Structural Pest Control Board

May 2000 Newsletter


CorporateFranchise Tax
Frank M. Crull, General Counsel, Austin

 It is a licensing requirement of the Structural PestControl Board and other state agencies that corporations be in good standingwith the Comptroller of Public Accounts when applying and renewing theirlicenses.  The Office of theComptroller of Public Accounts has passed specific rules concerning thefranchise tax requirement.  TheRules of the Comptroller of Public Accounts are covered under Title 34 of theTexas Administrative Code.  Thespecific Comptroller Rule that covers the franchise tax-licensing requirement islisted as 34 Texas Administrative Code 3.544 (34 T.A.C. 3.544). The Internet website for this rule is http://info.sos.state.tx.us/. The website is maintained by the Secretary of States office.

 The Structural Pest Control Board asks for thiscorporate franchise tax information on the following forms: Application forBusiness License, Renewal Application for Business License and Application forBusiness Name Change.  When fillingout these forms, you are required to give your corporate franchise tax number. The Board will contact the Comptroller of Public Accounts to verify thisinformation.  If the Comptrollerreports back to the Board that the tax has been paid, the Board will go aheadand process the application.

 Ifthe Comptroller reports to the Board that a companys corporate franchise taxis delinquent, it is the companys responsibility to resolve the situationwith the Comptroller. The Comptroller will provide documentation showing that an account hasbeen paid. If you are originally listed as delinquent and then paid the owed tax,the Comptroller will issue a certificate showing that your account is paid infull. You will then need to forward that documentation to the Board forprocessing purposes. The business license will then be issued to the corporation, assumingthat there are no other problems.


NewLaw Book Available Soon!
Dianna Offen-Anderson, Newsletter Editor, Austin

A new look book is in the works.  This version will be ready for release this summer. We will again be following the 8 X 11 loose-leaf format that we usedfor the Orange Cover; however, this newest version, hopefully, will be easier touse.

We will also continue to have replacement pages availableon at least an annual basis, although we will be striving for a semi-annualpublication of replacement packets.

For your copy please forward your written request to us byeither regular mail, email or by fax.  Asbefore we will provide one copy to each business or noncommercial entity and weexpect copies to be made at the business discretion. As always, we will continue to update the pocket sized summaries on amore frequent basis.


AttorneyGeneral Referrals
Frank M. Crull, General Counsel, Austin

The following is a listing of individuals that havebeen referred to the Attorney Generals Office for violation of an existinginjunction or injunctive action for violating Section 593.1 of the StructuralPest Control Board regulations (operating without a license).

James Danzy                        Bill Chalker                  Sohail Shaikh   
Joe Moreno                          Sidney Woodall            John Trussell


NewBoard Policy Statements Adopted September 1999 

Use of Toll Free Telephone Numbers 
Business licensees may use a toll free number associated with the business on the face of any contract, warranty, invoice, termite treatment disclosure document or guarantee and other documents provided to consumers in lieu of or together with the telephone number of the local business address and/or post office box business address.
Consultants 

Consultants may inspect, make identifications, and make recommendations to licensed Texas Pest control Operators without a business license.  Consultants performing such services directly to the public, or actually performing such services by the use of insecticides, pesticides, or allied chemicals or substances, or mechanical devices for compensation for the public must obtain a business license and be certified in the categories in which they operate. 


Summaryof Regulation Changes With Effective Dates After September 1999
|DiannaOffen-Anderson, Newsletter Editor, Austin

 AdoptedSeptember 23, 1999 Changes Effective December 1, 1999

Section 593.5 -Examinations
Sets forth newtime lines and fees for tests.

Section 593.7 - Fees
New fee schedule

Section 593.21- Technician License Requirements
Fee change for application and category

Section 593.24- Criteria and Evaluation of Continuing Education
Fee Change on course teaching and proctoring requirement. 

 

Adopted September 23, 1999 Changes EffectiveSeptember 1, 2000

Section 591.11 - Determination of Administrative Penalties
Changein base penalty categories from 4 to 3, change wording from Hazardous to impacton public.


