Know The Law

 

Why I’m Not Renewing My Qualified Applicators License

Like many of you, I just received a renewal application for my Qualified Applicators License from the Department of Pesticide Regulation.  I have maintained this license many years by paying the license fees, county registration fees, and continuing education course registration fees.  Add to these fees the travel costs and costs of my time when I could have been doing something more productive, then the cost of maintaining my QAL has added up to quite a pile of money. I used to think it was money well spent, but now I’ve changed my mind, and here’s why.

I trap and remove nongame and furbearing  mammals from properties under the authority of my Fish and Game Trapping License. Three of my company’s employees do the same. My QAL did not authorize me to perform animal trapping in, on, under or next to residential or commercial structures . The trapping of rats, mice, gophers, moles and voles in agricultural and residential settings no longer requires a DFG trapping license.

My company (Urban Wildlife Management) performs vertebrate pest control work without the use of pesticides, so although the QAL permits me to apply restricted use pesticides, I would jeopardize the structural pest control Branch 2 license exemption provided by a permanent federal court injunction if I started using avicides and rodenticides. If the time ever comes when an ADC job absolutely requires the application of a pesticide, I will simply sub-contract that portion of the job to a licensed PCO.

Can I perform pigeon control work on structures using my QAL? Absolutely not!  The CNWCOA has asked the DPR for this authority and has been repeatedly turned down.  The deal the structural PCOs seem to have made with the agricultural PCOs is apparently this - you guys stay out of our structures, we’ll stay out of your fields, and we’ll all get along just fine.

When engaged in the live capture or removal of pest birds and mammals or bees and wasps without the use of pesticides, WCOs like me are exempted from the agricultural and structural pest control licensing requirements by Food And Agriculture Code Section 11531(e) and the Business And Professions Code Section 8555(g) respectively.  Neither the individual QAL or Branch 2 licenses nor the company pest control business licenses is now required.

Construction work on structures to rodent-proof homes or prevent birds and other mammals from getting in or to repair animal related damage caused by nuisance wildlife is authorized by either a Branch 2 structural license or an Animal Damage and Bird Control license issued by the Contractors State License Board.

 Without the QAL license renewal requirement won’t I be missing out on important continuing education opportunities? Not in the least!  The Department of Pesticide Regulation requires the completion of 20 CEUs on a bi-annual basis. Four of those units must be in “Laws” and the remaining sixteen in the “Other” category. In general, the courses sponsored by PAPA and the pesticide manufacturers and distributors are irrelevent to developing non-pesticide wildlife control competence needed by WCOs. The most valuable annual wildlife control conferences put on by the national, regional and state organizations have not been approved by DPR for  CEU credits.
 


Alan Merrifield,
President CNWCOA

 Last year I requested CEU credits for attending a Nuisance Bird and Wildlife Conference in St. Louis sponsored by the National Pest Management Association. The two day conference could not have been more relevant to the work I perform, and it would have satisfied the CEUs required to renew my QAL, but the DPR rejected my application so I didn’t attend.  In the future, instead of taking training classes simply to satisfy my QAL renewal requirements, I will decide for myself which training opportunities best meet my professional needs and I’ll attend those courses without any thought of CEU credit requirements.