← 7A Cheat Sheets
⚡ CHEAT SHEET

Ch.1: Legalities of General Pest Management

What the exam tests on FIFRA, NREPA, Reg 636, Reg 637 sub-rules, school applications, applicator notification, and PPE requirements.

🎯 Top 5 Traps

1
Reg 637 Rule 11 sign posting = AT LEAST 48 HOURS — not 24. Required for COMMERCIAL buildings, HEALTH CARE facilities, licensed DAY-CARE centers, and SCHOOLS after insecticide application. Sign goes at the primary point of entry; cloud-encompassing-house illustration required (available from MPCA).
2
Reg 637 Rule 15 school reentry = AT LEAST 4 HOURS, OR LONGER if the product label specifies — the correct answer requires BOTH conditions. "4 hours" alone is incomplete; "depends on the label" alone is incomplete. The applicator must notify the school's building manager of the time period for reentry. School district administrator must notify parents BEFORE application (except emergencies, then after).
3
Record retention: 1 YEAR minimum for general-use, 3 YEARS minimum for restricted-use (Reg 636). Six required fields on every record: pesticide name + concentration, amount applied, target pest/purpose, date, address/location, method/rate. Easy to flip the years.
4
Spill kit required for ALL mixing/loading EXCEPT single containers under 16 OUNCES of use-dilution pesticide. Reg 637 Rule 4. Easy to forget the exception. "Use-dilution" means ready-to-apply concentration — not concentrate or RTU products.
5
Endangered species protection IS Category 7A's concern — even when applying inside or around buildings. The MDNR Land and Water Management Division administers the MI Endangered Species Act (Act 451, Part 365) and maintains state + federal lists. Applicators must take initiative to consult.

🔢 Numbers You Must Know

Number
What It Represents
48 hours
Minimum sign posting period (Reg 637 Rule 11) at commercial / health care / day-care / school sites after insecticide application
4 hours
Minimum reentry period for school rooms after insecticide application (Reg 637 Rule 15) — OR longer if product label specifies
1 year / 3 years
Record retention: 1 year minimum for general-use pesticides; 3 years minimum for restricted-use pesticides (Reg 636)
6 required fields
Pesticide application records must contain: name + concentration, amount applied, target pest/purpose, date, address/location, method/rate when applicable
16 ounces
Spill kit exception threshold (Reg 637 Rule 4) — single containers of use-dilution pesticide under 16 oz are exempt from spill kit requirement
12 months
Maximum service contract duration (Reg 637 Rule 12) without annual continuation notification or signed long-term contract
10 workers
OSHA threshold — businesses with 10 or more workers are subject to OSHA record-keeping for work-related deaths/injuries/illnesses
7 IPM elements
Required IPM training elements (Reg 637 Rule 14): site evaluation, threshold concept, pest biology/management relationship, pest reduction + prevention, IPM development/implementation, evaluation, record-keeping
2 subclasses
Commercial applicator subclasses under NREPA: Subclass A (RUP users for non-agricultural purpose); Subclass B (anyone applying non-RTU pesticides in employment OR for hire)

🔀 Easily Confused

Pair / Group
Distinguishing Feature
FIFRA vs NREPA Act 451 Part 83 vs Reg 636 vs Reg 637
FIFRA: federal — registers pesticides, classifies GUP/RUP, misuse penalties. NREPA Act 451 Part 83: state — gives MDA authority to certify applicators. Reg 636: state — types of applicators + record-keeping. Reg 637: state — pesticide USE (the operational rules — 7A's main reference).
General-use vs Restricted-use pesticides
General-use (GUP): purchasable without restriction; 1-year record retention. Restricted-use (RUP): only by/under direct supervision of a certified applicator; 3-year record retention.
Subclass A vs Subclass B applicators
Subclass A: anyone (incl. homeowners) who uses or supervises RUPs for non-agricultural purpose. Subclass B: anyone applying non-RTU pesticides in employment OR for hire.
Ready-to-use vs Use-dilution vs Concentrate
Ready-to-use (RTU): aerosols, pump sprays, strips, baits — applied from manufacturer's container, no mixing. Use-dilution: ready-to-apply concentration (the <16 oz spill-kit exception applies here). Concentrate: requires mixing/loading; full spill kit required.
Rule 11 (48-hr) vs residential lawn marker (24-hr)
Reg 637 Rule 11: 48-hour sign at commercial/health care/day-care/school after insecticide application. Lawn markers (turf/ornamental, residential): 24-hour customer-recommended retention. Different rules, different time periods.
Service Agreement vs Per-Application Info vs Risk/Benefit Info (Rule 12)
Service Agreement (oral or written): customer consent, company info, schedule. Per-application written info: company, applicator name, target pest, pesticide list with active ingredient common name, time/date, label warnings. Risk/Benefit info: required at INITIAL application only — definition of pesticide, how it works, why used, toxicity, precautions, environmental fate, physician consultation instructions.
MDA vs MDNR vs MDEQ vs EPA
MDA (now MDARD): registers/certifies applicators, enforces FIFRA in MI under cooperative agreement. MDNR Land and Water Mgmt Div: administers MI Endangered Species Act, maintains lists. MDEQ: water quality jurisdiction. EPA: federal pesticide registration; ESA.