Adopted December 2, 1999 Changes Effective September 1, 2000

Section 593.1 - Persons Required to Secure License
Clarification ofDefinitions/Commercial Certified Applicator may be a certified applicator formore than one business license.

Section 593.6 - License Expiration and Renewal 
Wording changes to simplify language regarding expiration dates andretraining, changed time period that individual must be licensed as anoncommercial applicator prior to becoming a commercial applicator to 2 years.

Section 593.8 - Loss of Certified Applicator or Business Owner                           
Cuarto de alojamiento MarseilleClarification of wording Specific notification time limitincluded

Section 593.11 - Certified Noncommercial Applicator Restrictions.                               Pronoun/Grammatical Changes

 

Adopted February 15, 2000 Changes Effective June 1, 2000

593.23 - Continuing Education Requirements for Certified Applicators
Clarification of regulation, thenumber of credits that may be obtained from self-study or electronic means is 1per year, revised and relocated course submission criteria to section 593.24.

593.24 - Criteria and Evaluation of Continuing Education
Addition of course criteria from section 593.23, limits approval timeperiod to 2 years with resubmittal after 2 years with changes to course, changedfee for course submission to $40.00 per continuing education unit.

597.1 - Grounds for Revocation, Suspension, Penalties, Reprimanding, Refusal toExamine, Refusal to Issue or Renew Licenses.
Addition of further grounds for revocation failure to pay administrative penalty, failure to comply with sections 593.24 or595.11.

597.2-
Suspension or Revocation
Clarificationin wording - Added the word Revocation


Adopted February 15, 2000 Changes Effective September 1, 2000

593.2 - License Application 
Clarification of wording changed technician-apprentice to technician, added the phrase out of state

593.3 - Insurance Requirement
Clarification of word pronounchanges from him/his to applicant; requires application to obtain additionalinsurance if aggregate falls below $300,000 due to payment of claims.

593.4 - Resident Agent 
Clarification of Word Indicates the Texas Secretary of State

593.5 - Examinations 
Clarificationof Wording remove requirement that all exams be given in Austin, removerequirement that must skip a date before retesting, changed termite control totermite and wood destroying insect control, change wood to wood products, manygrammatical changes.

593.9 - Licensing Of Persons With Criminal Backgrounds 
Changed review of criminal records done byExecutive Director rather than board, added felony assault, pronoun changes,minor grammatical changes.

593.10 - Licensing of Persons With Delinquent Student Loans 
Clarification of Wording change in mandate from Administrative Procedure and Texas Register Act toAdministrative Procedure Act.

593.13 - Vegetation Management Technician 
Entire Regulation Repealed

593.21- Technician License Standards
Clarification ofWord; change apprentice required training hours to 20 general standards, 40 OJThours in each category, and 8 classroom hours in each category; add that somecollege credits may count towards training requirement; training records to bekept for 2 years; each technician must receive 8 hours per renewal period ofadditional training, after 1st licensing year.

Watch for Some Important Termite RegulationChanges in Our Next Newsletter Due Out July 2000

FollowingSpecific Label Directions During Application
Van Brock, Houston, Supervising Investigator

 The only important information on a termiticide label is not just the dilution rate.  There are other instructions that prove valuable when followed.  Things like how or even when to apply which certainly can affect the success of the treatment.  Termiticide labels have language like trench, rod and/or rod into a trench.  Rod into a trench means what it says and is not just another way of saying trench or rod.  If the label instructions say to rod into a trench that means the operator needs to first dig a trench, then rod down through the trench.  If rodding is done without a trench, any chemical that flows back up ends up in and on the surface of the soil.  If the rodding is done in a trench, any chemical that flows back up ends up in the trench that is going to be refilled.  There is a big difference. 

The time an application is made is also important.  Many product labels are such that they can be used in some areas but not others.  An example would

be that a certain product is allowed in non-food handling areas of a food-handling establishment but not in food-handling areas of the same establishment.  To add to the confusion, there are certain areas of such an establishment that may be considered food-handling at certain times of the day (such as when food is out and being prepared) but be considered non-food handling areas at some other time of the day (such as after all food has been removed ).  It is the responsibility of the pco to be familiar with the meaning of the terms food-handling and non-food handling as well as the operations of businesses they service.  This information needs to be considered by the pco when devising the plan of treatment including chosing which products can be used.  The pco needs to communicate with the management of such a facility to determine their activities and periodically to be reassured their timing for activities have not changed. 


