16.3 Categories 32–40 (Regulatory, Demo, Aerial, 35, Wood, Antimicrobial, Fumigation, Antifoulant, WPS)

Key Takeaways

  • Category 32 Regulatory is for government employees controlling regulated pests; competency covers quarantine law, regulated pests, eradication-program environmental impact, spread and population dynamics, and geographic variation in emergencies.
  • Categories 33 (Demonstration and Research) and 34 (Aerial) are add-ons that require a prior primary category; 33 needs a primary from Rule 40-21-2 (a)–(j), and GDA lists 34 as FAA Part 107 and/or Part 137 plus a primary from 21–32, 38, or 41.
  • Rule 40-21-3-.01(b)(12) aerial competency tests dispersal equipment, flight safety (patterns, swath marking, turnaround, obstructions), and protection of the pilot, flaggers, and loading personnel, and still cites 14 CFR Part 137.
  • Category 35 is GDA industrial, institutional, structural, and health-related RUP work in food handling, schools, hospitals, warehouses, and stored products — it is not SPCC HPC/WDO/FUM; competency includes continuous exposure to children, pregnant women, and the elderly.
  • Categories 36–40 cover pressure-treating lumber with RUP preservatives, antimicrobials (disinfectants/sanitizers/algaecides), agricultural commodity fumigation, restricted-use antifoulant paints on vessels, and the WPS trainer subcategory (0 recert hours). Recert hours (Chapter 3) are 6 for 32 and 35–39 and 0 for 33, 34, and 40.
Last updated: August 2026

16.3 Categories 32–40 (Regulatory, Demo, Aerial, 35, Wood, Antimicrobial, Fumigation, Antifoulant, WPS)

Quick Answer: 32 Regulatory is government quarantine and eradication. 33 Demonstration and Research and 34 Aerial are add-ons that need a prior primary category. GDA lists aerial as FAA Part 107 and/or Part 137 plus a primary from 21–32, 38, or 41; Rule 40-21-3 still requires 14 CFR Part 137 proof and tests dispersal equipment, flight safety, and flagger/loader protection. 35 is GDA industrial/institutional/structural/health-related work in food handling, schools, hospitals, warehouses, and stored productsnot SPCC HPC/WDO/FUM. 36 is pressure treating lumber with RUP preservatives. 37 is disinfectants, sanitizers, and algaecides. 38 is agricultural commodity fumigation. 39 is antifoulant paints on vessels. 40 is the WPS trainer subcategory with 0 recert hours. Recert (Chapter 3): 6 hours for 32 and 35–39; 0 for 33, 34, and 40.

Add-ons do not replace a major category. GDA still requires 70% on General Standards and at least one major category. 33, 34, and 40 are not a shortcut around Plant, Turf, Mosquito, or another primary.

Category 32 — Regulatory Pest Control

Rule 40-21-2-.01(j) covers State, Federal, or other governmental employees who use or supervise RUPs or state-restricted uses in the control of regulated pests. This is GDA Plant Protection, USDA APHIS, and similar official programs — not a private consultant who wants a "regulatory" title.

Rule 40-21-3-.01(b)(10) requires practical knowledge of laws relating to quarantine and regulation of pests; regulated pests; potential environmental impact of pesticides used in suppression and eradication programs; factors influencing introduction, spread, and population dynamics; and variations among geographic areas that allow valid judgments when emergency measures are invoked.

Georgia examples include imported fire ant quarantine movement of regulated articles, historical boll weevil eradication across the cotton belt, and emergency treatments when a new pest is detected at the Port of Savannah or a nursery. Eradication chemistry that would be excessive in a single peanut field may be used in an official program — and still has environmental impact the applicator must understand. A technique that works in south Georgia pine may fail in a mountain county; the rule asks you to judge new situations, not copy last year's map.

Category 33 — Demonstration and Research (add-on)

Rule 40-21-2-.01(k) covers people who demonstrate proper RUP use to the public — Extension specialists, county agents, commercial representatives, and public-program demonstrators — and people who conduct field research with RUPs. To be certified in Demonstration and Research requires prior certification in one or more of categories (a) through (j) — GDA 21–27, 35, 31, and 32.

Rule 40-21-3-.01(b)(11) repeats that 33 is an add-on requiring prior certification in competency clusters 1 through 10. Because the category covers teaching others, it also requires knowledge of a broad spectrum of pesticide uses, pesticide-organism interactions, and integrating non-chemical methods with pesticide use.