🏛️ Pesticide Law Hierarchy & Authority

Law / Regulation
Level / Agency
What It Covers
FIFRA
Federal — EPA
Registers all pesticides; classifies as general-use or restricted-use; misuse penalties. MDA enforces some provisions in MI under cooperative agreement.
OSHA
Federal — US DOL
Record-keeping and reporting of work-related deaths, injuries, and illnesses for businesses with 10 or more workers.
Endangered Species Act
Federal — EPA
Pesticide labels must limit use in areas where endangered/threatened species could be harmed. 7A applicators must consider this even indoors.
MI Endangered Species Act (Act 451, Part 365)
State — MDNR Land & Water Mgmt
Maintains state and federal endangered/threatened species lists. Applicators must take initiative to consult.
NREPA Act 451, Part 83 (Pesticide Control)
State — MDA
Gives MDA director authority to register/certify private and commercial applicators and prescribe certification standards.
Regulation 636
State — MDA
Establishes types of certified applicators; record-keeping (1 yr GUP minimum / 3 yr RUP minimum); 6 required record fields.
Regulation 637 (Pesticide Use)
State — MDA
Primary 7A regulation. Use compliance, drift, PPE, notification/posting, applicator service agreements, IPM training, school applications, and more.
MIOSHA Right-to-Know
State
Employers must obtain and retain MSDS for all hazardous chemicals (including pesticides) for employee review; develop written training program; label all hazardous material containers.

📜 Regulation 637 Rule Quick Index

Rule
Topic
Rules 1 - 3
Definitions and terms used throughout the regulation
Rule 4
Pesticide use compliance — label-consistent application; off-target prevention; equipment in sound mechanical condition + properly calibrated; antisiphoning device when drawing water; spill kit access (under-16-oz use-dilution exception)
Rule 9
Personal Protective Equipment — long pants, protective footwear, long sleeves (short OK if wash water/waterless soap immediately available), impervious gloves when hands likely to contact pesticide
Rule 10
Pesticide drift outdoors AND indoor air circulation/ventilation considerations; written drift management plan with informed consent of affected residents when drift is anticipated
Rule 11 (Part 4)
Notification and posting — sign at primary point of entry of commercial / health care / day-care / school after insecticide application; posted minimum 48 hours; cloud-encompassing-house illustration (available from MPCA)
Rule 12
Applicator service agreements — oral or written; per-application written info; risk/benefit info at initial application; 12-month max contract without renewal; provide labels/MSDS/EPA fact sheets/AI rate document on request
Rule 13
Prohibits misrepresentation of pesticide safety — no claims of federal/state endorsement, "absolutely safe," "all natural ingredients," "least toxic chemicals known," or "pollution approved"
Rule 14
IPM training requirement for commercial applicators serving schools, health care facilities, public buildings — 7 required IPM training elements
Rule 15
Pesticide applications in/around schools — insecticide cannot be applied in school rooms unless room unoccupied for at least 4 hours (or longer per label); applicator notifies building manager; district notifies parents before application (except emergencies)
Rule 16
Certified Organic Farm Registry
Rule 17
Penalties for violation of local pesticide ordinances

💡 Memory Hooks

Posting and reentry: "48 for the sign, 4 for the school." Rule 11 sign posting = 48 hours minimum at commercial sites; Rule 15 school reentry = 4 hours minimum (or longer per label).
Records: "1 for general, 3 for restricted." Same rule across categories — one of the most-tested specs on the MI exam.
Spill kit: "Always required, except under 16 ounces of use-dilution." The single specific exception under Rule 4.
Law hierarchy: "FIFRA federal, NREPA state, Reg 637 = use." Three layers govern what you do every day.
Misrepresentation prohibited: "Never call it safe, endorsed, natural, or pollution-approved." Five forbidden claims under Rule 13.
All 7A chapters Ch.2 →