The Virginia Pest Management Association (VPMA), the largest association in Virginia representing pest control operators in the structural pest control industry, strongly supports the Petition for Rulemaking to amend 2 VAC 5-685 to create a new certification category for pest control measures of public health significance.

Creating a distinct category to separate the training and licensing requirements for area-wide pest control programs of public health significance from those for non-area-wide (backyard) pest control measures is essential to maintaining and improving the safe and effective use of pesticides across the Commonwealth.

Continual advancements in pest control products, technology, and methods are critical to helping Virginia’s pest control operators confront the growing threat of insect-borne diseases. Applicator technicians are expected to enhance their knowledge throughout their careers and ultimately obtain advanced credentials, including the Certified Applicator License.

However, many qualified technicians face a significant barrier: the current Category 8 – Public Health Pest Control examination includes content focused on area-wide control programs and aerial or large-scale application techniques—topics that are irrelevant to technicians who conduct only backyard or localized mosquito control. These individuals often lack experience with such large-scale operations, and the inclusion of these topics unnecessarily limits their ability to advance professionally.

Establishing a separate category or subcategory focused on non-area-wide pest control would ensure that training and examinations are directly relevant to the scope of work performed by backyard mosquito control applicators. This targeted approach would promote better understanding and safer pesticide use without diluting the standards for broader public health pest control programs.

The VPMA believes that this adjustment will strengthen Virginia’s pest management workforce by encouraging more technicians to pursue certification. Expanding access to relevant, role-specific training and licensure will enhance professional development and elevate the industry’s overall capacity to apply pesticides safely and effectively throughout the Commonwealth.

We respectfully urge the Board to approve the petition and move forward with rulemaking to establish a distinct certification category for non-area-wide mosquito and other pest control measures of public health significance.

Thank you for your consideration and for your continued commitment to ensuring pesticide safety and effectiveness in Virginia.

My name is Rhonda, and I am with Commonwealth Exterminators, a licensed pest control company in Virginia. We employ 11 certified pesticide applicators across the Commonwealth.

We fully support the VPMA Petition for Rulemaking to create a new certification category that separates area-wide public health pest control from non-area-wide (backyard) mosquito control.

This change will make certification requirements more relevant and achievable for commercial applicators, while maintaining high standards for safety and professionalism. Many technicians struggle to pass the current Category 8 exam because it includes questions unrelated to the work they perform. This adjustment would allow them to advance their careers and strengthen our industry’s capacity to protect public health.

Thank you for considering this important issue. We urge the Board to approve the petition.”

Good morning,
My name is Alex Sullivan, and I am with Accel Pest and Termite Control, a licensed pest control company in Virginia. We employ numerous certified pesticide applicators across the Commonwealth.

We fully support the VPMA Petition for Rulemaking to create a new certification category that separates area-wide public health pest control from non-area-wide (backyard) mosquito control.

This change will make certification requirements more relevant and achievable for commercial applicators, while maintaining high standards for safety and professionalism. Many technicians struggle to pass the current Category 8 exam because it includes questions unrelated to the work they perform. This adjustment would allow them to advance their careers and strengthen our industry’s capacity to protect public health.

Thank you for considering this important issue. We urge the Board to approve the petition.

Kindly, 
Alex S. 
Peninsula Area Manager
Accel Pest and Termite Control

It would be a good thing to split the category 8 into right of way and backyard as they are two very different things.  And it would help to get more people certified to help with supervision of seasonal work forces.

My name is Jill Cox, and I am the business manager with Mark's Pest Control, a licensed pest control company in Virginia. We employ 11 certified pesticide applicators across the Commonwealth.

We fully support the VPMA Petition for Rulemaking to create a new certification category that separates area-wide public health pest control from non-area-wide (backyard) mosquito control.

We feel that having the public health certification has prevented us from adding mosquito control to our services that our customers want.  We are asked often to add this service to private homes during the summer season, and we can not offer it do to the extra certification required.  We would not need the public health certification for any other reason than private mosquito control.

This change will make certification requirements more relevant and achievable for commercial applicators, while maintaining high standards for safety and professionalism. Many technicians struggle to pass the current Category 8 exam because it includes questions unrelated to the work they perform. This adjustment would allow them to advance their careers and strengthen our industry’s capacity to protect public health.

Thank you for considering this important issue. We urge the Board to approve the petition.

