In response to the proposed regulation change in 2VAC5-685-50 , VACPA, Virginia Crop Production Association, is opposed to this regulation change that Registered Technicians cannot make any pesticide application during the 30 day period following failing the Registered Technician exam.  This change in the regulation would put undue hardship on our Agricultural Commercial businesses and Commercial Applicators that rely on Registered technicians to make pesticide applications during our seasonal business.  We are opposed to this specific change in the 2 VAC5-685-50 regulation.

2 VAC -5-685-20 VACPA supports the proposed change that eliminates the 10 day waiting period to retake a failed certification exam.  By reducing the obstacles for getting technicians properly certified and licensed in Virginia, an employer can get an employee certified in a more timely manner.