Virginia Pest Management Association (VPMA) Comment on Notice of Intended Regulatory Action (NOIRA) 2 VAC 5-685 – Amend Commercial Applicator Certification Category for Public Health Pest Control

The Virginia Pest Management Association (VPMA) appreciates the Virginia Board of Agriculture and Consumer Services and the Virginia Department of Agriculture and Consumer Services (VDACS) for their consideration of, and support for, the Petition for Rulemaking approved by the Board in December 2025. VPMA strongly supports this Notice of Intended Regulatory Action and the Department’s efforts to move forward with this important regulatory initiative.

VPMA believes this rulemaking will provide greater clarity and consistency within Virginia’s commercial pesticide applicator certification program by establishing certification requirements that more closely reflect the type of public health pest control work being performed. The proposed separation of area-wide public health pest control from non-area-wide public health pest control recognizes the significant differences in application methods, equipment, training, and operational responsibilities associated with these activities.

By aligning certification standards more closely with actual job duties, this regulatory change will create a more meaningful and relevant certification pathway for structural pest management professionals whose work focuses on residential and other site-specific public health pest control applications. VPMA believes this will encourage more individuals to pursue certification, support workforce development, and increase the number of qualified applicators available to provide these important services throughout the Commonwealth.

VPMA appreciates that the Department has recognized the concerns raised by industry stakeholders and has undertaken this rulemaking process to address them. We believe the NOIRA appropriately identifies the need to maintain public health and safety while improving access to certification for qualified applicators.

As the regulatory process moves forward, VPMA looks forward to reviewing and providing feedback on the proposed regulatory language. We stand ready to work collaboratively with VDACS, the Office of Pesticide Services, and other stakeholders to help ensure that the final regulation achieves its intended objectives while maintaining Virginia’s high standards for pesticide applicator training, competency, and public protection.

Thank you for your continued leadership and commitment to a regulatory framework that supports both public health and the professional development of Virginia’s pest management workforce.

Respectfully submitted,

Virginia Pest Management Association