Sincerely,

Jill Cox, Business Manager

and licensed technician

Due to the demand for mosquito control around public housing to protect the health of Virginians it is important that we train and license individuals accordingly. The existing tests are based on commercial application methods and equipment that are not used in residential mosquito control resulting in a high failure rate. We need a separate form of testing that will result in properly trained technicians with the knowledge of the equipment that is being used to provide such services.  

My name is Ben Carter with PermaTreat Pest Control.  I have been in the industry for over 19 years now.  We employ over 75 employees that are licensed in the state.  

We fully support the VPMA petition for rulemaking to create a new certification that separates area-wide public health pest control from non-area-wide (backyard/ residential) mosquito control.  I know personally, it took me a few attempts to pass the exam, because if the broad questioning in areas we do not service.  

This type of change is good across the board for the industry in Virginia, allowing companies to focus training and education to what matters for their business.  

And hopefully this will allow more to become licensed and knowledge in the proper categories for the applications.  

Thank you for your consideration to this matter and look forward to your approval.  

We employ [20] certified pesticide applicators across the Commonwealth.

We fully support the VPMA Petition for Rulemaking to create a new certification category that separates area-wide public health pest control from non-area-wide (backyard) mosquito control.

Our number one priority is ensuring that our staff have the proper training for their specific job. The wide range of content on the current test makes it difficult for applicants to pass.  

This change will make certification requirements more relevant and achievable for commercial applicators, while maintaining high standards for safety and professionalism. Many technicians struggle to pass the current Category 8 exam because it includes questions unrelated to the work they perform. This adjustment would allow them to advance their careers and strengthen our industry’s capacity to protect public health.

Thank you for considering this important issue. We urge the Board to approve the petition.

To Whom it may concern,

As a certified applicator in Virginia for more than thirty-years, I am an advocate for engaging PCO's to push beyond being a registered technician, to hold certifications in all disciplines that pertain to their job.  Public Health has routinely been the most challenging for technicians, in part due to a sizeable amount of content on the exam that may not be relevant to their work.  

We at American Pest support VPMA's petition for rulemaking to create a two-tier Category 8, separating area-wide and non-area wide (mosquito control).  Our hope is to have trained, knowledgeable team members that want to advance their careers in part through proper licensing, including Category 8.

We appreciate the Boards consideration of this matter.

Respectfully,

Conrad Lyons, ACE

American Pest

 My name is Brandon Watz, I am the Region Service Manager for Orkin here in Virginia. 

I completely support the petition to tier the Public Health Cat 8 certification to area wide and non area wide specific training. This has long been an issue when attempting to certify technicians in the Cat 8 training as the scope of the exam is extensively broad, requiring questions that would mainly pertain to area wide treatments that are usually reserved for government and agricultural applications. We have also had multiple technicians that have had to take this exam numerous times to pass due to the extensive scope the exam purviews. 

This change would allow more technicians and companies to obtain this certification and help residents control their mosquito concerns more effectively.

 Thank you for considering this petition. 

I support the VPMA petition to create a separate and distinct Pesticide Applicator Category for non-area-wide (backyard) pest control measures. 

A large part of the Category-8 testing is unrelated to backyard pest control applications causing a disadvantage to our technicians attempting to attain certification.

It makes sense to reconsider this approach and have the training pointed towards the methods for localized treatments that are related to the scope of the work being performed. This will promote more understanding and safer pesticide use.

I respectfully urge the the Board to consider this petition.

As a pest control company, we want to make sure everyone is properly trained and licensed to properly and safely perform treatments. The way the current Category 8 certification is structured makes it unnecessarily difficult for companies and technicians who want to comply with the licensing. The exam focusses too much on area-wide treatments that are performed by government and agricultural applicators. I would encourage supporting the VPMA petition to have a separate exam with relevant questions for pest control technicians performing backyard and similar mosquito control treatments. This would help improve residential vector control and ensure that technicians know content relevant to their job duties. 

Thank you,

Brett Lieberman
My Pest Pros

As a pest control operator, I believe that a new certification category for Non-area-wide pest control is necessary.  The creation would result in better trained applicators and a safer environment for all.  

Sincerely,

Adam Brown

I fully support the VPMA Petition for Rulemaking to create a new certification category that separates area-wide public health pest control from non-area-wide (backyard) public health pest control.

The current category 8 exam includes some content that is not relevant to backyard mosquito control. Technicians sitting for the exam struggle to understand content like area-wide fogging and other non-relevant material as they will never be exposed to that in their daily work.

