As both a licensed commercial applicator and an Associate Certified Entomologist actively engaged in training and supporting professionals across Virginia's pest management industry and beyond, I fully support the petitioner's request for the Board of Agriculture and Consumer Services to establish a new certification category or subcategory for public health pest control in non-public applications.

This proposed distinction is both timely and necessary. Commercial applicators who perform mosquito, tick, and other vector control services in residential and private settings operate under a different set of conditions, tools, and accountability measures than those conducting large-scale or publicly funded area-wide applications. Creating a separate certification path would allow for more focused education and examination that aligns with the specific risks, formulations, and integrated pest management (IPM) practices unique to private sector public health pest control.

Additionally, differentiating training and testing requirements would elevate professional standards across both sectors. Public agency applicators would continue to be evaluated on their responsibilities in surveillance, resistance management, and area-wide control, while applicators in the private sector could focus more deeply on customer education, source reduction on private property, and the responsible use of EPA-registered products.

By recognizing the specialized expertise required in both arenas, the Commonwealth would strengthen its commitment to protecting public health, the environment, and applicator professionalism. This clarification would also create clearer pathways for training providers and industry associations to deliver targeted, high-quality education that supports compliance and excellence within our growing field. 

I respectfully urge the Board to give this petition full consideration and to work collaboratively with industry representatives, public health officials, and training providers to define the most appropriate framework for implementation.