The National Pest Management Association (NPMA) represents the professional pest management industry in the United States with more than 200 members based within the Commonwealth. Our industry's role in protecting public health, food safety and property start with our member companies, who manage and treat numerous pests, including mosquitoes, in countless commercial, residential and institutional settings in Virginia. NPMA supports the petition for rulemaking to amend 2 VAC 5-685 to create a new certification category for pest control measures of public health significance. 

Our industry relies on continual advancements in pest control products, technology, and methods to confront the growing threat of vector-borne diseases. More than 5,000 pest management professionals across Virginia are committed to continuing their education throughout their careers, through continuing education credits awarded by the Virginia Department of Agriculture and Consumer Services (VDACS) and earning advanced credentials, like the Certified Applicator License.  

Under current Virginia regulations, pest management professionals who provide mosquito control services are required to obtain the Category 8 - Public Health Pest Control license through examination. The Category 8 examination is a single, all-encompassing comprehensive test that encompasses content focused on both large-scale, wide area applications and targeted applications made by pest management professionals.

This single test approach tests individuals on application methods that fall outside of scope of their professional responsibilities and expertise, creating unnecessary hurdles to certification and career growth. The subsequent barrier of entry impacts otherwise qualified applicators, without providing a corresponding increase in competency, safety or environmental outcomes.

By establishing a new license certification category or subcategory for non-wide area applications, the Department can ensure examinations and continued training are properly tailored to the targeted applications that Virginia applicators make for the protection of public health. This action will expand opportunities for individuals to earn additional certifications, providing professional advancement and development within the professional pest management industry across Virginia.

Finally, this proposal is a concept that VDACS is prepared to implement, through the state’s Certification & Training Plan, approved by the U.S. Environmental Protection Agency (EPA)  in November 2023.[1] In this approved plan, VDACS outlined the creation of a new license subcategory 7F – Public Health for Commercial Applicators, which separates the targeted applications our members make from the broader wide-area applications under Category 8.

We respectfully urge the Board to approve the petition and move forward with rulemaking to establish a distinct certification category for non-area-wide mosquitoes and other pest control measures of public health significance.

Thank you for your consideration of the petition and for the Department’s continued commitment to ensuring opportunities for education and advancement are available in the state’s professional pesticide applicator community.

Sincerely, 

Megan Striegel 

Senior Director of Public Policy