This change will make certification requirements more relevant and achievable for commercial applicators, while maintaining high standards for safety and professionalism. Many technicians struggle to pass the current Category 8 exam because it includes questions unrelated to the work they perform. This adjustment would allow them to advance their careers and strengthen our industry’s capacity to protect public health.

Thank you for your consideration. I strongly urge the Board to approve this petition.

I concur with the two (2) tiered public health license for Category 8.  This change will result in having more technicians educated and trained throughout the state, thereby contributing, protecting and preserving our pollinators. The residents of Virginia deserve highly educated and well trained technicians to do so and this two tiered update will do just that through the efforts of the Virginia Pest Management Association and the National Pest Management Association.

My name is Jordan DiGeronimo, licensed for pest control operating throughout the Commonwealth. We employ numerous certified pesticide applicators who are trained and licensed under Virginia’s current standards.

We fully support the VPMA Petition for Rulemaking to create a new certification category that separates area-wide public health pest control from non areawide (residential/backyard) mosquito control.

Currently, I oversee technician training, licensure, and field operations daily. One of our biggest challenges is helping qualified technicians advance into public health certification when much of the current Category 8 exam material focuses on aerial and large scale mosquito control programs. These topics are irrelevant to their work, which centers on small scale, residential mosquito management using ground-based equipment, integrated pest management practices, and homeowner education.

This disconnect often discourages skilled professionals from pursuing licensure, creating staffing bottlenecks and limiting our ability to respond to community demand for safe, regulated mosquito control services. A targeted, residential specific certification would not dilute safety standards, it would enhance them by ensuring every technician is trained and tested on practices that directly reflect their scope of work.

This change would strengthen our industry’s professionalism, support workforce development, and help Virginia maintain high compliance and safety standards while keeping pace with modern pest control needs.

Thank you for considering this important issue. I strongly urge the Board to approve the petition and move forward with the rulemaking process.

My name is Michael L. McCranner, and I am one of the owner's of Slug-A-Bug in Virginia.

We fully support the VPMA Petition for rule making to create a new certification category that seperates area wide public health pest control from non-area-wide (Backyard) public health control.

Thank you for considering this important issue. We urge the Board to approve the petition.

I am in support of this petition as there is a difference between an Area Wide Integrated Mosquito Management Program and a Backyard Integrated Mosquito Management program. I have established, trained and worked both of these programs in multiple states for over two decades with over 15 years as an Associate Certified Entomologist. The effectiveness of an Integrated Pest Management program and worker protection begins with the proper verified knowledge. In this case, it is more important as there needs to be a proper balance of the environment while protecting the public's health where people live.  

As both a licensed commercial applicator and an Associate Certified Entomologist actively engaged in training and supporting professionals across Virginia's pest management industry and beyond, I fully support the petitioner's request for the Board of Agriculture and Consumer Services to establish a new certification category or subcategory for public health pest control in non-public applications.

This proposed distinction is both timely and necessary. Commercial applicators who perform mosquito, tick, and other vector control services in residential and private settings operate under a different set of conditions, tools, and accountability measures than those conducting large-scale or publicly funded area-wide applications. Creating a separate certification path would allow for more focused education and examination that aligns with the specific risks, formulations, and integrated pest management (IPM) practices unique to private sector public health pest control.

Additionally, differentiating training and testing requirements would elevate professional standards across both sectors. Public agency applicators would continue to be evaluated on their responsibilities in surveillance, resistance management, and area-wide control, while applicators in the private sector could focus more deeply on customer education, source reduction on private property, and the responsible use of EPA-registered products.

By recognizing the specialized expertise required in both arenas, the Commonwealth would strengthen its commitment to protecting public health, the environment, and applicator professionalism. This clarification would also create clearer pathways for training providers and industry associations to deliver targeted, high-quality education that supports compliance and excellence within our growing field. 

I respectfully urge the Board to give this petition full consideration and to work collaboratively with industry representatives, public health officials, and training providers to define the most appropriate framework for implementation.

I am reaching out regarding a rule and regulation that I believe warrants attention in the Pest Management industry. This regulation, which was introduced and passed on January 1st, 2015, affects Pest Management Professionals. Specifically, it pertains to the qualifications required for commercial applicators, who hold the 7A license for general pest control, a certification higher than that of a Registered Technician. A commercial applicator's license allows them to train newly hired employees under direct supervision until they obtain their Registered Technician license. This provision has been beneficial to the industry, and overall, the law as it stands is supported by the Virginia Pest Management community.

