Only Certified Applicators Can Mix and Load Dicamba

Recently, ARA provided this update from DC: 
Late last fall ARA became aware of a possible requirement that not only applicators, but also those involved in mixing and loading those applications, would need to be certified applicators for over-the-top dicamba formulations. 

Certification requirements were expanded with the renewal of labels so that working under the supervision of a certified applicator would no longer be considered adequate; the actual applicator had to be certified.  A question arose from some EPA guidance that appeared to require those who mix and load those products to also be certified.
After an ARA call in November with EPA that gave a tentative “yes” to that question, the State Federal Issues Research and Evaluation Group (SFIREG) run cooperatively by the Association of American Pesticide Control Officials (AAPCO) and EPA started work to clarify an answer.  Though slowed down by the government shutdown in January, the guidance document from SFIREG was published on March 21, 2019. It confirms the need for mixing and loading employees to be certified applicators.
The actual text from Page 2 of the guidance document reads as follows:
2. Do mixers, loaders, handlers, and spray equipment cleaners need to be certified applicators in 2019?
Yes, anyone who is responsible for any part of the use and application process, which includes mixing, loading, application, or cleaning dicamba application equipment, must become a certified and licensed private applicator or a commercial applicator. Workers are not required to be certified and licensed if they are involved in nothing more than transportation of unopened dicamba containers, transportation of “hot loads” that were mixed by a certified and licensed applicator, or unloading of a pre-mixed “hot load” directly from the transportation vehicle into a spray rig. Details on becoming certified and licensed are available at your state pesticide regulatory agency’s website.

Many other questions about dicamba certifications are included in the guidance document, which is available here.