortage of Spartan®, which until this week was the only sulfentrazone-based product labeled for sunflowers, dry peas and chickpeas."
The shortage of Spartan® results from unexpected manufacturing delays that FMC is experiencing as it replaces Spartan®, a dry flowable formulation, with the liquid Spartan® 4F. Until now, Blanket® and Authority® had only been approved for use on soybeans. FMC recently released Tenkoz and DuPont from supply contracts, freeing the companies to label their products for other crops.
Johnson commended DuPont, Tenkoz and especially FMC for their efforts in making these products available to North Dakota growers.
"By working together and with the North Dakota Department of Agriculture (NDDA), these companies filled a real need for North Dakota producers," he said. "They deserve recognition for their efforts."
Johnson also commended Jim Gray, NDDA's pesticide registration coordinator, for his work in obtaining the registrations and exemptions for the sulfentrazone-based products.
"Jim did an outstanding job of managing this complex issue," Johnson said. "His knowledge of the products, his understanding of the rules and regulations, and his patience and tact in dealing with the various players resulted in growers getting the herbicides they needed."
Larry Kleingartner, executive director of the National Sunflower Council, also commended Gray and NDDA in a letter to Johnson.
". . . Thanks to you and Jim for your excellent work on this very difficult subject," said Kleingartner. "My board of directors, especially those familiar with pesticide issues, opined that getting Authority® and Blanket® labels was a long shot at best, and probably not doable. Well, it is done and it is a very good feeling to know that farmers will be in compliance."
The Agricultural Worker Protection Standard (WPS) is a regulation that the U.S. Environmental Protection Agency issued in 1992 and amended in 1995. It covers pesticides that are used in the production of agricultural plants on farms, forests, nurseries and greenhouses. The WPS requires you to take steps to reduce the risk of pesticide-related illness and injury if you (1) use such pesticides, or (2) employ workers or pesticide handlers who are exposed to such pesticides.
This fact sheet will help you understand how to comply with WPS requirements concerning the information that commercial handlers must provide to their customers when a pesticide application does not take place as scheduled. People seeking clarification on this part of the regulation submitted these questions to the agency, and the EPA's Office of Compliance answered them.
The WPS requires commercial handlers (handler employers) to provide information to their customers — the farm, forest, nursery or greenhouse operators (agricultural employers) — about the pesticide before it is applied. [40 CFR section 170.224]. What provisions apply if the pesticide cannot be applied as scheduled?
The WPS requires the commercial handler to provide specific information to the grower about pesticide applications on the agricultural establishment before the application has taken place.
This is so growers can, in turn, provide appropriate protection to their workers and family. The agency is aware, however, that some commercial handlers occasionally may not be able to perform pesticide applications at a previously scheduled time.
The "How to Comply" manual provided some flexibility on this issue, noting that "if the pesticide is not applied as scheduled, the agricultural employer must be informed of the corrected time and date of the application. Make the correction before the application takes place, or as soon as practicable thereafter." Questions have arisen concerning the notification requirements if applications do not take place as scheduled, including when and how the employer must be notified of the change.
The WPS places certain requirements upon growers (agricultural employers). One of the most important requirements involves keeping workers out of treated areas during applications and while the restricted entry interval (REI) remains in effect. Growers also must provide workers with, among other things, information, protective equipment and decontamination supplies when they enter treated fields within 30 days of the expiration of the REI. The requirement for commercial handlers to notify growers before an application takes place must be viewed in light of its central purpose: to provide growers with information they may need to protect their workers.
The notification provision does not affect the obligation of growers to assure that workers remain out of treated areas during applications and while the REI remains in effect, and to assure that proper protections are provided when workers enter treated areas within 30 days of the expiration of the REI. The obligation of the grower continues whether or not notification of an application occurs. Growers should take whatever steps are necessary to assure that they are informed of an application before workers might enter treated areas.
Obviously, notification before application is the best way to assure that growers have the necessary information to protect the agricultural employees. For this reason, the WPS requires that notification take place before applications. Commercial handlers are liable under the WPS if they fail to provide such notification.
The EPA recognizes that an application sometimes does not take place when scheduled, and that communication between commercial handler and grower may be difficult to accomplish. The agency therefore is willing to allow some rescheduled applications to go forward without requiring prior notification. This flexibility is available only when:
• An application previously has been scheduled (including day, date and time) and agreed upon by the commercial handler and grower
• The prior notification that the WPS requires has been provided
• The pre-arranged application subsequently does not take place as scheduled
Commercial handlers and growers must keep in mind that growers still are liable if their employees enter fields during the REI, or within 30 days of expiration of the REI, if any applicable WPS requirements are not met. Notification must occur in one of two ways.