A UGA Cooperative Extension agent running a pecan spray plot in Albany needs the primary (typically 21) plus 33 if the work is demonstration or research under this category. A salesperson demonstrating a product at a Tifton field day is in the same add-on. GDA lists 0 recertification hours for 33; demo hours may combine with the primary (Chapter 3). 0 hours does not mean 33 is a major category.

Category 34 — Aerial Methods (add-on)

GDA's category page: individuals who have obtained Part 107 and/or Part 137 through the Federal Aviation Administration, and who are certified in one or more of (21) through (32), (38), and (41).

Rule 40-21-2-.01(l) describes aerial as persons licensed by the FAA for Agricultural Aircraft Operations who are also certified in categories (a) through (j) and (o) — a slightly older letter list. Rule 40-21-3-.01(b)(12) calls aerial an add-on requiring prior certification in clusters 1 through 10, proof of compliance with Title 14 CFR Part 137 (Agriculture Aircraft Operations), and a written exam on:

  1. Aerial application equipment, including pesticide dispersal accessories, their operation and calibration.
  2. Flight safety for protection of the public, including flight patterns, swath marking, turnaround, and obstructions.
  3. Personal safety for the pilot and ground personnel, including flagmen and loading personnel.

Study both snapshots. For the GDA card, expect Part 107 and/or Part 137 plus a primary from 21–32, 38, or 41. For the competency paper, expect Part 137 agriculture-aircraft rules plus dispersal calibration, swath and turnaround safety, and flagger/loader protection. A drone operator with only Part 107 and no primary category is not finished. A manned ag-plane operator with Part 137 who never sat a primary (cotton 21, mosquito 41, commodity fumigation 38, and so on) is not finished.

Georgia aerial sites include cotton and peanut custom application in southwest Georgia, mosquito adulticiding over coastal marsh, and forestry work. Turnaround over a school or highway, obstructions (towers, power lines, gin legs), and flagger exposure in the swath are the safety items. Loaders handle concentrate at the airstrip — often the highest exposure on the job. GDA lists 0 recertification hours for 34.

Category 35 — Industrial, Institutional, Structural, and Health Related

This is the loudest trap on the Georgia sitting. Category 35 is a GDA Pesticide Program commercial category. It is not the Georgia Structural Pest Control Commission (SPCC) Certified Operator path in household pest control (HPC), wood-destroying organisms (WDO), or fumigation (FUM). Termite work, household pest-control companies, and structural fumigation of buildings are SPCC, taught under a different commission. Do not sit Category 35 thinking you have earned WDO.

Rule 40-21-2-.01(h) covers commercial applicators using or supervising RUPs or state-restricted uses in, on, or around food-handling establishments, human dwellings, institutions such as schools and hospitals, industrial establishments including warehouses and grain elevators, and other structures and adjacent areas, public or private, and for the protection of stored, processed, or manufactured products.

Rule 40-21-3-.01(b)(8) — competency cluster 8, GDA number 35 — requires practical knowledge of a wide variety of pests and their life cycles; formulations appropriate for control; methods that avoid contamination of food, damage and contamination of habitat, and exposure of people, pets, and other animals; continuous exposure that may create a hazardous condition for babies, children, pregnant women, and the elderly; and environmental conditions related to this category.

Picture a warehouse on the Savannah port, a school kitchen in DeKalb, a hospital in Augusta, or a grain elevator in south Georgia protecting stored product. People occupy these sites all day, every day. A formulation and method that would be acceptable in an empty barn can be a continuous-exposure failure around children or elderly patients. Food-handling sites demand methods that do not contaminate food. That is Category 35 competency — still not SPCC termite treatment of a crawl space.

Category 36 — Wood Treatment

Rule 40-21-2-.01(m) is commercial applicators pressure treating lumber and timber with preservatives classified as restricted-use pesticides to protect products from termites, powder post beetles, other wood-destroying insects, surface molds, and wood-destroying fungi.

This is a treating plant — cylinders, retorts, RUP preservatives — not a truck treating a house. SPCC WDO remains the structural wood-destroying-organism operator credential. Category 36 does not issue that card. Know the pests the lumber is being protected from and the restricted-use preservative process.

