Pest Control Adviser Licensing Requirements for Internal Pest Control Decisions by a Firm or Agency

The enclosed document is the Department of Pesticide Regulation’s (DPR’s) interpretation of the Food and Agricultural Code relative to the need for a Pest Control Adviser license by employees involved in internal discussions/decisions for pest control by the property owner-operator (i.e., grower, firm, or corporation).

It is DPR’s position that the “Operator of the Property” (i.e., growers, firms, or corporations) and their employees are not required to be licensed by DPR as pest control advisors when making decisions in regard to pesticides used for agricultural use on property under their control.

It is important to properly determine whom the operator of the property is when making a determination if licensing is required. Please refer to Title 3, California Code of Regulations section 6000 for the definition of “Operator of the Property.”

This supercedes all previous positions issued including Enforcement letters December 26, 1975, ENF 81-21, 81-43, 82-41, 83-27, 83-40, 89-47, and 89-119. It essentially returns DPR to the position recommended by the Pest Control Advisory Committee in 1983 that licensing is not required in this situation.

If you have any questions about the subject, please contact your Senior Pesticide Use Specialist Liaison.

Sincerely,