Proposed Changes to the Technician TrainingStandards

Dianna Offen-Anderson, Newsletter Editor, Austin

This year a Technician Training Task Force was formed. The primary directive set forth to this task force was updating andstreamlining of the technician training requirements. The following is a summary of the changes that were proposed. Upon Board approval these changes have a planned effective date ofSeptember 1, 2000.

The number of classroom hours required in the GeneralStandards will change from 22 hours to 20 hours.  This was accomplished by combining two of the requiredsubjects (1) Emergency procedures and pesticide cleanup; and (2) Proceduresfor immediate reporting of spills and misapplications.

The On the Job or hands on training per categoryrequirement was decreased from Sixty hours (60) down to forty hours (40) percategory.  Additionally, eachindividual seeking to be a licensed technician must also obtain eight hours (8)of classroom training per category - this requirement was decreased from ten(10) hours.  Attendance in a Boardapproved technician training course will still be required prior to sitting forthe technician training exams.

After the first year as a license technician, thetechnician will now be required to obtain a minimum of eight hours (8) ofverifiable training per year two hours (2) of which may be either on the jobor hands on.  This change will takeapproximately one year to phase in depending on renewal dates of the business.

As always continuing education courses attended will counttowards the per category classroom training requirement on an hour-by-hourbasis.  Internet based training,videos, slides, and other training materials can be utilized to provide theannual training required of a licensed technician if the responsible certifiedapplicator verifies that the training provided is appropriate

Some examples of annual verifiable training for techniciansinclude:

  • A combination of attendance at CEU courses along with video or internet training of up to 6 total hours, with 2 hours of hands on training by the certified applicator, totaling 8 hours per year.
  • A training provider may offer 6 hours of training and the certified applicator may provide 2 hours of hands on training to totaling 8 hours per year.
  • Internet, videos and other training materials may be used by the certified applicator and/or a private provider to be verified by the Responsible Certified Applicator to completed the training.

There are many combinations of verifiable training that maybe utilized.  The ResponsibleCertified Applicator shall keep records of training received and will berequired to provide proof of verification to the Board upon request.


Be Prepared for Emergencies Before They Occur

Van Brock, Houston, Supervising Investigator

We have discussed earlier being prepared for emergencies such as leaks and spills but there are other types of situations a trainer would be wise to address in the training process.  A good training activity includes posing different scenarios to the service personnel and allow them to state how they would address the situation.

The discussion of the group oftentimes reveals there may be more than one solution to a problem, however, with the leadership of the trainer, the preferred method can be identified.

 By hearing their solution, the trainer gains a good perspective on how different individuals think.  How would your personnel address the following? 

  • The lady next door to where you just sprayed says her cat got sick.
  • The top came off the duster and all the dust spilled on the customers floor.
  • The hose blew off the pump and the chemical is in the street.

 

  • The technician came out of the customers house and found the neighborhood kids playing with the stuff in the back of the service truck.

These are just a few examples and you can think of many, many more.  There is no way to be prepared for every possible situation but you would be wise to be prepared for the more common and predictable circumstances.