Category 37 — Antimicrobial Pest Control

GDA's hours table may say Microbial Pest Control; the description is Antimicrobial. Rule 40-21-2-.01(n) covers commercial applicators who apply pesticides (disinfectants, sanitizers, algaecides, fungicides, and similar) to control undesirable or harmful algae, bacteria, fungi, and viruses in homes, institutions, medical facilities, industrial, and other sites.

This is hard-surface and water-system antimicrobial work, not crop fungicides (21/24) and not mosquito adulticides (41). Hospitals, food plants, and cooling towers are typical Georgia sites. Use-site and contact-time on the disinfectant label are the competency, even though 40-21-3(b) does not reprint a long 37 bullet list.

Category 38 — Agricultural Commodity Fumigation

Rule 40-21-2-.01(o) covers commercial applicators applying or supervising fumigants to control insect pests in raw or processed agricultural commodities. Think peanut warehouses, grain bins and elevators, and processed commodity stacks — not tenting a house. SPCC FUM is structural fumigation. Category 38 is commodity fumigation. A primary 38 can support aerial add-on 34 under GDA's list (21–32, 38, 41).

Category 39 — Antifoulant Paints

Rule 40-21-2-.01(p) covers commercial applicators applying antifouling paints classified for restricted use to water-going vessels to inhibit barnacles and algae. Georgia sites are Savannah, Brunswick, and coastal yards and marinas. This is not Category 26 aquatic herbicide work and not painting a barn.

Category 40 — Worker Protection Standard trainer subcategory

Rule 40-21-2-.01(q) : this subcategory is for those engaged in training workers and handlers as required by EPA's Worker Protection Standard. GDA lists 0 recertification hours. Category 40 documents WPS trainer authorization. It is not a major category that pairs with General Standards to finish commercial certification by itself, and it does not replace Chapter 15 WPS employer/handler duties.

Competency map for 32–40

GDA no.Rule 40-21-2Add-on?What it isWhat it is not
32 Regulatory(j)No (government)Quarantine, regulated pests, eradication programsPrivate "inspector" title
33 Demo/Research(k)Yes — prior (a)–(j)Extension, county agents, product demos, field researchA standalone major category
34 Aerial(l)Yes — FAA + primary 21–32, 38, 41Dispersal equipment; flight patterns/swath/turnaround/obstructions; flagger/loader safety; Part 137 (GDA also lists Part 107)Aerial without a primary; drone-only without GDA's listed credentials
35 Industrial/institutional/structural/health-related(h)NoFood handling, schools, hospitals, warehouses, stored products; continuous exposure to children/elderlySPCC HPC / WDO / FUM
36 Wood treatment(m)NoPressure treating lumber with RUP preservativesSPCC WDO house treatment
37 Antimicrobial(n)NoDisinfectants, sanitizers, algaecides in homes/institutions/medical/industrialCrop fungicide or mosquito adulticide
38 Ag commodity fumigation(o)NoFumigants in raw or processed commoditiesSPCC structural FUM
39 Antifoulant paints(p)NoRUP antifouling paint on vesselsAquatic pond herbicides
40 WPS(q)SubcategoryTraining workers and handlers under EPA WPSA major category; 0 recert hours

Exam traps for 32–40

  • 35 ≠ SPCC HPC/WDO/FUM. Repeat it until it is automatic.
  • 33 and 34 require a primary first. 40 is a subcategory with 0 hours, not a major.
  • Aerial competency includes flaggers and loaders, not only the pilot.
  • 36 is the cylinder at the treating plant; 38 is commodity gas; neither is structural fumigation of a house.
  • 39 is vessels at Savannah or Brunswick, not farm-pond algae (26) and not antimicrobial pool sanitizer (37).
Loading diagram...
GDA Categories 32–40: add-ons, Category 35 trap, and specialties
GDA recertification hours for Categories 32–40 (full rules in Chapter 3)
Test Your Knowledge

An Athens termite technician asks whether passing GDA Category 35 replaces the Structural Pest Control Commission Certified Operator exams in household pest control, wood-destroying organisms, and fumigation. Which statement is correct?

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Test Your Knowledge

What does GDA require before Category 34 Aerial Methods, and what does Rule 40-21-3-.01(b)(12) test on the category paper?

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Test Your Knowledge

Which statement about GDA Categories 36 through 40 is accurate?

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