RISE is a national not-for-profit trade association representing over 220 producers and suppliers of specialty pesticide and fertilizer products to both the professional and consumer (do-it-yourself) markets.  Established in 1991, RISE serves as a resource   and provides current and accurate information on issues and research affecting the specialty pesticide and fertilizer industries.  RISE member companies manufacture over 90 percent of domestically produced conventional specialty pesticides utilized in the United States, including consumer lawn and garden, professional pest control, golf course and other professional turf and lawn care, greenhouse and nursery, Aquatic Vegetation, and mosquito control products.

COMMENT RE: "E. Persons with a history of repeat violations---." We would suggest using 'convictions  for violations',  'findings against', or the most appropriate legal terminology that make it absolutely clear that the intent is to deny certification for actual violations only, and not allegations. Due to the public and highly visible nature of many specialty applications, it is not uncommon for concerned, but uninformed, citizens to lodge complaints which are discounted on investigation. 

It is our belief that those who intentionally and/or repeatedly misuse our industry's products should face the full penalties prescribed by law and regulation, it is also our belief that legislation and regulation must be sufficiently clear (precise) that no-one be penalized for unproven allegations.

I thank you for the opportunity to offer my comment both as a representative of RISE, and as a citizen of the Commonwealth of Virginia (Leesburg.)

Respectfully,

Frank A. Gasperini

Director of State Issues, RISE