VDACS has a curious policy of sending recertification notices ONLY to the employee.   The letter to remind them is addressed to the employee but sent to the employer's address, which by law the employer cannot open.  If the employee fails to maintain their certification and continues to spray,  VDACS penalizes the employer!   Debbie Brown said at least twice in her last presentation that I heard it is the EMPLOYEE's responsibility to maintain his/her certification.   Never did she say - 'but if you don't,  we'll fine the employer'.  

• Send notices to both the employee and employer - how is the employer to know otherwise?
• Fine/penalize the person who fails to maintain their cert,  not the employer

We all want the same thing - certified applicators doing the work safely and professionally.  VDACs could help the employer accomplish this by including them in the correspondence.