Essential Elements of Contracts

Van Brock, Houston,Supervising Investigator

We spend a lot of time reading contracts as a part ofroutine complaint investigation and find a number of problems. The contract needs to clearly state all of the terms and not leaveanything open to interpretation (by the consumer or the legal system). The terms of the contract needs to state, among other things, what is tobe done by the PCO as well as what is expected of the consumer. Even though this information may be thoroughly discussed during the salespresentation, it is amazing how memories fail or differ whenever a disputearises.  It only makes good businesssense to have the necessary particulars included in the written contract. The PCO does not want to be held liable beyond what is agreed tooriginally and neither does the consumer have any legal right to expect any morebut the key here is, what does the contract state. An Investigator relies heavily on the terms of a contract wheneverinvestigating a complaint so, do yourself and all interested parties a favor andmake sure your contract states what you want it to state on the day of sale aswell as at some point in the future.  Furthermore,do not leave out important information and assume whoever reads thecontract is just automatically going to know some important piece ofinformation.  Dont forget, the reason a customer hired you was becausethey could not take care of a problem themselves. They do not have all the necessary expertise you have and that is the wayyou want it, otherwise, they would not need your services. But, along with that comes a responsibility for you to thoroughlyexplain, both orally during the sales presentation and in writing in thecontract, what is expected from both parties.  The written contract should be reviewed with the customer to point outimportant items that were discussed during the oral sales presentation. Most consumers will not take the time to read a written contract unlessforced to do so.  It reminds us ofthe old saying about how you can lead a horse to water but you cant makethem drink.  That saying is verytrue today but as a person in  business,you still need to continue to lead the horse to water. A properly written contract can be one of your best friends while apoorly written contract can be a nightmare.  


Maintain and Routinely Inspect All Spray Equipment and Service Vehicles  

Van Brock, Houston,Supervising Investigator

The SPCB receives some complaints that are both costly tothe company and harmful to the pest control industry by bringing unwanted andunnecessary media attention.  Thesetypes of complaints involve an accidental spill or pesticide run-off resultingin a pesticide ending up in a non-target area. The worst thing about these complaints is that most are avoidable. Many of the spills occur simply because equipment has become wornand undetected by the user.  Oftentimes, the run-off complaints could have been farless a problem if the operator had only been properly prepared by having thecorrect supplies and training to know what to do in case of an emergency. The pest control company owner/manager has many responsibilities but oneof the more important responsibilities is to keep a constant check on thecondition of the equipment used by their personnel and make sure that allemployees are properly equipped and trained to handle emergencies. A manager must routinely inspect service vehicles and equipment to beassured that worn or damaged equipment is repaired or replaced as necessary.  An inspection should also insure that proper clean-upmaterials are present and that all containers are properly labeled. New equipment is costly but a bargain when compared to the cost of payingfor the clean-up of a spill.  Weknow of incidents where the PCO was billed for the cost of Haz-Mat operations,disposal of material that was cleaned up and a fee for the use of police andfirefighter equipment including the time of the police officers andfirefighters.  One incident occurred simply because the operator ignoredrepairing a small leak that they knew about and continued to use the riguntil one day, it became a larger leak and was reported by an interestedcitizen.         

Sometimes, in spite of efforts to monitor andrepair/replace equipment, spills or leaks may still occur. It is at this time that being prepared is the most important. If  an operator has beenproperly trained what to do and if they have on-hand the necessary materials,the spill can be kept to a minimum and a thorough clean-up can occur in a timelymanner such that before the situation becomes an incident, it is over. The company and the industry have benefited from prompt, decisive actionand the impact against the environment has been held to a minimum. This positive outcome occurred as the result of the operator beingprepared.  Maybe that is what ismeant when it is said that an ounce of prevention (and preparation) is wortha pound of cure.


Step by Step, The Processing of a Complaint 
Judy Graven, Case Preparation Officer
 

To initiate an investigation the consumer must submit either a completed complaint form or a letter outlining the circumstances regarding the complaint to the Structural Pest Control Board office in Austin. 

Upon receipt of the written complaint, after review of the allegations, the priority is determined:

         Priority 1 Imminent Health Hazard immediate human exposure or environmental hazard, insurance lapse

         Priority 2 Health Related recent Human Exposure, fraud, evidence availability time restrictions

         Priority 3 Non-health related WDI Reports, disclosures, retreatments, licensing. 

If necessary, Priority 1 complaints may be relayed by telephone to the Board office, and the complaint will be initiated from the telephone conversation based upon the facts presented. 

At this point the complaint is assigned to an investigator.  The complaint is assigned based upon geographic guidelines set by the board. 

 Copies of the written complaint, and any applicable attachments are then forwarded to the assigned investigator.  The investigator will contact the complainant to schedule an appointment that will include an interview, and may also involve an inspection if necessary. 

