11.3 Categories 7, 8, 9 & 10: Structural, Public Health, Regulatory & Research

11.3 Categories 7, 8, 9 & 10: Structural, Public Health, Regulatory & Research

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Category 7: Industrial, Institutional, and Structural Pest Control

Section 3(7) scope. Persons who use or supervise the use of pesticides in, on, or around food handling establishments, packing houses, and food-processing facilities; human dwellings; institutions such as schools, hospitals, and prisons; and industrial establishments including manufacturing facilities, warehouses, grain elevators, and any other structures and outside areas, public or private, for the protection of stored, processed, or manufactured products.

The category is divided into three subcategories:

7(a) Structural Pest Management

Section 3(7)(a). Persons who use pesticides, other than fumigants, to control pests, general pests, and wood-destroying organisms that threaten the structural integrity, the human occupancy, or the contents of such structures.

The regulation attaches a significant benefit to this subcategory: persons licensed under this section shall be exempt from the certification license requirements of other categories if using or supervising the use of pesticides to control pests, general pests, and wood-destroying organisms in outside areas related to a structure. A 7(a) licensee treating a perimeter band, a foundation trench, or an exterior harborage adjacent to the building it serves does not additionally need Category 3.

Section 5(7)(a) competency. Practical knowledge of a wide variety of pests including general pests and wood-destroying organisms - their life cycles, habits, types of formulations, insecticides appropriate for their control, minimum standards of application, and methods of application that avoid contamination of habitat and exposure of people and pets - and a practical knowledge of an integrated pest management program to determine if and when a treatment is needed. The regulation names the possible IPM components: education, proper sanitation, structural repair, mechanical control techniques, and pesticide application. Because human exposure is frequently a potential problem, the applicant must demonstrate practical knowledge of the specific factors that could lead to a hazardous condition, and because structural work may involve outdoor applications, of environmental conditions as well.

Kentucky practice: German and American cockroaches, bed bugs, commensal rodents, stored product pests in food plants, and subterranean termites treated by soil barrier, rod-and-trench, or baiting systems. Food-contact surface rules, crack-and-crevice volume discipline, and school and healthcare occupancy constraints dominate the day-to-day.

7(b) Structural Fumigation

Section 3(7)(b). Persons who use or supervise the use of a pesticide to fumigate anything other than soil, including structures intended for human occupancy. Section 5(7)(b) then imports an extensive eight-part standard covering labeling comprehension for non-soil fumigants; safety (exposure pathways, common mistakes, signs and symptoms, air concentrations requiring respirators or evacuation, what to do on sensory irritation, air monitoring, buffer zones and who may be in them, first aid, and labeling requirements for transport, storage, spill cleanup, and emergency response); chemical characteristics of non-soil fumigants including how they change phase and disperse and compatibility with tanks, hoses, and tubing; application methods, site characteristics, timing conditions such as air stability, temperature, humidity and wind currents, pre-application inspection, sealing methods, product quantity calculation, calibration, and air monitoring; pest factors including density and rate relationships; personal protective equipment including respirator medical evaluation, fit testing, cartridge replacement, and recordkeeping; fumigant management plans and post-application summaries - when the plan must be in effect, how long it is kept, where it is kept during the application, who has access, who verifies accuracy, and who prepares the post-application summary; and posting requirements including who may be in the area, the difference between labeling-required posting and treated-area posting with their pre- and post-application timeframes, and proper choice and placement of warning signs.

7(c) Wood Preservatives

Section 3(7)(c). Persons who apply pesticides to wood and wood products to protect from wood-destroying organisms; persons engaged in structural pest control are excluded from this subcategory.

Section 5(7)(c) competency. Practical knowledge in the use of wood preservatives, air monitoring procedures, personal protective clothing and equipment, hygiene, related health and safety measures, emergency procedures, and practices necessary to prevent environmental contamination. Kentucky operations are pressure-treating plants, crosstie and utility pole facilities, and remedial pole treatment - which is why RCRA drip-pad rules and containment sit at the center of the work.

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Category 8: Public Health Pest Control

Section 3(8) scope. State, tribal, federal or other governmental employees and contractors who use or supervise the use of pesticides in government-sponsored public health programs for the management and control of pests having medical and public health importance. As in Category 5, the regulation adds the one-way cross-over: applicators holding a public health license and engaged in public-health-related activities may make applications requiring an aquatic pest control license.

Section 5(8) competency. Practical knowledge of vector-disease transmission as it relates to and influences pesticide application programs. The standard is explicit that a wide variety of pests are involved and must be known and recognized, that appropriate life cycles and habitats must be understood as a basis for control strategy, and that the applicant must know a great variety of environments ranging from streams to conditions found in buildings. It requires knowledge of how to minimize damage to and contamination of areas treated, acute and chronic exposure of people and pets, and non-target exposures, and - a point candidates often miss - practical knowledge of the importance and employment of nonchemical control methods such as sanitation, waste disposal, and drainage.

Kentucky vector work: Culex and Aedes mosquito surveillance and larviciding, West Nile virus and La Crosse encephalitis, truck-mounted ULV adulticiding, tick-borne disease, and source reduction through drainage and container removal.

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Category 9: Regulatory Pest Control

Section 3(9) scope. State, tribal, federal, or other local governmental employees and contractors who use or supervise the use of pesticides in government-sponsored programs for the control of regulated pests. The regulation adds an express limitation: licensure in this category does not authorize the purchase, use, or supervision of use of products for predator control authorized under federal law.

Section 5(9) competency. Practical knowledge of regulated pests, applicable laws relating to quarantine and other regulation of pests, and the potential impact on the environment of pesticides used in suppression and eradication programs, plus factors influencing introduction, spread, and population dynamics of relevant pests. The regulation then says the knowledge shall extend beyond that required by their immediate duties, because regulatory personnel are frequently deployed to other areas of the country where emergency measures are invoked and individual judgments are necessary.

Kentucky context: emerald ash borer, spotted lanternfly, and thousand cankers quarantine and survey work; nursery and hemp inspection; cooperative USDA APHIS eradication programs.

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Category 10: Demonstration and Research Pest Control

Section 3(10) scope. Individuals who demonstrate to the public the proper uses and techniques of applying pesticides or supervise the demonstration - including extension specialists and county agents, individuals demonstrating methods used in public programs - and persons conducting field research with pesticides who apply or supervise applications, including state and federal employees.

Section 5(10) competency. Practical knowledge of the potential problems, pests, and population levels reasonably expected to occur in a demonstration situation and the effects of pesticides on target and non-target organisms; an understanding of techniques to mitigate effects of pesticides on non-target organisms; and - the requirement unique to this category - the applicant shall demonstrate competency in each pest control category applicable to their demonstrations, and persons conducting demonstration pest control work shall possess a practical knowledge in each pest control category applicable to their demonstrations.

That is the exam-relevant twist. Category 10 is not a shortcut around the other categories; it is layered on top of them. A researcher demonstrating an aquatic treatment must be competent in aquatic pest control as well.

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Master Comparison: Categories 7, 8, 9 and 10

Exam Alert: The 7(a) exemption for outside areas related to a structure is high-frequency. So is the one-way public-health-to-aquatic cross-over, the predator control limitation on Category 9, and the Category 10 requirement to be competent in each category applicable to the demonstration.