These comments are submitted by the Virginia Pest Management Association (VPMA).  VPMA, in operation since 1948, is the trade association for pest management companies in Virginia.  VPMA represents 225 pest management companies in Virginia. The mission of VPMA is to safely protect the health and property of the Commonwealth’s general public by promoting ethical and environmentally responsible business and pest management practices among our members through education, coalition and professionalism.

For several reasons, the VPMA urges the Board of Agriculture and Consumer Services to deny the Coake petition for rulemaking. The petition is unclear, and consequently very broad.  It does not allow for emergency exemptions. It would have an adverse economic impact on pest management companies in Virginia. And finally, it would undermine important mosquito abatement and invasive insect species work.

The pending petition is unclear and unnecessary.  It has far too broad in scope to be practical. There is no clarity of whether the application of “any pesticide or herbicide” pertains to both interior and exterior treatments. Moreover, the petition appears to cover all formulations of active ingredient including baits and gels, which pose no risk of exposure. Further, because antimicrobials are considered pesticides, would the nighttime cleaning crew have to get permission and post notification before cleaning the windows or toilets of an office building?

The petition does not allow for any emergency exemptions to the regulation in the case of threat to human health or safety.  This oversight could cause harm in the case of stinging or biting insects or venomous spiders.

Applications of pesticides and herbicides to commercial and multifamily properties would be extremely difficult, as the Pest Management Professionals are not dealing with the property owner, but rather a property manager or resident.  Extra time and manpower would be needed to obtain the written permission of the property owner and provide the suggested notification, as well as keep records of these activities. This would drive the cost of performing structural pest control up, causing an adverse economic impact on the more than 600 pest management firms in Virginia.

This petition would also undermine the very important work that is done in mosquito abatement programs to protect the health and welfare of Virginia’s citizens.  It would also weaken the work that is done to control invasive species in Virginia, such as the Red Imported Fire Ant and the Brown Marmorated Stink Bug, that can have both an economic impact and a negative health impact on the citizens of the Commonwealth.