The grower can receive notification before workers could be exposed to pesticide residues resulting from the application in violation of the WPS. Otherwise, the commercial handler must notify the grower with a form of notification previously agreed upon by the commercial handler and grower, which was calculated reasonably to get information to the grower before workers could be exposed to residues in violation of the WPS.
EPA strongly recommends that commercial handlers and growers work out in advance between themselves:
• How notification of regularly scheduled applications should be accomplished
• Under what circumstances applications may take place without prior notification if previously scheduled applications do not occur on time
• How notification of rescheduled applications should be accomplished.
For more information on WPS,
go to the NDSU Pesticide Program Resource Web site at:
www.ag.ndsu.nodak.edu/aginfo/pesticid/WorkerProtection.htm
The EPA has published an interpretive statement outlining circumstances under which National Pollutant Discharge Elimination System (NPDES) permits are not required to apply pesticides to U.S. waters. The EPA also is proposing to codify the interpretive statement in regulation.
In recent years, courts have been faced with the question of whether the Clean Water Act requires an NPDES permit for pesticide applications (e.g., Headwaters Inc. v. Talent Irrigation District). As a result, public health authorities, natural resource managers and others who rely on pesticides have expressed to the EPA their concern and confusion about whether they have a legal obligation to obtain an NPDES permit (under the Clean Water Act) when pesticides are applied to or over U.S. waters.
They also were concerned about the impact such a requirement would have on their ability to accomplish their missions.
The interpretive statement and proposed rule are intended to address these concerns and clarify jurisdictional issues between the Clean Water Act and the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) pertaining to the application of pesticides.
The EPA solicited public comment on an interim statement and guidance in a Federal Register notice published on Aug. 13, 2003, and received more than 400 comments expressing a wide range of views.
The application of a pesticide to U.S. waters consistent with all relevant requirements under FIFRA does not constitute the discharge of a pollutant that requires an NPDES permit in the following two circumstances:
1. The application of pesticides directly to U.S. waters to control pests. Examples of such applications include applications to control mosquito larvae, aquatic weeds or other pests that are present in the U.S. waters.
2. The application of pesticides to control pests that are present over or near U.S. waters that results in a portion of the pesticides being deposited in U.S. waters. Examples include aerial applications of insecticides to a forest canopy where U.S. waters may be present below the canopy or applications of pesticides over or near water for control of adult mosquitoes or other pests.
Clarification of these issues is important because doubt over a requirement to obtain an NPDES permit could impede local officials' ability to quickly control pests, such as mosquitoes, that may carry communicable diseases, such as West Nile virus, or invasive species that may damage natural resources. The EPA believes that the existing regulatory requirements for pesticides under FIFRA adequately safeguard human health and the environment without imposing an undue burden on local governments and others that rely on pesticides.
Additional copies of the Federal Register notice that contains the interpretive statement and proposed rule are available on the EPA's Web site at www.epa.gov/npdes/agriculture .
Editors note: The following law is the only substantive change to the pesticide use provisions found in the North Dakota Century Code as a result of the 59th state Legislature. Its impact on resident certified applicators is negligible, but for nonresident applicators seeking reciprocity, it should dramatically speed the processing time because the secretary of state will no longer be in the loop.
AN ACT to amend and re-enact section 4-35-11 of the North Dakota Century Code relating to designation of the agent for service of process for a nonresident pesticide applicator or dealer; and to provide for application.
BE IT ENACTED BY THE LEGISLATIVE ASSEMBLY OF NORTH DAKOTA:
SECTION 1. AMENDMENT.
Section 4-35-11 of the North Dakota Century Code is amended and
re-enacted as follows:
4-35-11. Nonresident application - Designation of agent for
service of process. Any nonresident applying for certification as
an applicator or dealer under this chapter to operate in this
state shall file a written power of attorney designating the
North Dakota State University Extension Service or its
designee as the agent of such nonresident upon whom service of process
may be had in the event of any suit against said nonresident
person, and the power of attorney must be so prepared and in such form as
to render effective the jurisdiction of the courts of this state over
the nonresident applicant; provided, however, that any nonresident
who has a duly appointed resident agent upon whom process may
be served as provided by law is not required to designate the
secretary of state
Extension
Service as such agent. The secretary of
state
Extension Service is allowed
such fees therefore as provided by law for designating
resident agents. The nonresident must be furnished with a copy of
the designation of the secretary of
state
Extension Service or of a
resident agent. The copy will be duly certified by the
secretary of state
Extension Service.
Contact:
NDSU Pesticide Training and Certification Program
Box 5051, Fargo, ND 58105-5051
Tel: (701) 231-7180
Fax: (701) 231-5907
E-mail: pesticid@ndsuext.nodak.edu
Internet: www.ndsupesticide.org