Request for additional information regarding the requirements for PMT and TPMT trainees
The Environment Protection Authority (EPA) welcomes the opportunity to work with AEPMA to ensure that the requirements for PMT/TPMT trainees and their supervisors are clear. We appreciate your feedback on information that we could add to our ‘training permit’ webpage here.
Trainees and supervisors can also call us on 131 555, email info@epa.nsw.gov.au or submit an online form here to clarify their regulatory obligations.
Documentation required for trainees to apply for a PMT training licence
To apply for a PMT Training licence, the applicant must demonstrate that they are enrolled in training to complete an approved course of training that includes the required units of competency. A letter on the employer's letterhead listing the required units is acceptable if the employer is also a registered training organisation. Alternatively, the applicant must provide an enrolment confirmation letter from the training facility or a tax invoice listing the units.
Occasionally, we have contacted employers directly; however, this is no longer the routine process we follow.
Request to introduce additional requirements for PMT trainees
The EPA supports a nationally implemented, competency-based qualification framework for obtaining pesticides licences. This system is harmonised and relies on the vocational education and training sector to assess PMT and TPMT trainees for competency and to only certify competent persons. Hence, opportunities for improvement are best progressed at the national level. We expect the Commonwealth Government to provide soon more details regarding the new industry clusters, which are due to commence on 1 January 2023. Once established, the relevant cluster should provide for AEPMA and state and territory regulators to progress a discourse on ways to better meet industry training needs for new entrants, including considering minimum durations for trainees.
We acknowledge that although trainees must keep a logbook of their training and pesticide use under section 14 of the Regulation, we prioritise assessment of these records on an as-needed basis rather than routinely as you have proposed.
PMT compliance campaigns
We are about to commence a proactive compliance campaign for PMTs within NSW. We will undertake inspections of a sample of the 4727 holders of NSW EPA PMT licences to determine if they are operating in accordance with the requirements of the Pesticides Act 1999 and Pesticides
Regulation 2017 (the Regulation). These inspections will include assessing compliance with PMT licences and training qualifications, checking pesticide application records, inspecting chemical storage areas and vehicles used to transport chemicals. This campaign will also focus on educating the PMT industry to encourage behavioural change and to provide information to help licensees to understand their legislative obligations. We will consider taking regulatory action if required. Note: these audits will begin in early December 2022.
Despite several attempts by AEPMA NSW to have qualifications prior to the introduction of the Competency Standards (1998) recognised for the purpose of obtaining a TPMT Licence, this was rejected by EPA NSW.
As suggested on previous AEPMA newsletters, if you or one of your employees achieved their Pest Management Qualification prior to the Competency Units system (before 1998, have the supportive paperwork) and have been continuously working in the industry, they should get in touch with EPA or see an RTO to obtain the required units of competency.
Request to reconsider TPMT qualifications
Thank you for AEPMA’s input in developing and endorsing the nationally agreed policy and minimum competency-based qualifications for holding a TPMT licence.
This policy is crucial for assuring that TPMT licence holders are suitably qualified and competent to apply pesticides in and around people’s homes, workplaces and other potentially sensitive settings.
These competency-based qualifications are also critical, noting TPMT licence holders may use restricted chemical products such as pre-construction bifenthrin or chlorpyrifos.
Like other state and territory licensing authorities, the EPA continues to accept a suite of earlier versions of Units 8 and 10 (published here) for existing licence holders as there are clear grounds for approving these as equivalent qualifications for the purposes of clause 7(A)(b) of the Regulation. This approval acknowledges industry experience, that these units have been endorsed as equivalent through successive formal reviews, and that both content and equivalence of unit versions is publicly documented on the national register of vocational education and training. It also assists the EPA to be satisfied those licences are held by technically competent persons as required by section 5B(1)(d) of the NSW Pesticides Act 1999.
The qualifications indicated in your letter issued before the introduction of the competency standards in 1998 testified to the achievement of agreed course requirements rather than an assessment of individual competency. We are not aware of any objective documentation that provides a basis for these courses to be generally considered equivalent to Units 8 and 10, so the EPA cannot issue a licence based on those qualifications. I acknowledge that some AEPMA members who do not hold the nationally agreed and industry-endorsed requirements for TPMT qualifications may be dissatisfied with updating their training to obtain a TPMT licence. We hope that AEPMA will support their impacted members to update their training. We note that some RTOs have adapted the delivery of their training product to accommodate existing licensees including online and self-paced learning.
Request to conduct an education program on the introduction of TPMT licences
You may recall that the EPA did mail-outs to all PMT licence holders in late 2021 and mid-2022 to ensure people were mindful of the introduction of TPMT licences into NSW. We have also progressively updated the EPA licensing webpage in light of questions being directed to us. We welcome AEPMA support for improving reach into the PMT community and delivering accessible educational materials.
If you have any queries on the above, you can call EPA NSW on 131555 or email:info@epa.nsw.gov.au
Back to eNewsletter