Regulatory Brief

 Possible changes in EPA certification for pesticide use

Proposal:

 EPA is considering amendments to regulations that would require certification of users of both restricted and non-restricted conventional pesticides in all commercial settings. 

Brief Description and AVMA Response:

Currently, veterinarians are exempt from certification in their usage of restricted-use pesticides. The Environmental Protection Agency is considering requiring certification for those who use conventional pesticides in a commercial setting, including veterinarians who administer pesticides in the normal course of professional practice.

The AVMA is recommending to the EPA that veterinarians be categorically exempted from this certification process based on the education they received during their Doctor of Veterinary Medicine degree. Veterinary training includes physiology, toxicology, pharmacology, pathology, jurisprudence, and public health courses, which provide expertise in pesticide usage and safety.

The AVMA cites in their letter to the EPA that several government agencies authorize veterinarians to handle potent medical agents in the course of their practice. For example, the FDA authorizes veterinarians to prescribe prescription drugs for animals, the DEA allows veterinarians to prescribe controlled substances, and USDA recognizes veterinarians as professionals who may vaccinate animals for the advancement of national animal disease control and eradication programs.

The EPA has held a long-term exemption for veterinary practitioners, which allows them to forgo certification for the use of restricted-use pesticides. It is both reasonable and appropriate that this exemption be extended to the use of conventional pesticides.

Full AVMA response:

View AVMA's first response to the EPA (PDF) (November 29, 2006)

Status:

The EPA wrote to the AVMA and assured the organization that, barring new information; veterinarians would retain current exemptions and not be subject to additional certification.