After the complainant is interviewed, the pest control operator named in the complaint is contacted by the investigator.  The PCO is encouraged to provide any documentation or statements that would be helpful to the investigator.  This information may be either given directly to the investigator or, upon request, may be mailed to the SPCB office for inclusion in the complaint file. 

After the investigation has been completed the investigator will submit a written report to the SPCB office stating the facts, evidence found, general observations, and citing any violations, that were noted.  The investigator may also include their recommendations concerning the final disposition of the complaint, such as no action, warning letter, administrative penalty, license revocation, etc.  A final determination will be made by the General Counsel. 

 

If no violation is found the complaint will be closed with no action.  If a violation is found that requires an official warning letter to be issued then that warning letter is issued citing the specific violation and the consequences of future violations.  The warning letter becomes a permanent part of the PCO file. 

If a violation is found that requires an administrative penalty or revocation of licensure is proposed, a letter will be sent to the PCO notifying them of the proposed penalty or revocation of licensure.  The PCO will have twenty days to respond by either accepting the penalty and/or revocation., or request an informal meeting with the Executive Director or his designee to discuss the allegations. 

If the PCO agrees to the penalty and/or revocation, then the Executive Director will execute an Agreed Final order.

 If an informal meeting is requested, the time and date will be set and a written notification will be sent to the PCO.

 If an agreement can be reached during the meeting, a consent agreement will be drawn up.  The PCO and the Executive Directors signatures will be notarized.

 If an agreement cannot be reached, then an administrative hearing before the Administrative Law Judge at the State Office of Administrator Hearings will be scheduled.  At this hearing, the Structural Pest Control Board will present our evidence to the Administrative Law Judge and then the PCO will be allowed to present his/her evidence.

 Within 60 days after the hearing, the administrative law judge will submit a proposal for decision to the Structural Pest Control Board for approval.  Once the proposal for decision has been approved, a final order will be sent to the PCO notifying them of the decision and advising them of their rights to appeal the decision to the Travis County District Court.

 Any questions regarding complaints may be referred to Judy Graven, Case Preparation Officer at (512) 451-7200 or email judy.graven@spcbtx.org.


Examination Pass Rate For September1999 through March 2000

DiannaOffen-Anderson, Editor, Austin

 

September 1999 through March 2000

 

 

Total Tested

Pass

Fail

Percent Passed

Certified Applicators

1773

1014

759

57.19%

Technicians

1016

770

246

75.79%

Total

2789

1784

1134

63.97%

 

 

 

 

 


Self-Auditing What is it, and how do I do it?

Dianna Offen-Anderson, Newsletter Editor, Austin

In 1995, the Texas Legislature passed a new law designed to benefit businesses that are required to comply with the state's environmental health and safety laws including the Texas Structural Pest Control Act.  This law will allow limited privileges and immunities for businesses that conduct self-audits to determine their compliance with environmental laws.  How does this apply to you? 

In simpler terms what this means is that any business governed by an environmental health and safety law in Texas may perform a self-audit to monitor their own compliance with state laws and receive certain privileges and immunities for any violations found, reported, and corrected.  You may choose to have your Self-Audits performed by a contracting company. 

First of all, certain documents created during a self-audit are not subject to discovery by the Structural Pest Control Board or in civil litigation.  Take note, however, that this privilege does not extend to state required documents.  All documents found to be in violation must be marked Self-Audit Document in order to be extended immunity. 

Furthermore, any violations you discover, disclose and correct are not punishable by the Structural Pest Control Board.  This immunity does not apply for criminal acts or if there is a pre-existing pattern of disregard for the law or if management policies caused the violation. 

If you are interested in performing a self-audit at your business the following steps need to be followed: 

 

1.   Notifying the Texas Structural Pest Control Board in writing (by mail or fax) at least ten (10) days in advance of when you wish to begin conducting a self-audit.

2.  When the chosen day arrives, begin auditing your business for compliance with structural pest control laws and regulations (A sample list of items to check follows this Article).

3.  The self-audit must be completed within a reasonable time and in no case should it last longer than five (5) days. 

4.  Notify the Structural Pest Control Board in writing by certified mail of any violations found immediately.  Violations discovered by the Agency due to an investigation initiated prior to this notification are not covered.

