The Virginia Pest Management Association submits this additional comment on proposed changes to 2 VAC 5-685-20.

As stated in previous comments submitted, VPMA does support the elimination of the 10 day waiting period to retake a failed certification exam because it removes obstacles to getting technicians certified.  We do not support, however, the proposed change in this section that requires an applicant who fails the exam to pay the full applicator certification fee to retake the exam.

It is not uncommon to encounter individuals who struggle with test taking.  The ability to retake the exam without an additional fee certainly has a benefit for the companies who hire such individuals.  It is recognized that there are costs to OPS in re-processing the paperwork, but certainly these do not justify the imposition of the full application fee a second time.

This additional cost seems punitive to pest management businesses in Virginia, especially in light of the fact that the Pesticide Control Fund – which these fees pay into - carries a substantial balance each year.  A balance that has been raided to augment the state’s general fund on several occasions in the past.

Respectfully submitted,

Andrea Coron

VPMA Executive Director

PO Box 7161

Fredericksburg, VA 22404

vpma@cox.net

540/374-9200