However, there has been a significant change since 2015 that I believe has unintended consequences. The new regulation now requires commercial applicators to obtain a Public Health license (category 8), which specifically certifies them in mosquito and tick treatments. While I understand the intent behind this—ensuring greater expertise in response to the growing threat of vector-borne diseases such as West Nile Virus, Lyme disease, and others—I have concerns about its implementation.

The core issue is that, under the current rules and regulations, a technician with a 7A commercial applicator license is legally unable to perform mosquito and tick treatments unless they also hold the Public Health license. This creates two primary issues:

1. Impact on Workforce Efficiency: Technicians who hold the 7A license (which is a higher certification than the Registered Technician license) are now restricted from providing these services, which were previously covered under the 7A category. This reduces the pool of qualified employees available to perform mosquito and tick treatments, leading to delays in service and potentially lower-quality work, as these tasks are now handled by less experienced technicians.
2. Unintended Consequences: The law was designed to ensure better training in response to health concerns, but it has had the opposite effect. Many Registered Technicians are reluctant to pursue the Public Health license due to the added responsibility, and technicians who already hold a 7A license are struggling to pass the Public Health exam. This has led to operational inefficiencies and increased costs for businesses across the state.

As a member of the Virginia Pest Management Association Board, as well as the chair of the Professional Development Committee and a member of the Legal, Legislative & Regulatory Committee, I am deeply familiar with these challenges. I strongly recommend making a rule and regulation change to separate the category 8 public health exam into two separate categories, 1 for Government and municipal vector control and 1 for Pest control operators who practice residential Mosquito and Tick control.

My name is Marie Horner and I am the Vice President of Government Affairs for Arrow Exterminators, a pest control company located in Richmond, VA.  Our company operates in 11 other states and we have seen those states adopt a new tier of Category 8 Public Health certification which more accurately tests commercial applicators knowledge on pesticides, safety and equipment that are used for residential and commercial treatments.

We are in support of the creation of a new certification category in Virginia for those reasons and encourage the department to move forward with this petition.

Best Regards,

Marie Horner, ACE

The National Pest Management Association (NPMA) represents the professional pest management industry in the United States with more than 200 members based within the Commonwealth. Our industry's role in protecting public health, food safety and property start with our member companies, who manage and treat numerous pests, including mosquitoes, in countless commercial, residential and institutional settings in Virginia. NPMA supports the petition for rulemaking to amend 2 VAC 5-685 to create a new certification category for pest control measures of public health significance. 

Our industry relies on continual advancements in pest control products, technology, and methods to confront the growing threat of vector-borne diseases. More than 5,000 pest management professionals across Virginia are committed to continuing their education throughout their careers, through continuing education credits awarded by the Virginia Department of Agriculture and Consumer Services (VDACS) and earning advanced credentials, like the Certified Applicator License.  

Under current Virginia regulations, pest management professionals who provide mosquito control services are required to obtain the Category 8 - Public Health Pest Control license through examination. The Category 8 examination is a single, all-encompassing comprehensive test that encompasses content focused on both large-scale, wide area applications and targeted applications made by pest management professionals.

This single test approach tests individuals on application methods that fall outside of scope of their professional responsibilities and expertise, creating unnecessary hurdles to certification and career growth. The subsequent barrier of entry impacts otherwise qualified applicators, without providing a corresponding increase in competency, safety or environmental outcomes.

By establishing a new license certification category or subcategory for non-wide area applications, the Department can ensure examinations and continued training are properly tailored to the targeted applications that Virginia applicators make for the protection of public health. This action will expand opportunities for individuals to earn additional certifications, providing professional advancement and development within the professional pest management industry across Virginia.

Finally, this proposal is a concept that VDACS is prepared to implement, through the state’s Certification & Training Plan, approved by the U.S. Environmental Protection Agency (EPA)  in November 2023.[1] In this approved plan, VDACS outlined the creation of a new license subcategory 7F – Public Health for Commercial Applicators, which separates the targeted applications our members make from the broader wide-area applications under Category 8.

We respectfully urge the Board to approve the petition and move forward with rulemaking to establish a distinct certification category for non-area-wide mosquitoes and other pest control measures of public health significance.

Thank you for your consideration of the petition and for the Department’s continued commitment to ensuring opportunities for education and advancement are available in the state’s professional pesticide applicator community.

