I am Ronald L Gaskill, President & General Manager of Oaklare Management Corporation d/b/a Mosquito Joe of the National Capital Region and South Richmond.  Oaklare is a licensed pest control business in Virginia since 2014. Oaklare employs two pest control professionals who are certified commercial applicators in categories 3B, 7A, & 8. It also employs 6-8 applicator technicians who are licensed Registered Technicians under Virginia law. I am one of the two aforementioned certified commercial applicators.

I strongly support the Board's acceptance of the Petition for Rulemaking, to create a new category or subcategory for non-area wide applications of pest control measures of public health significance. The single most important step that can be taken for the safe use of pesticides in the Commonwealth is the training and licensing of pest control applicators. For many pest control operators in the state, career advancement is contingent on attaining increasingly more advanced training and licensing in pest control procedures and practices. To be most safe by virtue of being most licensed, it is essential that training and exam requirements most closely fit the license category for which license applicants are examined.

Currently, the requirements for obtaining license certification in Category 8, Public Health, are not always consistent with the intended use of the Category 8 certification. Many applicants for Category 8 certification never intend to apply area-wide treatments such as those conducted by public agencies. Yet the Category 8 examination includes several questions about area-wide pesticide applications by public agencies, topics that many applicants have not reasonably studied because it is not their intent to undertake such pest control applications. They aren't prepared to answer the exam questions, too often causing them to not pass the examination and consequently not being awarded the Category 8  Public Health certification. This is not a reasonable basis for being denied the Category 8 Public Health certification when area-wide application is not the intended use of the Category 8 certification.

A safer approach for the Commonwealth is to establish a new category or subcategory of Public Health certification exclusively for non-area wide pest control measures, so that more applicants for certified commercial applicator licenses may become licensed in the safe use of pesticides and pest control measures of public health significance. Other states have done it successfully. The Commonwealth of Virginia should do likewise for the additional protection of Commonwealth resources from pesticide misuse.

Thank you for your consideration of these views. I look forward to the Board's support for the Petition so presented.