Illinois Fertilizer & Chemical Association
Supply · Service · Stewardship

Licensed Operators Must be Certified Applicators to Apply Dicamba to Soybean

For the past few weeks, IFCA has been working to determine how the new dicamba labels impact the commercial application industry in Illinois.  We finally have answers for you and instructions on what to do next.  It is not welcome news but there is a path forward and time is short to assure compliance for retailers who wish to provide custom dicamba application to soybean.  Here is what you need to know and do to apply dicamba in 2019:  
1.  Under federal law, only CERTIFIED APPLICATORS can apply dicamba to soybean in 2019.  The definition of "certified applicator" in Illinois and federal law is here.  The certified applicator requirement on the dicamba labels means that the person doing the application must be certified by the State of Illinois as a certified applicator.  Licensed operators are not certified applicators.  For the commercial industry, the only way to obtain a certified commercial applicator license to apply dicamba to soybean is to pass both the General Standards (GS) and Field Crop (FS) exams. 
2.  According to the IDA, if you are currently a licensed operator, and you pass the FC test, you can upgrade to a certified commercial applicator license by paying a fee of $60.  If you are not due to renew your GS this year, eventually you will need to "sync" your GS and FC testing years to get on the 3-year cycle.  You can do that by taking both the GS and FC exams this year at the clinics.  If you were not due to test in GS this year, but take FC and pass it and don't feel like taking GS the same day, so long as you take and pass the GS exam at some point in 2019 you can get back on the 3 year license cycle.  Note: If you are currently a licensed operator and pass the FC exam, you technically do not have to pay $60 to receive a certified applicator license; IDA will have a record that you passed the exam and they will consider you a "certified applicator."  However, it is a measure of professionalism to have the license itself and it also removes any uncertainty in the recordkeeping requirements or in any investigations; therefore IFCA recommends that you become a licensed certified commerical applicator if you pass the FC exam.  
3.  The University of Illinois Pesticide Safety & Education Program (PSEP) has added additional FC training and testing clinics to better handle the demand for training for the field crop certification.  There are currently six FC training and testing clinics on the calendar--the first is in less than two weeks on November 28 at the Wyndham CIty Centre in Springfield.  To view and register for the currently scheduled FC clinics go to and select "field crops" in the drop-down window.  We realize that six FC clinics are not enough to handle the demand for training and testing.  IFCA has been working with the PSEP team to identify more dates and locations and in addition to the six already scheduled.  Today they added three more FC clinics:  January 18 at Celebrations 150 in Utica, January 25 at John Logan College in Carterville, and February 11 at the Illinois Conference Center in Champaign.  Field Crop training is from 8:00 am to 11:30 am with testing to follow.  At these three newly added clinics, IDA will offer testing in both GS and FC.  We are working to also offer FC training at the IFCA Convention in Peoria on January 29 (stay tuned for details on that).  The newly added clinics should be on the PSEP website soon.  
4.  If you are only interested in taking the FC exam and NOT attending a study clinic, there is testing only (in all categories) available at many locations listed on the PSEP website.  Or you can take the test by appointment at IDA in Springfield by calling 217-785-2427. You can also test at the IDA office in Dekalb by calling 815-787-5476.   
5.  Dicamba specific training will also be required for all certified commercial and private applicators prior to applying dicamba in 2019.  This year IDA will accept proof of either registrant provided on-line training or registrant provided classroom training.  The registrants do not have their training materials ready at this point.  But you can visit the Illinois Dicamba Training Website for updates:  IFCA manages this website and we've posted the labels, helpful resources and frequently asked questions.  As more information becomes available we will keep this site current.  The registrants do plan to offer some classroom training, but with the early availability of on-line training this year, the number of classroom training events will be smaller than last year.  We will provide more information as soon as the registrants have a plan developed for training.  Indiana will NOT require you to attend a dicamba training class taught by Purdue this year to apply dicamba in Indiana.  
6.  Farmers who obtain a private applicator license are considered to be Certified Applicators in both state and federal law.  They do not have to pass any additional test such as field crops to apply dicamba on their own property, but whoever is spraying on the farm in a private application scenario MUST be a private applicator--there can also be no "supervision" by the private applicator as is also the case with the commercial applicators.  
7.  New Labels.  Please review the new labels and note the additional requirement for omnidirectional buffers if endangered species are indicated in your county.  IFCA followed the label instructions for application of either Engenia, FeXapan or Xtendimax applied in May 2019 and the map of areas in red where the 57 foot omnidirectional buffer is required affects quite a few counties.  Click here to see the map.  We assume more information on compliance with this new requirement will be offered in the training provided by the registrants.  
8.  Mixing and Loading of Dicamba Products for use on Soybean.  There is some uncertainty as to the level of training or certification that may be required of those who mix and load dicamba for application to soybean.  USEPA indicates on their website that certification is required for these individuals but there is nothing on the label.  We are working to clarify this provision.  
We understand the burden of this new requirement on our members.  We have expressed our concern to each of the registrants.  We want to thank the IL Dept of Ag and the UI for working with us to bring you answers and options for training and testing--they too had a lot of unanswered questions when the labels came out on Oct 31.  We looked at all avenues to determine if licensed operators could apply dicamba, but the consistent answer from USEPA was "negatory."  Illinois is not the only state that is impacted by this label requirement; there are other states who also have licensed operators working under the supervision of a certified commercial applicator.  
IDA will present on the details of the licensing requirements and dicamba investigations at the IFCA convention on January 29 during the morning general session, so please plan to attend to learn more about this process.  
Please feel free to call our office with questions.  We realize that not all of the questions are answered in this Alert but we wanted to make sure you did not miss the upcoming opportunities for Field Crop training and testing.  Good luck everyone and let us know if we can assist you.