Sincerely, 

Megan Striegel 

Senior Director of Public Policy 

I am Ronald L Gaskill, President & General Manager of Oaklare Management Corporation d/b/a Mosquito Joe of the National Capital Region and South Richmond.  Oaklare is a licensed pest control business in Virginia since 2014. Oaklare employs two pest control professionals who are certified commercial applicators in categories 3B, 7A, & 8. It also employs 6-8 applicator technicians who are licensed Registered Technicians under Virginia law. I am one of the two aforementioned certified commercial applicators.

I strongly support the Board's acceptance of the Petition for Rulemaking, to create a new category or subcategory for non-area wide applications of pest control measures of public health significance. The single most important step that can be taken for the safe use of pesticides in the Commonwealth is the training and licensing of pest control applicators. For many pest control operators in the state, career advancement is contingent on attaining increasingly more advanced training and licensing in pest control procedures and practices. To be most safe by virtue of being most licensed, it is essential that training and exam requirements most closely fit the license category for which license applicants are examined.

Currently, the requirements for obtaining license certification in Category 8, Public Health, are not always consistent with the intended use of the Category 8 certification. Many applicants for Category 8 certification never intend to apply area-wide treatments such as those conducted by public agencies. Yet the Category 8 examination includes several questions about area-wide pesticide applications by public agencies, topics that many applicants have not reasonably studied because it is not their intent to undertake such pest control applications. They aren't prepared to answer the exam questions, too often causing them to not pass the examination and consequently not being awarded the Category 8  Public Health certification. This is not a reasonable basis for being denied the Category 8 Public Health certification when area-wide application is not the intended use of the Category 8 certification.

A safer approach for the Commonwealth is to establish a new category or subcategory of Public Health certification exclusively for non-area wide pest control measures, so that more applicants for certified commercial applicator licenses may become licensed in the safe use of pesticides and pest control measures of public health significance. Other states have done it successfully. The Commonwealth of Virginia should do likewise for the additional protection of Commonwealth resources from pesticide misuse.

Thank you for your consideration of these views. I look forward to the Board's support for the Petition so presented.

To Whom It May Concern,

I am John Reid, Vice-President of Accel Pest & Termite Control and the current President of the Virginia Pest Management Association (VPMA).

I am writing in full support of VPMA’s Petition for Rulemaking requesting that the Board of Agriculture and Consumer Services create a new certification category or subcategory for commercial applicators who perform non–area-wide (backyard) public health pest control, and adjust the related training and examination requirements to accurately reflect the work being performed.

There is a clear distinction between area-wide mosquito management programs and localized backyard treatments. The current Category 8 exam contains content focused on large-scale public health operations that does not apply to many technicians conducting residential mosquito control. This creates unnecessary barriers and discourages participation in certification.

Adopting this petition will not only promote safer and more effective pesticide use, but will also serve the best interests of the Board of Agriculture by encouraging greater compliance among businesses and expanding the number of properly trained pest management professionals. Many companies currently operate outside of full compliance, and some technicians forgo certification due to the impractical nature of much of the existing content. A category that aligns with real-world applications will bring more professionals into the system, benefiting both public health and environmental protection.

From personal experience, I’ve seen technicians lose motivation and often forgo further professional development due to the excessive difficulty and limited relevance of the current Category 8 content and test.

I respectfully urge the Board to approve this petition.

Sincerely,

John Reid

Vice President - Accel Pest & Termite Control

President - Virginia Pest Management Association

My name is Nathan Bullock, President of the Tidewater Pest Control Association and owner of Talent Pest Control in Virginia Beach.

I’m writing in support of VPMA’s petition to create a new certification category for non–area-wide public health pest control. Right now, the existing Category 8 exam focuses heavily on government-style, area-wide mosquito control programs. That doesn’t reflect the day-to-day work done by most private pest control professionals who perform localized treatments on residential and commercial properties.

Because the test content doesn’t match the work being done, many good technicians either struggle to pass or avoid certification altogether. A new, more relevant category would fix that—helping more people get properly trained, stay compliant, and operate safely.

Other states have already made this update successfully. It’s time for Virginia to do the same and bring the rules in line with how the industry actually operates today.

Thank you for your consideration.

Nathan Bullock
President – Tidewater Pest Control Association
Owner – Talent Pest Control

I absolutely believe there should be a different category for general pest control companies that are doing residential mosquito control.  This should not be under the same licensing as people that are doing aerial spraying and other things like that.