5.  Take whatever action is  necessary to correct the violation yourself. 

A complete self-audit for purposes of complying with the laws and regulations of the Texas Structural Pest Control Board must include the following: 

         Licenses - Are all licenses for the business and employees involved in sales and service correct and in force?  

         Businesses Check Business Name, License Number, Categories of Service, Location Address/ Mailing Address, Responsible Certified Applicators, License Display, TPCL Number on Service Vehicles 

         Certified Applicators - Business Name, Location, Categories, Continuing Education Status, Supervision of Non-Certified Personnel 

         Technicians - Completed Training Course (by 9/1/96 if licensed before 9/1/91, Supervision of Certified Applicator, Business Name, Location, Categories Apprentice - Date of Hire, Training Records, Training Course Attendance, Business Name, Location, Categories, Supervision by Certified Applicator, On-Site supervision for those with incomplete training 

         Records- Two (2) Years of Use Records, Completeness of Use Records, Warranties/Contracts-Jurisdictional Statement, Pest Control Signs, Consumer Information Sheets, Records for School Contracts, Fumigation Records, Reduced Impact, Inspection & Use Records, Reduced Impact Consumer Information Sheet, Emergency waivers-48 hour Posting and 12 Hour, Re-Entry

 

         Termite Procedures- Approved Devices, Treatment Disclosure, Treatment Stickers, Wood Destroying Insect Reports, Inspection Stickers, Fumigation Records

 

         Advertising- Standard, Reduced Impact

 

         Insurance-In Force, Branch Address, Correct Business License Holder, Certificate Sent to SPCB by Agent

 

         Safety - Chemical Storage-Vehicle, Chemical Storage-Office, Personal Protective Equipment, Chemical/Rinsate Disposal, Labels, MSDS Sheets

 


Summaryof Administrative Penalties for FY 1999
Judy Graven, Case Preparation Officer, Austin

 

Section #

Nature of Violation

Number of Violations

Penalty Amount

593.1

Operating without a License

16

$ 38,823.01

595.11

Madrid hotel roomsFailure to Follow Procedures for IPM for Schools

3

$ 1,500.00

595.13 (8)

Advertising in a manner prohibited

1

$ 250.00

597.1 (1)

Misrepresentation, Fraud

2

$ 1,000.00

597.1 (2)

Misrepresentation on License Application

2

$ 2,000.00

597.1 (8)

Use Injurious

2

$ 500.00

597.1 (9)

Failure to Comply with Contract

3

$ 1,500.00

597.1 (11)

Failure to Register Employees

3

$ 2,000.00

597.1 (12)

Use Inconsistent with Labeling

31

$ 22,050.00

597.1 (13)

Failure to Maintain Proper Pest Control Use Records

13

$ 1,500.00

597.1 (17)

Failure to File Change of Address with Board

1

$ 1,000.00

597.1 (19)

Failure to Adequately Supervise Employees

3

$ 2,400.00

597.1 (21)

Failure to Maintain Proper Insurance Coverage

11

$ 6,000.00

597.1 (23)

Failure to Maintain Training Records

1

$ 500.00

599.3

Improper Pre-Construction Termite Treatments

14

$ 39,000.00

599.4

Failure to Provide Completed/Accurate Termite Treatment Disclosure Documents

8

$ 4,800.00

599.5

Failure to Follow Proper Inspection Procedures

8

$ 5,500.00

599.7

Failure to Post Notice of Inspection

1

$ 500.00

 

Totals

122

$130,823.01


Have You EverWondered?

When a pest control company buys another pestcontrol company are separate business licenses required?

        If the company is only purchasing the accounts and equipment andwill not be maintaining a separate location or separate phone number thenseparate business licenses are not required. 

        If the company is purchasing the name as well as the accounts andequipment and plans to continue to operate under that name then separatebusiness licenses are required.

        If the company is purchasing only the accounts and equipment butplans to continue to maintain the telephone numbers of the company purchased, nomatter how the line is answered or forwarded, separate business licenses arestill required.


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