I am reaching out regarding a rule and regulation that I believe warrants attention in the Pest Management industry. This regulation, which was introduced and passed on January 1st, 2015, affects Pest Management Professionals. Specifically, it pertains to the qualifications required for commercial applicators, who hold the 7A license for general pest control, a certification higher than that of a Registered Technician. A commercial applicator's license allows them to train newly hired employees under direct supervision until they obtain their Registered Technician license. This provision has been beneficial to the industry, and overall, the law as it stands is supported by the Virginia Pest Management community.

However, there has been a significant change since 2015 that I believe has unintended consequences. The new regulation now requires commercial applicators to obtain a Public Health license (category 8), which specifically certifies them in mosquito and tick treatments. While I understand the intent behind this—ensuring greater expertise in response to the growing threat of vector-borne diseases such as West Nile Virus, Lyme disease, and others—I have concerns about its implementation.

The core issue is that, under the current rules and regulations, a technician with a 7A commercial applicator license is legally unable to perform mosquito and tick treatments unless they also hold the Public Health license. This creates two primary issues:

1. Impact on Workforce Efficiency: Technicians who hold the 7A license (which is a higher certification than the Registered Technician license) are now restricted from providing these services, which were previously covered under the 7A category. This reduces the pool of qualified employees available to perform mosquito and tick treatments, leading to delays in service and potentially lower-quality work, as these tasks are now handled by less experienced technicians.
2. Unintended Consequences: The law was designed to ensure better training in response to health concerns, but it has had the opposite effect. Many Registered Technicians are reluctant to pursue the Public Health license due to the added responsibility, and technicians who already hold a 7A license are struggling to pass the Public Health exam. This has led to operational inefficiencies and increased costs for businesses across the state.

As a member of the Virginia Pest Management Association Board, as well as the chair of the Professional Development Committee and a member of the Legal, Legislative & Regulatory Committee, I am deeply familiar with these challenges. I strongly recommend making a rule and regulation change to separate the category 8 public health exam into two separate categories, 1 for Government and municipal vector control and 1 for Pest control operators who practice residential Mosquito and Tick control.